Dear Colleagues, 

Two items regarding this.....

======================================
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? It looks like it could be a typo that
has crept in. I appears consistently in the text. It shows up in the
directive posted in the Commission web site and at a site maintained by
Finland.

If the seven is taken as written then the limit in my example is 25*7 or
175. But this conflicts with the table 1 graph indicating a limit line
of PS * V = 25.

Any ideas???
=========================
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. 

 <<PED analysis.doc>> 

Best Regards,

Lauren Crane
Senior Safety and Compliance Engineer
Eaton Corporation

Attachment: PED analysis.doc
Description: MS-Word document

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