Evaluation of the Pressure Equipment Directive (PED) and the Simple Pressure Vessels Directive (SPVD)

GAMBICA members regard the Pressure Equipment Directive (PED) as fit for purpose. It has been in use for many years, is well understood, and poses no significant compliance challenges, even outside the EU, including in the supply chain and among end users. Nonetheless, revising the PED to incorporate new technological developments and the harmonised standards associated with these advancements would be advantageous.

We refer to Pressure Equipment Directive (PED) 2014/68/EU. The PED regulates the safety and conformity of pressure equipment within the European Union. Article 1, paragraph 2 of the PED specifies that certain pressure equipment is excluded from the application of the directive. Railway vehicles and their pressurized components fall under these specific exemptions.

The PED was first published in 1997 as 97/23/EC, and its technical content has remained largely unchanged since then, Hence, much of its content is more than 25 years old, so one can certainly find a significant number of reasons that might speak for a revision: 1. It would give the opportunity to - where appropriate - address recent technical developments more specifically and precisely, such as e.g.

Feedback of the Czech Republic to the Call for evidence for an evaluation of the Pressure Equipment Directive (PED) and the Simple Pressure Vessels Directive (SPVD) published on 23. 5. 2024 on Have your say portal The Czech Republic welcomes the EC's intention to initiate a process of evaluation of both directives (PED and SPVD) aimed at identifying and possibly eliminating or correcting shortcomings related to…

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CECE welcomes the chance to respond to the call for evidence regarding the current evaluation of the Pressure Equipment Directive (PED) and the Simple Pressure Vessels Directive (SPVD). We believe the PED and SPVD are fit for purpose and recommend against merging them. Maintaining their distinction is crucial for clarity and the prevention of unnecessary disruption to existing compliance mechanisms.

Regarding Directive 2014/29/EU (SPVD): The SPVD should be repealed and its regulatory scope incorporated into the PED. It is incomprehensible why a separate directive should be necessary for the relatively small product range of simple pressure vessels.

- The guidelines of PED and SPVD are useful to interpretate the directives, but the guidelines are not mandatory regulation. Could be useful to connect the directives with guidelinses with mandatory acts. - Manytimes the innovative technologies are not considered on directives.

In addition of the feedback of the TÜV Association we would like to give following feedback: From the perspective of a Notified Body that is active in 12 countries for many years, the following aspects of the PED and SPVD should be revised: 1. + 4.

Unfortunately, the current Pressure Equipment Directive covers only containers made of metallic materials and is therefore not applicable to plastic containers with fibre reinforced (e.g. glass fibre or carbon fibre). This also prevents the use of such new materials as pressure vessels and reduces the relevance of the existing Pressure Equipment Directive.

Filed in German · English published by the European Commission

The climate and environment is not taken into consideration in current PED where the effect can be seen in the European Commission document "Best Available Techniques on Emission from Storage" (EFS BREF https://eippcb.jrc.ec.europa.eu/reference), which in chapter 5.2.2.1 Piping describes pipe flanges as "Bolted flanges and gasket-sealed joints are an important source of fugitive emissions.

ASAP-0851 is a notified body to the Commission for conformity assessments of the DPE and SPVD Directives. It is necessary for this evaluation to provide feedback directly from practice. 1_There are two directives for the risk of pressure, PED/SPVD, why not to bring them together. 2_Clarify the assessment of assemblies, Article 14 (6) is open to many understandings.

Filed in French · English published by the European Commission

It would seem to be logical to merge the PED & the SPVD so that manufacturers have a common standard for this type of equipment and the potential for misapplication is removed. In integrating the requirements care should be taken that the requirements for products formerly under each of the separated directives do not become more onerous for either category.

Contribution from the French Committee for Liaison of Pressure Vessels (without the French administration’s point of view) The CLAP brings together all the players in the French industry (regulatory experts of manufacturers, bodies, operators, administration). He is responsible for interpreting the DPE and SPVD at French level. It actively contributes to the harmonisation work. A.

Filed in French · English published by the European Commission

The TÜV Association welcomes the European Commission's intention to evaluate the Pressure Equipment Directive 2014/68/EU (PED) and the Simple Pressure Vessels Directive 2014/29/EU (SPVD). The SPVD has not been assessed since 1987, while the PED was last assessed in 2012 and then merely adapted to the new legal framework. Directives 2014/29/EU and 2014/68/EU have proven their worth in practice.

In accordance with Article 1(1)(a) and (b) of Ril 2014/029/EU, it applies only to containers made of weldable materials (steel or aluminium, with b) excluding containers of alloy steel (“stainless steel”) according to EN).

Filed in German · English published by the European Commission

(1) In the past, intensive discussions have taken place as to whether taps and fittings should also be interpreted as machines and therefore the machine rectangle should be used in addition. In our view, this discussion has not contributed to the clarity of the applicable directives between market players.

Filed in German · English published by the European Commission

Dear Sir/Madame, In general we believe the PED and SPVD are functioning well, though the necessity of a SPVD with regards to the PED could be questioned. In the short time which was available for providing feedback, we would like to present the following points for your consideration: In the PED tables for classification of vessels, the lowest displayed volume is 0.1L.

In Teknikföretagens view both PED and SPVD function well, and the technical requirements are well-established. Therefore, we propose that the technical requirements remain unchanged in the event of a revision. We do however see benefits with better alignment of legal requirements with other product regulations, such as introducing digital product passports for relevant data.

