New decree regarding the monitoring of pressure equipment (PE)

A new decree from November 2017 standardizes the monitoring rules for pressure equipment. It extends inspection and requalification intervals and allows for monitoring with or without an inspection plan.

Marie Faucon
Consultante HSE
Publication : 
02.03.2018
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

In-service monitoring of pressure equipment and simple pressure vessels (such as boilers, autoclaves, piping, compressors, fire extinguishers, etc.) is now governed by the decree of November 20, 2017 [1]. This decree consolidates all applicable regulatory provisions, previously scattered across several decrees, professional guides, and technical manuals, into a single text. Consequently, it repeals 27 decrees, including the one dated March 15, 2000 [2]. It has been in effect since January 1st , 2018.

We invite you to review this new decree, specifically the key changes compared to the March 15, 2000 version.

Pressure equipment concerned

The decree of November 20, 2017, establishes the procedures for the in-service monitoring of the following pressure equipment and simple pressure vessels (SPVs):

Equipment type Characteristics
Vessel intended to contain a hazardous gas (Group 1) Maximum allowable pressure (PS) × volume (V) > 50 bar.litres, unless V ≤ 1 litre and PS ≤ 200 bar
Vessel intended to contain a non-hazardous gas (Group 2) other than steam or superheated water PS × V > 200 bar.litres, unless:
  • V ≤ 1 litre and PS ≤ 1,000 bar
  • PS ≤ 2.5 bar for quick-release removable-cover vessels
  • PS ≤ 4 bar for other vessels
Steam or superheated water vessel PS × V > 200 bar.litres, unless V ≤ 1 litre
Steam generator V > 25 litres
Piping intended to contain a hazardous gas (Group 1) Nominal size > DN 100 or PS × DN > 1,000 bar, unless nominal size ≤ DN 25
Piping intended to contain a non-hazardous gas (Group 2), including steam and superheated water Nominal size > DN 100 and PS × DN > 3,500 bar
+ Pressure accessories fitted on the above equipment (e.g. valve, pressure regulator, pressure gauge)
+ Safety accessories fitted on the above equipment (e.g. safety valve, rupture disc)

Content of the decree of November 20, 2017

The decree defines:

  • general conditions for the installation and operation of equipment;
  • obligations regarding personnel: resources, information, and competence;
  • documentation requirements: maintaining and updating a list of fixed vessels, steam generators, and piping subject to in-service monitoring obligations (including decommissioned equipment or installations), and an operating file for each piece of equipment;
  • specific requirements for steam generators, quick-opening pressure vessels (QOPVs), and safety accessories;
  • procedures for declaration and commissioning inspection: equipment covered, the LUNE online service, performance of the inspection by an authorized body (OH) or a recognized inspection service (SIR) for steam generators and quick-opening pressure vessels (ACAFR), and performance of the inspection by a competent person for other equipment;
  • obligations related to the different types of interventions (major, significant, or non-significant).

In addition, equipment falling within the scope of the order must be subject to in-service monitoring:

  • either according to an inspection plan as per the procedures in the "In-service monitoring with inspection plan" chapter of the order;
  • or based on the periodic inspections and requalifications prescribed by the order in its "In-service monitoring without inspection plan" chapter.

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

Note: the operator of a pressure equipment (ESP) or a pressure vessel is the owner of the equipment, their agent, or designated representative.

Key changes to pressure equipment regulations

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

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

Conclusion

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

  • evaluate the feasibility and benefits of implementing a monitoring system with an inspection plan if you have a significant number of PEs and SPVs;
  • adjust upcoming inspection and requalification dates according to the chosen regime;
  • review and update your equipment list;
  • verify the contents of your PE operating files.

[1] Decree of November 20, 2017, regarding the in-service monitoring of pressure equipment and simple pressure vessels [JORF of December 3, 2017]

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

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