On Wed, 1 Sep 1999, Crane, Lauren wrote:
> ======================================
> In reading through the PED (97/23/EC) I notice the following, apparent
> contradiction...
> The text of say Article 3, section 1.1(a) first indent says
> "for fluids in Group 1 with a volume greater than 1 L and a product of
> PS and V greater than 25 bar 7L, or with a pressure PS greater than 200
> bar (Annex II, table 1),"
> The confusing bit is the '7L' in '25 bar 7L'. When I look at the graph
> of table 1 it looks like the limit is the product of pressure and volume
> exceeding 25 bar * 1L.
> What is that 7 (seven) all about?
> Any ideas???
Dear Lauren:
That is a "translation error" between different character
sets used to display on computers. The correct interpretation is to
determine the product of pressure (in bars) time the volume (in
liters).
> I have studied the Pressure Equipment Directive tables in Annex II
> and created a matrix to guide me in the analysis of our equipment.
> This matrix may be useful to others, so I have attached it.
> It seems that the only elements of our equipment that cause us to
> fall within the "constrained" scope of the directive are the gas
> bottles that are installed by the user and not supplied by us.
> Removing these bottles from consideration, our equipment would not
> fall into even the first Category of any of the 9 tables, and so
> we would be obligated by only Article 3, section 3.
> It seems to me that since we do not supply the gas bottles with our
> equipment, we may take this approach, and avoid all of the conformity
> assessment procedures called out in article 10 section 1.3.
> I look forward to any comments on this opinion.
I have yet to look at your analysis, but must say that I
appreciate your attaching it and making it available. It is my
opinion that in general, a manufacturer of something that is to be
evaluated under the Machinery (or Low Voltage) Directive is not
likely to be called to perform an evaluation to the Pressure
Equipment Directive. This is because the area under "Category I"
covers the bulk of pneumatic and hydraulic systems.
Regards,
Chuck Seyboldt
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