Pressure equipment: new order

In-service monitoring of pressure equipment and simple pressure vessels (such as boilers, autoclaves, piping, compressors, extinguishers, ...) is now governed by the Order of November 20, 2017 [1]. The latter brings together, in a single text, all the applicable regulatory provisions dispersed in several orders, professional guides and professional technical specifications. As a result, it repeals 27 orders, including that of March 15, 2000 [2]. It has been applicable since January^1, 2018.

We'd like to give you an update on this new decree and, in particular, its main changes compared with the decree of March 15, 2000.

Pressure equipment concerned

The Order of November 20, 2017 sets out the procedures for in-service monitoring of the following pressure equipment and single pressure vessels (SPVs):

Type of equipment	Features
Container for hazardous gas (Group 1)	Maximum allowable pressure (PS) × volume (V) > 50 bar.liters, unless V ≤ 1 liter and PS ≤ 200 bar
Container for non-hazardous gases (Group 2) other than steam or superheated water	PS × V > 200 bar.liters, unless : V ≤ 1 liter and PS ≤ 1,000 bar PS ≤ 2.5 bar in the case of a device with a removable quick-closing lid (ACAFR) PS ≤ 4 bar for other containers
Steam or superheated water container	PS × V > 200 bar.liters, unless V ≤ 1 liter
Steam generator	V > 25 liters
Piping designed to contain a hazardous gas (Group 1)	Nominal size > DN 100 or PS × DN > 1,000 bar, unless nominal size ≤ DN 25
Piping for non-hazardous gases (Group 2), including steam and superheated water	Nominal size > DN 100 and PS × DN > 3,500 bar
+ Pressure accessories installed on the above equipment (e.g., valve, pressure regulator, pressure gauge)
+ Safety accessories installed on the above equipment (e.g. safety valve, bursting disc)

Contents of the order of November 20, 2017

The order defines :

general conditions of installation and operation of equipment;
obligations relating to personnel: resources, information, skills ;
documentation obligations: keeping and updating a list of fixed vessels, steam generators and piping systems subject to in-service monitoring obligations (including equipment or installations that are no longer in service), and an operating file for each piece of equipment;
special features for steam generators, quick-closing removable lid appliances (ACAFR) and safety accessories;
declaration and commissioning inspection procedures: equipment concerned, LUNE teleservice, inspection by an authorized body (OH) or a recognized inspection service (SIR) for steam generators and ACAFRs, inspection by a competent person for other equipment;
the obligations associated with the different types of intervention (major, significant or not significant).

In addition, equipment falling within the scope of the decree must be monitored in service:

or according to an inspection plan as described in the "In-service monitoring with inspection plan" section of the decree;
or on the basis of the periodic inspections and requalifications prescribed by the decree in its chapter on "In-service monitoring without an inspection plan".

Note: the inspection plan must be drawn up by a competent person under the responsibility of the operator, and approved by the operator for piping not subject to requalification, or by an OH or SIR for other equipment.

Note: the operator of an EHV or pressure vessel is the owner of the equipment, his or her agent or designated representative.

Main developments in pressure equipment

The order of November 20, 2017 repeals and replaces the order of March 15, 2000. The main changes in relation to this order are as follows:

It is now possible to opt for in-service monitoring WITH or WITHOUT an inspection plan;
All ESPs subject to a declaration of commissioning are now also subject to a commissioning inspection (same scope of application for both obligations);
Contents of the list of fixed equipment: it is no longer mandatory to indicate the risk category (I to IV), but the in-service monitoring regime (with or without inspection plan) must be specified;
Contents of the operating file for each ESP: the in-service monitoring regime must be indicated;
Inspection frequencies are expressed in full years rather than months;
The frequency of periodic inspections for ESPs monitored without an inspection plan has been extended to 2 years instead of 18 months for steam generators and equipment with quick-closing removable covers (ACAFR);
The frequency of periodic inspections of ESPs monitored without an inspection plan (other than steam generators, ACAFRs and piping systems) has been increased from 40 months to 4 years;
The inspection and requalification periods for ESPs covered by an inspection plan are set at 6 and 12 years respectively, except in special cases;
The frequency of requalification of containers or piping subject to declaration and commissioning inspection containing a toxic or corrosive fluid with respect to the walls of the ESP is set at 6 years (instead of 5 years).

Conclusion

If you have any of the ESPs or RPSs concerned(boilers, autoclaves, piping, compressors, fire extinguishers, etc.), the publication of this new order is an opportunity to check that your management is compliant. We therefore recommend that you take the following actions:

study the opportunity and interest of setting up a follow-up with an inspection plan if you have a sufficiently large number of ESPs and RPSs;
reschedule the next inspection and requalification dates according to the chosen system;
update your equipment list ;
check the contents of your ESP operating files.

[1] Arrêté du 20 novembre 2017 relatif au suivi en service des équipements sous pression et des récipients à pression simples [JORF du 3 décembre 2017]

[2] Decree of March 15, 2000 on the operation of pressure equipment [JORF of April 22, 2000].

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