Steel Plates and the EU Pressure Equipment Directive

The EU Pressure Equipment Directive (PED) sets out requirements for fabricators of all types of pressure equipment – and the material they use. Specifically the steel plates that are used to make boilers, pressure vessels and heat exchangers.

Recently a customer asked us about whether a mill’s MTC needs to have a statement on it that it complies with the requirements of the PED. Here’s the full question:

Our client and DNV have new requirement for these future CE marked projects. Their new requirement is  “All vendor /suppliers QMS must comply to PED 97/23/EC, App.1, Sect 4.3..”  That is to say the statement of PED 97/23/EC, App.1, Sect 4.3. compliance have to be indicated in the Material Mill Certificate.

Please check with your Manufacturer/Mill if their mill certificate EN 10204 type 3.1 or 3.2 can include the PED compliance statement mentioned above.

My immediate response was:

  1. Of course they do
  2. The mill won’t change the certificate just for 1 customer

Being pretty certain of this I still needed to check it out. So having spent some time in Brussels being involved in drafting the guidelines for another directive (the Railways Interoperability Directive) my first stop was the Pressure Equipment Directive itself.

Section 4.3 says:

“The equipment manufacturer must take appropriate measures to ensure  that the material used conforms with the required specification. In particular, documentation prepared by the material manufacturer affirming compliance with a specification must be obtained for all materials.

For the main pressure-bearing parts of equipment in categories II, III and IV, this must take the form of a certificate of specific product control system, certified by a competent body established within the Community and having undergone a specific assessment for materials, certificates issued by the manufacturer are presumed to certify conformity with the relevant requirements of this section.”

The first paragraph requires the fabricator to establish that the steel meets the requirement. This is done using the MTC prepared by the steel mill, for example Dillinger Hutte. Dillinger in their MTC must affirm compliance with a specification.

Dillinger does this in all their steel MTCs.

The second paragraph puts more detail into this requirements.

It says that if the MTC:

  • is produced according to a quality system
  • and is certified by a competent body – that is a quality systems assessor that is approved to assess that quality system – from the EU
  • and that competent body is competent in assessing the quality of steel production

Then the certificate can be presumed by the PV manufacturer to meet the requirements of the PED.

So looking at the certificate we see that the certificate is produced according to EN10204:2004 and also to ISO 9001 (See the statement at the top left) and that it has been verified by the Stuttgart office of Lloyds Register who are a competent body.

So this is sufficient to meet the requirements of the directive.

However for the avoidance of doubt if you look in the Annex ZA of EN 10204:2004 then there is a specific reference to the PED and the clause you are concerned about. I’ve badly cut my finger so I’m not going to type the whole annex out. In brief it says:

Once the PED has been adopted in at least one EU country (which it has) if you comply with Table ZA.1 then there is “a presumption of conformity with the corresponding essential requirements of that directing [the PED] and associated…regulations“. Table ZA.1 says you comply if you have a 2.1,2.2, 3.1 or 3.2 certificate.

So in plain English: If the MTC has a 3.2 or 3.1 certificate, then it complies with the PED and does not need a specific statement on the MTC

So if you get customers asking about the PED and material compliance with it you should show them an MTC that complies to EN10204 and is a 2.1, 2.2, 3.1 or 3.2 certificate.

No certificate – no material compliance with the PED.

With steel certificated to a US or a Japanese standard there will still be a route to demonstration as laid out in the first part of this article but it will just be a little bit more time consuming to demonstrate

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