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The Transportable Pressure Equipment directive
Purpose Directive 1999/36/EC, the Transportable Pressure Equipment Directive, also known as the TPED is one of a series of measures implementing ADR - the European agreement on the International Carriage of Dangerous Goods. It is implemented in the UK along with ADR by The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2004 The purpose of the TPED is to provide for a legal structure whereby pressure equipment to be transported under pressure can be manufactured and sold and used throughout the European community without having to go through a local approval regime in every member state and can be transported between EU member states and beyond. The means by which this is achieved is to ensure common standards of design, manufacture, testing and certification in all transportable pressure equipment sold and used within the European Economic Area. Manufacturers, and owners of cylinders for compressed gases are therefore able to meet the requirements for approval in any member state of the EU, and do not have to repeat the process when selling goods in any other state. In most cases, clearly, manufacturers will have their equipment approved in their home state. Manufacturers outside of the EU may also have approvals and test work undertaken at their own factory (and in all cases this is obligatory) but responsibility for compliance with the requirements of the directive will ultimately rest on the person responsible for placing the product on the EU market place as well as suppliers of compressed gases, who transport their goods in cylinders.
Scope The Directive applies to the design, manufacture, conformity assessment and periodic reassessment of transportable cylinders, tubes, cryogenic vessels and tanks for transporting gases as well as hydrogen cyanide, hydrogen fluoride and hydrofluoric acid. It also covers their associated valves and other pressure equipment. Most of this equipment was subject to earlier national regulations. Both refillable and non-refillable cylinders are included. It applies not only to new equipment but also to existing equipment which must be reassessed at the time of its periodic inspection under the ADR regulations. Typical examples of pressure equipment covered include:
Pressure vessels and apparatus used for non-transport related applications will usually be within the scope of the Pressure Equipment Directive 97/23/EC instead.
Exclusions Equipment placed on the market before 1st July 2001 does not require initial conformity assessment but must be reassessed at the time of its periodic inspection under the ADR regulations as defined in the ADR packing instruction P200 and dependent on the gas carried. Other specific exclusions are:
Implementation dates The implementation date for the Directive in all member states is 1 July 2001. During a transitional period up to 1 July 2003, member states could permit the placing on the market of any equipment which complies with the legislation in force in that state on 1 July 2001.
Structure The Directive defines 3 categories for pressure equipment, based on its pressure volume product (P.V) in bar.litres and hence its stored energy. Assessment and conformity procedures are different for each category, ranging from occasional auditing of test procedures for the lowest (category I) hazard up to full ISO9001 quality management and/or notified body type examination for category 3 equipment. The assessment procedures are arranged in a modular structure and manufacturers have the choice of which modules to select (within pre-determined combinations) in order to best suit their application and manufacturing procedures.
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Aspects of the design, production and testing of the equipment are the subject of a large number of harmonised standards, many of which are still in the process of being produced. They cover all aspects of equipment design and production, including dimensions, materials, welding and test methods. In some cases manufacturers will be required to operate strictly within the guidelines imposed by these standards, whereas in other circumstances application of standards, while not compulsory, will considerably simplify compliance with the essential requirements of the directive. National conformity assessment is still allowed as an alternative with approval by an approved body and conformity assessment by A1, C1, F & G. These products cannot bear the pi mark and cannot be used for international transport. This provision was to be reviewed in 2004.
Protection requirements The Directive itself contains no safety requirements. Instead it refers to the requirements set out in Chapter 6.2 of Annex A of ADR. These are set out according to the 'old approach' with detailed technical requirements covering design, materials, openings, fittings, etc as well as a list of standards giving presumption of conformity with the requirements of ADR. The filling pressure of cylinders is to a large extent defined in the packaging instructions of ADR. It should not be assumed that gases can be transported at a pressure chosen by the cylinder manufacturer or user.
Administration requirements In addition to ensuring that the equipment is capable of meeting the performance requirements of the directive, manufacturers must also complete a specified declaration of conformity and they must compile and maintain a technical file of information about how the equipment was designed and manufactured and supply it to the Notified body. There is no requirement for instructions. Instead, detailed instructions for use, transport, filling, regular inspection, training of drivers etc. are contained in ADR, particularly in packaging instruction P200 concerning gas cylinders. According to ADR section 6.2.1.7, new cylinders must be marked with following particulars in clearly legible and durable characters:
Non-refillable receptacles must also be marked with:
Safety related valves are required to be pi marked or CE marked for the PED. Other valves require no special markings. Old cylinders must be marked with the Pi mark, Notified or Approved Body number and inspection date when they pass their first periodic inspection after the introduction of the TPED. Although the wording of the Pressure Equipment Directive (PED) 97/23/EC and TPED is not clear, European Commission guidelines interpret that although it is permissible to incorporate pi-marked pressure equipment into a CE marked pressure system without further assessment, it is not permissible to use CE marked cylinders for transporting compressed gases. They must be re-assessed to the TPED and pi-marked. The reason for this is that the Conformity Assessment Procedures for the TPED are stricter and always require notified body certification whereas pressure vessels in the lower categories of the PED can be self-assessed and certified by the manufacturer. Please see: http://ec.europa.eu/enterprise/pressure_equipment/ped/index_en.html. Overall the requirements of the directive are difficult to understand because it refers for much of its detail to ADR, which is a very detailed directive running to nearly 1000 pages of prescriptive technical requirements. There is a lack of information available to the uninitiated. However if the manufacturer of the equipment designs it according to approved design standards and follows the instructions of his chosen notified body for manufacture, testing and final inspection, then the equipment will comply.
Useful links The European Commission have a special section on transportable pressure equipment on their EUROPA server with links to the guidelines and the text of the directive. The most up to date requirements of ADR are most easily read at The United Nations Economic Commission for Europe (UNECE) web site. Section 6.2.2 of Annex A of the ADR directive 94/55/EC has a list of standards providing presumption of conformity with the requirements of the directive. It can be downloaded from Eur-Lex, EUROPA's legislation database. Useful information may also be found on the Health and Safety Executive web site, particularly a list of notified and approved bodies in the UK Most PED Notified Bodies are also notified for the TPED. The Department for Transport has some background reading. Links to some bodies notified under the directive can be found on our Notified Bodies page.
Further Advice As with all directives, the actual requirements for any piece of equipment under the directive are complex and dependent on not only the design but also the type of user, the intended use and sometimes even what is claimed in the instructions or sales literature. For further advice specific to your products, please contact us at Conformance and we will be pleased to discuss your needs. If you'd like us to prepare a no-obligation quote for assisting you with CE marking your products, please take a look at our page which gives details of the information required in order to be able to give you an accurate idea of the costs and procedures involved.
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