Frequently Asked Questions
On this page you can find frequently asked questions and answers to the same.
PRESSURE EQUIPMENT
1. If the design and markings on the product specify a category of pressure equipment, is classification required?
Accordingly Ordinance on technical requirements for the design, manufacture and conformity assessment of pressure equipment the manufacturer specifies and indicates the category of pressure equipment (on the nameplate, declaration of conformity,…).
The Ordinance on inspections of pressure equipment during the service life prescribes the obligations of the owner/user during the use of pressure equipment.“Classification of pressure equipment which is being put into service for the first time or which is in use shall be carried out by a designated body for the classification of pressure equipment and shall complete the record sheet.”
The approach is that, if the project defines the pressure equipment, then the classification is approached, if the designer or manufacturer has determined that the subject of the project – the product is not pressure equipment, then the classification is not approached.
Categorization (designer) and classification (designated body) are two separate processes. Technically, there are similarities in the categorization/classification diagrams, but the criteria themselves are not identical, nor are the results of the two processes:
- categorization is the basis for the design, manufacture and conformity assessment of pressure equipment before commissioning;
- classification is the basis for inspections and tests of pressure equipment during use.
2. What is the procedure in case of non-compliance with pressure equipment in use?
Immediately after determining the non-compliance, the owner/user of the pressurized equipment shall be notified of the non-compliance via:
- records: in case of determining non-compliance that requires urgent action or non-compliance identified in a certain part of the implementation of control/inspection activities. Records are issued by the inspector.
- control reports: the final control document that includes one unit (subject and type of control). The report is issued according to the prescribed procedure and must be verified by the director of the Control Body.
The deadline within which the owner/user defines the measure for eliminating non-compliance runs from the notification of the owner/user. The time limit for defining the measure for the elimination of non-compliance depends on the type of non-compliance and is limited by the deadlines in the bid/contract.
After the expiry of the notice of non-compliance, if the owner/user:
a) determines the acceptable measure and deadline for elimination of non-compliance, this is confirmed in the new inspection report / report;
b) does not determine the measure or does not determine the acceptable measure for the elimination of non-compliance, a report with the identified non-compliance is issued and the report provides the following information for the client:
“Rejected issuance of a certificate of conformity – audit sheet. If the client does not notify the notified body of the non-compliance within __ days, the notified body will notify the Ministry of Energy of the non-compliance in accordance with the Ordinance on inspections of pressure equipment during its service life.
The client has the right to file a complaint according to the Complaints and Complaints procedure.”
After the expiration of the deadline from the report with the identified non-compliance, the activities of the owner/user are considered. If the owner/user:
a) submit a notification on the elimination of non-compliance, the procedure of controlling the elimination of non-compliance is carried out under the conditions and in the manner defined by the offer/contract or these activities are realized through a new offer/contract;
b) does not submit a notification on the elimination of non-compliance, the director of the Control Body informs the competent ministry about the existence of non-compliance and refusal to issue a document of compliance;
c) submit a complaint, it is considered according to the procedure Complaints and appeals.
3. How to determine the fulfillment of conditions for safe work for pressure equipment for which part of the documentation is missing?
In practice, it is usually found that there is no certificate of conformity and/or technical documentation for pressure equipment.
For pressure equipment that does not have the appropriate documentation, the fulfillment of the requirements for safe operation should be determined in accordance Ordinance on inspections of pressure equipment during its service life..
Checking the fulfillment of the requirements for safe work is done in the appendix of the first or periodic inspection. Confirmation of essential safety requirements is carried out by a designated body for the assessment of the conformity of pressure equipment, ie a designated body for the assessment of the conformity of simple pressure vessels.
To determine the fulfillment of the conditions for safe operation, pressure equipment in use must have one of the following technical documentation (TD):
- original TD from the manufacturer (documentation according to GOST; API; JUS, DIN… original from the manufacturer)
- subsequently prepared TD certified by the competent authority (the case when the documentation is certified as a subsequent collection of documents in Ordinance on technical standards for stable pressure vessels)
- specially made TD which proves the fulfillment of the requirements for safe work.
Requirements for safe operation are confirmed by inspections and tests that prove the essential requirements for the safety of pressure equipment – units in use. Evidence of inspections and tests carried out shall be part of the TD or an annex to the record/report/certificate issued by the notified body.
In the process of proving compliance with the essential requirements for the safety of pressure equipment, evidence from previous conformity assessment procedures may be accepted if there are credible documents of compliance.
4. Is the content of the technical documentation for pressure equipment in use prescribed?
The technical documentation for pressure equipment in use has the content determined by the manufacturer on the basis of applicable regulations at the time of manufacture of pressure equipment. For equipment manufactured from 01.07.2012 onwards, the content of the technical documentation is prescribed in Ordinance on technical requirements for the design, manufacture, and conformity assessment of pressure equipment.
If there is no technical documentation for pressure equipment, then technical documentation is prepared which proves the fulfillment of the requirements for safe work. Principled content of the technical documentation proving the fulfillment of the requirements for safe work:
- Technical description
- Calculation – calculation proof of strength, calculation of safety devices
- Instructions for installation, use, and maintenance with risk analysis and safety measures for use and maintenance
- Graphic documentation:
- assembly drawing with all connections and their purpose, thickness of parts exposed to pressure,
- nameplate drawing (completed)
- Inspections and tests:
- manufacturer’s declaration and/or third-party certificates (or similar document, if any)
- wall thickness measurement report
- non-destructive testing report;
- pressure test report
SIMPLE PRESSURE VESSELS
1. Pressure equipment shall be manufactured in accordance with the European Simple Pressure Vessels Directive (2009/105 / EEC). To which regulations and to which conformity assessment procedure is a simple pressure vessel subject?
The subject vessel is subject to Ordinance on technical requirements for the design, construction, and conformity assessment of simple pressure vessels.
For simple pressure vessels with a product of pV <=3000 barrels, a type verification procedure, and a control or verification procedure during the production of vessels are carried out.
For the type-examination procedure it is necessary to provide:
- assembly drawing of vessel type;
- instructions for use (Technically correct, without authorization)
- a document describing: selected materials, selected welding procedures, selected tests, and vessel details.
- sample, prototype vessel.
The manner of control or verification of production is determined by the contract with the manufacturer or his representative.
The type-examination certificate is valid as long as the documentation used for the production of the prototype is applied to the production, with controls or verifications during the production of the vessels (not time-limited).
MOBILE PRESSURE EQUIPMENT
1. Are IBC containers subject to inspections in the presence of a designated body for mobile pressure equipment?
IBC containers are subject to ADR / RID / ADN and are not subject to Ordinances on mobile pressure equipment. The container must have the appropriate code and meet all ADR / RID / ADN requirements in order to be used in traffic.
The IBC guidelines u given in ADR / RID / ADN should be used for periodic inspections of IBC containers. In case of doubts about the inspection, we suggest consulting with a consultant for the transport of dangerous goods.