Staying abreast of directive changes
21 July 2016
With recent changes to the Pressure Equipment Directive (PED) and the Simple Pressure Vessels Directive (SPVD), plus WEEE and RoHs coming under review, BCAS takes a closer look at the legislative changes affecting the compressed air industry.
The PED provides a European legislative framework for equipment subject to pressure and applies to the design, manufacture and conformity assessment of pressure equipment and assemblies with a maximum allowable pressure greater than 0.5 bar. The new Directive 2014/68/EU will be applicable from 19 July 2016, subject to the enactment of a UK Statutory Instrument (SI).
The new SPVD, 2014/29/EU, applies to simple pressure vessels manufactured in series. The simple pressure vessel is described in the Directive as 'any welded vessel subjected to an internal gauge pressure greater than 0.5 bar which is intended to contain air or nitrogen and which is not intended to be fired'.
The changes are due to the replacement of classification for fluid groups in the PED (article 9) and alignment with the EU New Legal Framework initiative.
Since June 2015, fluid groups have been published in the Classification, Labelling and Packaging Regulation. The good news is that Air (compressed) remains in Group 2, so this change is purely administrative. It will, however, require a change to current and new Declarations of Conformity to include reference to the new PED Article 13 of 2014/68/EU.
Other changes include the renaming of conformity assessment modules and requirements for, and the restructuring of, notified bodies.
Distributors and importers are also now included in the Pressure Equipment Directive and have certain legal obligations.
Specifically, there is now a requirement to analyse the hazards and risks in order to identify those that apply to equipment, and to then design and construct it with this in mind.
The new PED (2014/68/EU) also states that certificates and decisions issued by conformity assessment bodies under the old PED (97/23/EC) are valid under this directive. Certificates of declaration for existing equipment will need a statement to this effect when the new PED becomes UK law.
WEEE and RoHS
The scope of 'waste of electrical and electronic equipment' (WEEE) includes many of the ancillary components used in the compressed air industry,
WEEE is a complex mixture of materials and components that, because of their hazardous content, can cause major environmental and health problems. Careful management is therefore required when it comes to disposal.
Another aspect of WEEE is to consider the production of modern electronics, which requires the use of scarce and expensive resources. This has led to the promotion of a circular economy to improve the collection, treatment and recycling of electronics at the end of their life.
Two pieces of legislation address these issues the WEEE Directive 2012/19/EU and EU legislation restricting the use of hazardous substances in electrical and electronic equipment, the RoHS Directive.
New and on-going work on these directives includes the completion of a scope review to identify parameters for large and small Electrical and Electronic Equipment (EEE). There is also now an agreed common methodology for the calculation of the weight and quantity of Waste Electrical and Electronic Equipment (WEEE) across all the member states.
Other areas under review are the shipment of WEEE, illegal trade activities and the procedures and format for the registration and reporting of EEE producers.
Not many people realise that the enforcement agency for RoHS is the National Measurement Office (NMO). Contravening the RoHS Regulations could result in an unlimited fine on conviction plus enforcement notices requiring non-compliant goods to be withdrawn. So it is better for both the environment and your bottom line to adhere to RoHS.
Regular updates and information about changing legislation can be found on BCAS website – www.bcas.org.uk