Towards the end of 2016 John Thompson was contracted by a European-based company to supply a 12 t/h 14 bar(g) steam generator – complete with CE marking, the European Union (EU) quality approval stamp – to their processing plant in Ghana.
CE (European Conformity) marking is a mandatory conformity marking for some products sold within the EU. Jacques Matolla Engineering Manager – Package Boilers at John Thompson explains the procedures.
The European Pressure Equipment Directive (PED) 2014/68/EU is a set of jurisdictional rules and regulations which aim to eliminate or mitigate the potential dangers and risks associated with pressure equipment with a maximum allowable pressure greater than 0,5 bar(g).
This is achieved by mandating that manufacturers, suppliers and importers of pressure equipment for use in the EU adhere to the regulations, essential safety requirements (ESR’s), hazard categorisation and conformity assessment modules set forth in the PED.
Compliance with all applicable requirements bestows on the manufacturer the right to affix the CE marking to the pressure equipment. The following steps were taken to meet the customer’s requirements.
Step 1: Perform a risk assessment The first step a manufacturer has to perform to meet the requirements of PED 2014/68/ EU is to conduct a risk assessment of the pressure equipment in question. This process aims to identify and analyse potential hazards as a result of the equipment pressure, design and build. A typical risk assessment for a John Thompson steam generator includes consideration of the potential loadings, the mode of operation, the possible failure modes and any foreseeable misuse.
Step 2: Demonstrate solutions adopted to comply with the ESR’s In addition to identifying and analysing the risks, John Thompson had to illustrate that design solutions had been adopted in order to eliminate or reduce the hazards, show that appropriate protection measures had been implemented against the hazards and that users were informed of all residual hazards. This was achieved by tabulating the adopted solutions against the ESR’s as listed in the PED. The ESR’s John Thompson had to comply with included design, manufacturing, materials, pressure equipment requirements for fired equipment, piping and quantitative requirements for certain pressure equipment. In order to adhere to the ESR’s, John Thompson made use of harmonised European health and safety standards EN 12953, EN 13445 and EN 13480.
Step 3: Determine the product hazard/risk category The next step was to determine the risk category of the steam generator in accordance with the PED. To achieve this, the following parameters needed to be known or determined:
- The nature of the fluid i.e. gas or liquid.
- The hazard group of the fluid, which could be either Group 1 or Group 2. Group 1 is used for fluids which are classified as dangerous, whilst Group 2 is used for all others. In terms of PED 2014/68/EU steam is classified under Group 2.
- Steam generator design pressure and volume. The steam generator hazard/risk category was found to be Category IV pressure equipment.
Step 4: Select the appropriate conformity assessment module The knowledge gained in Step 3 was used in Step 4, which was to determine the applicable conformity assessment module in order to establish the scope of the Notified Body involvement and the level of technical documentation required.
John Thompson selected conformity assessment Module G for its steam generator from among the Category IV conformity assessment modules listed in the PED. Module G tasks the Notified Body with the following responsibilities:
- Examine design and construction of each item of the pressure equipment,
- Examine technical documentation with respect to design and manufacturing procedures,
- Assess materials,
- Verify material manufacturers certificates,
- Approve procedures for permanent joining of parts,
- Verify joining and NDE personnel are qualified or approved,
- Perform appropriate tests during manufacture,
- Perform final inspection and proof tests as per ESR’s,
- Examine safety devices
- Ensure identification number is affixed to pressure equipment,
- Draw up a certificate of compliance for tests carried out. In accordance with the requirements of Module G, the following technical documentation was supplied by John Thompson to the Notified Body for approval and verification:
- Record/results of the analysis and assessment of risks (manufacturer).
- General description of the product.
- Product general assembly drawings, component drawings, equipment lists and P&ID’s
- Details of design codes or standards applied.
- Evidence of compliance with materials specifications of the PED.
- EC or EU Declarations of Conformity for all purchased items of pressure equipment.
- Results of tests and inspections during manufacture.
- Evidence of qualification of permanent joining personnel.
- Evidence of qualification of permanent joining procedures.
- Evidence of qualification of NDE personnel.
- NDE test reports.
- Inspection documentation for base materials, consumables and bolting.
- Procedures for assuring material traceability.
- Reports of defects/ deviations arising from manufacture, including concessions.
- Details of manufacturer’s quality management system certification.
- Information on items sub-contracted and what controls are in place.
- Any other additional supporting documentation.
- Operating and maintenance instructions, including relevant safety information.
Step 5: CE marking and EU declaration of conformity Upon completion of all design, manufacturing, inspection and testing procedures, and after verification of conformity, John Thompson could issue an EU declaration of conformity with PED 2014/68/EU and affix the CE marking to the steam generator.
The CE marking ensures that the steam generator has freedom of movement within the EU. The EU declaration of conformity must comply with the PED and be approved by the Notified Body. The award of the CE marking opens up a wide range of opportunities for John Thompson in the export market.
