Focus on pressure equipment regulations

Present in the industrial environment, but also in our daily lives (service stations, hospitals, shopping centers, etc.), pressure equipment (ESP) performs a wide variety of functions.

These may include boilers, expansion vessels, autoclaves, compressors, gas tanks and cylinders, refrigeration units, etc.

Poorly designed, poorly maintained and uncontrolled, they can cause fatal injuries to operators and bystanders, as well as damage to plant and equipment.

In order to anticipate and prevent any accidents, European and French law has established a framework as to the operation of such equipment. Current regulations are mainly based on thedecree of November 20, 2017.

How to recognize pressure equipment

Pressure equipment is equipment or enclosures used for production or manufacturing purposes, containing a fluid (gas, liquid or vapor in pure phase or as a mixture) at a pressure greater than 0.5 bar.

These may include :

• fixed" pressure equipment (including diving cylinders and fire extinguishers);
• transportable pressure equipment (such as LPG cylinders, pressure drums, etc.).

Equipment meeting the conditions set out in the table below is subject to pressure equipment regulations.

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Group 1 hazardous gases (according to CLP classification) include: unstable or explosive gases in divisions 1.1, 1.2, 1.3, 1.4 and 1.5,

• Category 1 or 2 flammables;
• Category 1 oxidizers ;
• Category 1 or 2 acute oral toxicity;
• Category 1 or 2 acute toxicity by the cutaneous route;
• Category 1, 2 or 3 acute inhalation toxicity;
• Category 1 specific target organ toxicity by single exposure.

How to operate pressure equipment safely?

To ensure the safe operation of pressure equipment, the operator of such equipment must comply with general installation and operating conditions. In particular, he must :

• Define the conditions of use, maintenance and inspection of each piece of equipment, taking into account the conditions for which it was designed and manufactured. The conditions of installation, commissioning, use and maintenance defined by the manufacturer, in particular those shown on the equipment or its instruction manual, must be respected;
• Have the personnel required to operate, monitor and maintain its equipment. Personnel in charge of equipment operation and maintenance must be informed and competent to supervise and take any initiative required for safe operation;
• Keep an up-to-date list of fixed vessels, steam generators and piping systems subject to in-service monitoring obligationsThis list must include any equipment or installations that are out of service. This list must indicate, for each piece of equipment :
  • Type;
  • Surveillance regime (with or without inspection plan) ;
  • The dates of the last and next inspections;
  • Dates of last and next periodic requalification.
• Draw up an operating file, in paper or digital form, containing the information required for safe operation, maintenance, inspection and any necessary servicing. This operating file must be kept up to date and retained throughout the equipment's lifetime.

The list of fixed vessels, steam generators and piping, together with the operating file, must be made available to the inspectorate and any other party involved in an EHS compliance audit. EHS compliance audit.

What's more, pressure equipment is subject to regulatory inspections throughout its life.

How can I ensure that my pressure equipment is properly monitored in service?

Certain pressure equipment is therefore subject to declaration and commissioning inspection. This applies to equipment with the characteristics listed in the table below.

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The declaration of commissioning is required before the equipment in question is used for the first time. It is made by the operator by remote declaration via the LUNE APPLICATION.

The purpose of the commissioning inspection is to check that the pressure equipment, once installed, meets the general installation and operating conditions for safe use. It must be carried out before the pressure equipment is used for the first time.

The commissioning inspection must be carried out by an authorized body for :

• Steam generators ;
• Appliances with removable lids and fixed quick-release fasteners.

For other equipment (piping, containers, etc.), this inspection can be carried out by a competent person.

Note: for equipment subject to declaration and commissioning inspection, operating personnel must be formally recognized by the operator as qualified to operate the equipment, and periodically confirmed in this role.

In addition, equipment falling within the scope of the Order of November 20, 2017 must be subject to in-service monitoring :

• Or according to an inspection plan drawn up by a competent person under the responsibility of the operator and approved by an authorized body or a Recognized Inspection Service (SIR) or by the operator for piping systems not subject to requalification (i.e. piping systems not subject to declaration and commissioning inspection);
• Or on the basis of the periodic inspections and requalifications prescribed by the Order of November 20, 2017.

Follow-up with an inspection plan involves defining the minimum surveillance actions required to ensure that pressure equipment undergoes a complete examination between commissioning and its first periodic requalification, and again between two periodic requalifications. These actions must be defined in an inspection plan. It must be drawn up in accordance with the professional guides or professional technical specifications (CTP) approved by ministerial decision and listed in Appendix 2 of the Order. These include the professional guides applied by SIRs (e.g. DT32, DT84, DT82, etc.), as well as CTPs for specific categories of equipment (e.g. CTPs on the in-service monitoring of pressurized refrigeration systems, on the periodic inspection of heat exchangers in district heating networks, etc.). From January^1, 2021, in-service monitoring based on a professional guide or technical specification must be carried out in accordance with a formal inspection plan.

This inspection plan is set up under the responsibility of the operator and is subject to approval by an authorized body.

The difference between the two monitoring methods concerns the time between two periodic inspections or two periodic requalifications, since the solution with an inspection plan extends these times. Whatever the option chosen (with or without an inspection plan), in-service monitoring of pressure equipment involves periodic inspections and requalifications at regular intervals.

The periodic inspection must cover both the equipment and the pressure and safety accessories connected to it. It includes the following points in particular:

• External verification ;
• Checking safety accessories ;
• Further investigations as required.

It is produced by :

• An authorized body or a CRS for equipment with quick-closing removable lids, steam generators operated without a permanent human presence and for internally and externally coated equipment that is not exposed;
• A competent person under the operator's responsibility for other equipment.

The requalification requalification includes, in order (unless otherwise specified in a professional guide or technical specification):

• Verification of the existence and accuracy of the operating file;
• An inspection;
• A hydraulic test ;
• Checking pressure and safety accessories, as well as control devices.

They must be carried out under the responsibility of an authorized body.

Note: Transportable pressure equipment is subject to the periodic inspections stipulated in Chapter 6.2 of the ADR. Hydraulic test intervals are set out in ADR packing instruction P200.

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