(h) EES 3.2/3.2.1/3.2.2 and 3.2.3: it should be made clear that the manufacturer responsible for it, irrespective of the monitoring/assessment by the NAO, if necessary, according to the evaluation modules, wonder whether it is appropriate to incorporate certain guidelines into the Directive.

Filed in French · English published by the European Commission

2.4 relevance: Modernisation of DESP 2.4.1 NOTICE of instruction and digital availability: the DESP would benefit from being modernised, such as the Machinery Regulation. 2.4.2 EES 2.4: in order to take account of technological developments, it might be interesting to leave the designer the freedom to advocate robotic or drone inspections.

Filed in French · English published by the European Commission

2.2 effectiveness and efficiency of DPE 2.2.1 (a) The concept of the whole is poorly defined: classification, requirements, etc. are described in an extremely brief manner and in fact remain poorly understood and misapplied.

Filed in French · English published by the European Commission

1. Overall, the DIRECTIVES PED AND SPVD function AND ONT A POSITIVE IMPACT 1.1 they are stable, allowing industry and organisations to be operational. IT IS IMPORTANT TO KEEP THIS STABLE REGIME AS MUCH AS POSSIBLE. 1.2 overall, the mechanisms, rules and essential safety requirements work. Nevertheless, some improvements are desirable (digital, additive manufacturing and composites, drone inspection).

Filed in French · English published by the European Commission

Danfoss Inputs to evaluation of PED 2014/68/EU, 2024-06-14 Effectiveness 1. Clarify the rules of using Digital instruction, safety manual etc.. (similar to Machinery Regulation) 2. Clear PED definition of sub-assembly (ex. condensing unit), and whether they should bear CE marking. 3. Clarify why PED Category I product can be excluded from PED if its incorporated into machine under Machinery Regulation.

Concerning Pressure Equipment directive: The first step in analysing the adequacy and effectiveness of the PED Directive is to start with the official guidelines (and, if possible, the CABF recommendations). In many cases, these interpretations cover unclear statements or topics treated in too general a manner.

ANIMA considers that PED and SPVD, over the years, have achieved a high level of reliability and are adequate to ensure the safety of pressure equipment, each one with its own specificities for the products covered by.

FIM considers that the current requirements ensure the safety of pressure equipment against the potential challenges posed by hydrogen applications or innovative materials. Their possible application for hydrogen applications is achieved in particular through standardisation, which demonstrates that the requirements of the Pressure Equipment Directive are sufficient and technologically neutral.

Filed in French · English published by the European Commission

Good Day, as a first remark, I would like to note that the evaluation period is very short. The portal closes on 20/06/2024. The information that a revision of the Pressure Equipment Directive is planned only reached me on 18 June 2024. This seems to be the case for many as the data and the small number of entries show.

Filed in German · English published by the European Commission

Ladies and gentlemen, the Pressure Equipment Directive, with its harmonised standards, is an established tool for the design, manufacture and testing of valves and is also recognised beyond the EU. There is certainly a need for additions or corrections at one or another. However, I think that most such needs can be met by the harmonised standards.

Filed in German · English published by the European Commission

As a Notified Body, Apave identifies the following subjects for further clarification or clarification: — Clarify the requirements relating to the assessment of assemblies (resistance test, assembly, etc.) – Classification of assemblies incorporating RPS – Integrating generic guidelines – Integrating generic CABF recommendations – Specify the definition of a material (composite or additive manufacturing) –…

Filed in French · English published by the European Commission

Reference is made to the German version of the Directive, diagram 1 on page 215. However, it also concerns the other graphs. It is not clear which classes and conformity assessment procedures below the 0.1 V(L) volume are to be applied. Is Article 4(3) also applicable in excess of 200 bar, or module A, or even module B? This could be clarified in a new edition or in the PED guide. — Thank you.

Filed in German · English published by the European Commission

Both the Pressure Equipment Directive and the Simple Pressure Vessels Directive have proven valuable and reliable legislation supporting European companies coping with their business challenges. Any change of the Directives would create questions within their daily business. Therefore, I strongly recommend to leave the Directives unchanged except legal or formal adaptions if necessary.

(1) incorporate a validity date in the design review certificates associated with module H1, similar to the expiry date of the EU-type examination certificates (10 years) 2) Insert details on the specific final assessment (RES 3.2) for assemblies, similar to the Guidance Document for Notified Bodies ref.

Filed in Spanish · English published by the European Commission

Dear Madame or Sir, the following feedback is focusing on the PED as this Directive sets out requirements that we, as manufacturer of breathing protective equipment and other safety products, are following in our production. At the moment Article 4, number 3 of the PED 2014/68/EU requires that products are accompanied by adequate instructions for use.

Good day, we think that the two Directives, PED and Pression Devices should remain separate. The evaluation criteria and ESR are different, each type of product has been assessed for years according to PED or SPVD. All simple pressure equipment, if integrated into the DPE, would fall under a quality module, without all the safety criteria adopted so far. I consider it useful to go further on this argument.

Filed in Italian · English published by the European Commission

Three suggestions (food for thoughts) Aggregation of the SPVD and PED In several Member States, the number of Notified Bodies for the SPVD is limited. In the Netherlands, only one authority has been designated for this Directive. The size of the market makes it unprofitable for many parties to be accredited and designated for this Directive as well.

Filed in Dutch · English published by the European Commission

With regard to Directive 2014/68/EU, I would like to point out that the accreditation bodies check the notified bodies for actions based on the evaluation modules not falling within their competence. They require the notified body to control and approve the hazard analysis and the hazard analysis. They require the notified body to check and approve the manufacturer’s instructions for the user.

Filed in Greek · English published by the European Commission