Focus on pressure equipment regulations

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Found in industrial environments as well as in our daily lives (gas stations, hospitals, shopping centers, etc.), pressure equipment (PE) serves a wide variety of functions.

This includes boilers, expansion vessels, autoclaves, compressors, gas tanks and cylinders, refrigeration units, and more.

If poorly designed, inadequately maintained, or not inspected, these can cause fatal injuries to operators and bystanders, as well as damage to facilities and equipment.

To anticipate and prevent accidents, European and French law has established a framework for the operation of such equipment. Current regulations are primarily based on theorder of November 20, 2017.

How do you identify pressure equipment?

Pressure equipment consists of devices or enclosures used for production or manufacturing that contain a fluid (gas, liquid, or vapor in a pure phase or mixture) at a pressure greater than 0.5 bar.

This can include:

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

Equipment meeting the conditions presented in the table below is subject to the in-service monitoring described in the order of November 20, 2017.

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Group 1 hazardous gases (according to the CLP classification) are defined as gases that are: unstable explosives or explosives of divisions 1.1, 1.2, 1.3, 1.4, and 1.5,

• flammable, category 1 or 2;
• oxidizing, category 1;
• acutely toxic by oral route, category 1 or 2;
• acutely toxic by dermal route, category 1 or 2;
• acute inhalation toxicity category 1, 2, or 3;
• specific target organ toxicity following single exposure category 1.

How can pressure equipment be operated safely?

To ensure the safe operation of pressure equipment, the operator must meet general installation and operating requirements. In particular, they must:

• Define the conditions for use, maintenance, and inspection of each piece of equipment, taking into account the conditions for which it was designed and manufactured. The installation, commissioning, operating, and maintenance conditions defined by the manufacturer, particularly those indicated on the equipment or in its instruction manual, must be followed;
• Have the necessary personnel available for the operation, monitoring, and maintenance of their equipment. Personnel responsible for the operation and maintenance of equipment must be informed and competent to monitor and take any necessary action for their safe operation;
• Maintain an up-to-date list of fixed vessels, steam generators, and piping subject to in-service monitoring requirements, including equipment or installations that are out of service. This list must indicate, for each piece of equipment:
  • The type;
  • The monitoring regime (with or without an inspection plan);
  • The dates of the last and next inspection;
  • The dates of the last and next periodic requalification.
• Establish an operating filein paper or digital format, containing the information necessary for its safe operation, maintenance, inspection, and any potential repairs. This operating file must be updated and kept for the entire service life of the equipment.

The list of fixed vessels, steam generators, and piping, as well as the operating file, must be made available to the inspectorate and any personnel involved during an HSE compliance audit.

Furthermore, this pressure equipment is subject to regulatory inspections throughout its service life.

How can I ensure proper in-service monitoring of my pressure equipment?

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

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The commissioning declaration is required before the first use of the equipment in question. It is completed by the operator via electronic declaration using the LUNEapplication.

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

The commissioning inspection must be performed by an authorized body for:

• Steam generators;
• Fixed quick-opening pressure vessels.

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

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

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

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

Monitoring with an inspection plan requires defining the minimum surveillance actions to be carried out so that a pressure vessel undergoes a complete examination between its commissioning and its first periodic requalification, and subsequently between two periodic requalifications. These actions must be defined in an inspection plan. It must be established in accordance with professional guides or professional technical manuals (CTP) approved by ministerial decision as listed in Annex 2 of the decree. These include the professional guides applied by SIRs (e.g., DT32, DT84, DT82, etc.) as well as CTPs targeting specific categories of equipment (e.g., CTP on the in-service monitoring of pressurized refrigeration systems, on the periodic inspection of heat exchangers in district heating networks, etc.). As of^{January 1st,} 2021, in-service monitoring according to a professional guide or professional technical manual must be carried out in accordance with a formalized inspection plan.

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

The difference between the two monitoring methods relates in particular to the intervals between two periodic inspections or two periodic requalifications, with the inspection plan solution allowing for these intervals to be extended. Regardless of the option chosen (with or without an inspection plan), the in-service monitoring of pressure equipment includes periodic inspections and requalifications at regular intervals.

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

• External inspection;
• Inspection of safety accessories;
• Additional investigations, as necessary.

It is carried out by:

• An authorized body or an internal inspection service (SIR) for equipment with quick-opening removable covers, steam generators operated without permanent human presence, and equipment with internal and/or external linings that are not exposed;
• A competent person under the responsibility of the operator for other equipment.

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

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

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

Note : transportable pressure equipment is subject to the periodic inspections provided for in chapter 6.2 of the ADR. The intervals for hydraulic pressure tests are set by ADR packing instruction P200.

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Photo credit: iSawRed