At 15:16 -0500 31/3/2001, [email protected] wrote:
Hi Dan.
You wrote:
<One of our clients wants to ship a small (less than 10)quantity of an
industrial gas appliance into the EU. > -snip-< Would appreciate any input
from the
group.>
Here's some thoughts....
It goes without saying that you'll need EMC and LVD compliance (Damn, I said
it...) but for the gas sytems there is a bit of ambiguity.
If it's an industrial process, either a heating application where the gas is
the fuel, or a chemical process where the gas is a raw material, where there
are moving parts you may need the Machinery Directive.
If it's a food related application, where gas is used for the primary heat
source for cooking, I'm not aware of any European Cooking Directives, but
then it's not my area of expertise.
There isn't one in the UK, or at least not that affects equipment
manufacturers. And if the product legitimately carries the CE mark,
the rules are the same in every EFTA state.
If it's a food packaging application,
purging and packing with Argon or CO2 etc., then you're up against Hygiene
Regs in the UK, but not Europe wide I suspect.
Most of the hygiene rules affect the operator of the equipment rather
than the manufacturer - all the manufacturer has to do is ensure the
equipment allows the user to meet their obligations under the hygiene
rules (i.e. is fit for purpose). Hygiene matters will be highlighted
by a proper risk assessment under the Machinery Directive.
If it's a power generation application, Internal Combustion, Gas Turbine,
steam generation, then you may be up against those types (Automotive??) rules.
Power generation (even mobile) is a straightforward machinery/EMC/LVD issue.
If it uses Town Gas (natural gas) the equipment will need qualification for
safety according to the local Gas Safety rags in the UK, this includes fire.
explosion, stociometric (sp?) controls, extinguish lockout, and exhaust
venting requirements. This isn't a CE marking matter though.
If it's within the scope of the GAD, the UK gas safety regs apply. If
it's not a Gas Appliance, the regs do not apply, irrespective of the
type of gas used as a fuel.
Be aware, however, that there are completely separate sets of
regulations which are concerned with the duties of installers,
maintainers and owners of gas appliances. However, AFAIK, these apply
only to people working with equipment within the scope of the GAD,
not to industrial process operators and fitters.
If it uses bottled gas, or local piped LPG etc. or for a chemical process
bottled or piped raw material gases, , it'll need the same set of
qualifications, and observance of the various pressure related Directives,
Simple Pressure Vessel Directives, Low Pressure Directive (?? Memory is
slipping and it's very early in the day..).
The SPV Directive applies only to certain types of tanks for air or
nitrogen. The Pressure Equipment Directive may apply to some of the
components, but is highly unlikely to apply to the complete assembly,
and anyway it's not fully in force yet.
A phone call to a UK Test House like ITS (Intertek Testing Services) at
Leatherhead (Website) should provide a good lead in, and a few ever deceasing
circles will lead you up the garden path to the door you seek.
They won't be of much use to you if it is not a gas appliance,
however. In my experience the GAD test houses know relatively little
about the Machinery directive, or the other 'industrial equipment'
directives such as the PED, SPV or ATEX directives.
Regards
Nick.
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