PED Intentions and development

Development of PED and guidelines Analysis of the status quo Definition of aspired scenario Possible revision of PED Possible revision or restructuring of guidelines

Primary Intentions Free movement Harmonisation Common safety level Improve competitiveness of manufacturer Improve competitiveness of European Code on Pressure Equipment

Free movement Prior PED Afterwards 15 different Pressure Codes, multiple examinations, waste of time and resources Afterwards still different national Pressure Codes, but acceptance of conformity procedures of PED, some problems with in-service inspection and notified Bodies

In-service inspection In-service inspection is not covered by the scope of PED Annex I PED offers a broad range of technical solutions Required extent and kind of in-service inspection determined by the technical solution chosen

Complicacies in the context of In-service inspections PED requirements on information's for the user Information exchange between manufacturer and user Different design solutions (based on different Codes) permissible Inspection bodies often familiar only with their National Codes

Harmonisation Defined in Art. 95 of the Treaty, PED matches harmonisation on: Conformity assessment Essential safety requirements Partly on Notified Bodies No harmonisation on: Specific technical requirements Appointment and surveillance of N.B.

Common safety level Established national Codes still used, minor changes Decline of safety is observed by mass produced vessels from third countries Total harmonisation could not achieved by New Approach Directives

Specific technical requirements Predominance of national Codes, especially of AD-Merkblatt, BS 5500, Codap, ASME EN 13445 is slow in demand Some EN are delayed The introduction of a CEN consultant has improved considerably the link between PED and standardisation

Appointment and surveillance of Notified Bodies Recently discussions to improve the importance of accreditation CIRCA System has achieved better transparency and information exchange between Member States Discussions on the role of the EA have started

Competitiveness of manufacturer National protectionism is reduced Better access to markets of other M.St. The new approach concept of PED has downgraded the situation of European manufacturer on the global competition

Competitiveness of European Code on Pressure Equipment PED as an umbrella for several national Pressure Codes is not accepted as an European Code Other Codes may prevail in the global competition

Role of the guidelines Community legal system has no obligatory formal possibility to interpret a Directive Harmonized standard are only specifying essential safety requirements Interpretation of Directives is in the responsibility of the Member States Diversity of interpretation should be avoided Guidelines are a tool to close the legal gap and help to improve harmonisation

Feasible scenario of the development of PED Specific regulations will be predominated by ASME, this will cause a burden for European PE technologic development Increasing bureaucracy on accreditation will cause additional economic charges for Notified Bodies,which could be a burden for their technical judgement The New approach concept will reduce technical barriers of trade in Europe, but not in Third countries

Aspired scenario of development Concentration of engineer recourses on an accelerated development of a common European standard on PE ? Competition of different national Codes fulfilling the ESR, but introduction of an “Annex ZA” procedure for national Codes ? Revision of PED has to reflect the chosen aim

Basic goals Promotion of an European way of pressure equipment technology Access to further development remain in Europe New approach principle should not lead to randomness in fulfilling the ESR High safety level could be kept Strengthen the position of European manufacturer in the global competition

Consequences Narrow the room for interpretation by including guideline solutions in the PED National Codes should grow together by harmonizing their further development It may be necessary to find a way outside CEN because national Codes are normally not standards

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