The Pressure System Safety Regulations: Compliance matters

So first let’s deal with a question which is very much at the top of the list from both BCAS members and non-members alike: What do I need to do to comply with the Pressure System Safety Regulations (PSSR)?

Anyone asking this question is obviously aware of the PSSR and recognises the need to be compliant, albeit they need some guidance. 

Of more concern are the reports we receive regarding compressed air systems being operated without consideration to the PSSR. To put it quite simply, and forcibly, this is illegal.

If pressure equipment fails in use, it can seriously injure or kill people and cause serious damage to property. 

The regulations have the status of a statutory instrument (SI 128) and therefore are the law; non-compliance is a criminal (not civil) offence. 

It means that BCAS continues to beat the PSSR drum and endeavours to explain the PSSR, how it affects you as the owner/user and what you have to do to comply.

But let’s start at the beginning: The PSSR came into force as a UK Statutory Instrument on 21st February 2001 and applies to any compressed air system operating at a pressure of greater than 0.5 bar. If the pressure/volume relationship is less than 250 bar/litres, then the following regulations will apply.

• Regulation 7 - Safe operating limits
• Regulation 11 – Operation
• Regulation 12 – Maintenance
• Regulation 15 - Precautions to prevent pressurisation of certain vessels (user only)

If the pressure/volume relationship is greater than 250 bar/litres, then the following additional regulations will also apply:

• Regulation 8 - Written scheme of examination (WSE)
• Regulation 9 - Examination in accordance with the written scheme
• Regulation 10 - Action in case of imminent danger
• Regulation 11 – Operation
• Regulation 12 – Maintenance
• Regulation 14 - Keeping of records etc.

It is Regulation 8 about the Written Scheme of Examination (WSE) that generates the most interest and unfortunately confusion, so it is worth exploring it in greater depth

Competent person

The PSSR stipulates that a ‘competent person’ must certify the WSE, albeit any suitably competent and experienced engineer can draw up the content.  

In this respect the guidance for a competent person is that they should be qualified to at least Chartered or Incorporated Engineer, with practical and theoretical knowledge and actual experience of the relevant systems. They must also have access to specialist services, effective support and professional expertise within their organisation and proper standards of professional probity.  

It should be noted that these qualification criteria are for guidance only. If an appropriately experienced engineer meets the requirements then there is nothing in the legislation to prevent this person from carrying out the duties of a competent person. You must be aware however that enforcement agencies and/or the courts could test this suitability if any legal action is taken.

A competent person must also carry out the WSE (Regulation 9). They should have sufficient practical and theoretical knowledge and actual experience of the type of system under examination to identify defects or weaknesses and assess their significance in terms of the equipment’s integrity and safety.

User’s/owner’s responsibility

Another aspect of the PSSR that is often misunderstood is that it remains the user’s/owner’s responsibility to ensure compliance with the PSSR as detailed below:

• The user of an installed system and owner of a mobile system shall not operate the system or allow it to be operated unless he has a written scheme for the periodic examination, by a competent person, of the following parts of the system:
• • all protective devices;
  • every pressure vessel and every pipeline in which (in either case) a defect may give rise to danger; and
  • those parts of the pipework in which a defect may give rise to danger, and such parts of the system shall be identified in the scheme.
• The said user or owner shall:
• ensure that the scheme has been drawn up, or certified as being suitable, by a competent person;
• the content of the scheme is reviewed at appropriate intervals by a competent person for the purpose of determining whether it is suitable in current conditions of use of the system; and the content of the scheme is modified in accordance with any recommendations made by that competent person arising out of that review. 

So to summarise who is responsible for what:

The user/owner ensures that the scope of the scheme is appropriate i.e. which parts of the system are covered (with advice, if necessary, from a suitably experienced adviser); and the competent person specifies the nature and frequency of examinations and any special measures needed to prepare the system for safe examination.

Safe operating limits

The owner/user also has responsibilities for Regulation 7 of the PSSR about its ‘safe operating limits.’

Specifically, the user of an installed system and owner of a mobile system shall not operate the system or allow it to be operated unless they have established the safe operating limits of that system. The owner of a mobile system shall, if they are not also the user of it, supply the user with a written statement specifying the safe operating limits of that system or ensure that the system is legibly and durably marked with such safe operating limits and that the mark is clearly visible.

This regulation complements regulation 5, which makes the designer, manufacturer and supplier responsible for providing adequate information about the system or its component parts. It prohibits the user/owner from operating the system, or allowing its operation, before establishing its safe operating limits.

BCAS’ second most frequently asked question is related to the first: What do I do as the competent examiner if I find that there is a situation that may give rise to imminent danger?

In answer to this, the PSSR regulations state that the examiner must make a written report identifying the system and specifying the repairs, modifications or changes concerned and give it to the user or owner.  

The competent person must also send a written report containing the same particulars to the local enforcing authority for the premises where the pressure system is situated, within 14 days of completing the examination.

It is then up to the owner/user to ensure that the system (or if the report only affects a discrete part of the system, that part) is not operated until the repairs, modifications or changes have been made.

The PSSR is a complex piece of legislation and clearly cannot be dealt with in one article.  Its main aim however is clear – to prevent serious injury as a result of the failure of a pressure system or one of its component parts. By complying you ensure that your compressed air system is safe and fit for purpose.

Further advice can be found on the HSE website at: http://www.hse.gov.uk/pubns/priced/l122.pdf and the full text of the PSSR can be found at: http://www.legislation.gov.uk/uksi/2000/128/pdfs/uksi_20000128_en.pdf