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Does my compressed air breathing apparatus
count as pressure equipment? Why
does my apparatus come marked with so
many CE markings? Can I start using my
respiratory protective device as soon as it
has been delivered? These are the questions
which are asked time and time again,
by our readers, customers and users. Those
responsible for drawing up the European
standards have also left room for interpretation
when it comes down to such details, so
this article will attempt to shed some light
on the issue of European standardization
and its treatment of compressed gas cylinders.
Compressed gas cylinders, first and
foremost, are pressure vessels which, if
they are fitted with a valve, are known as
pressure equipment. This is the definition
contained in the European Pressure Equipment
Directive 97/23/EC, the PED. And
pressure equipment designed for operating
pressures in excess of 0.5 bar, regardless
of type, must be approved before being
placed on the European market. By approval
is meant that Notified Bodies in Europe
check that the equipment submitted by the
manufacturer conforms to the requirements
contained in the Directive and then approve
the equipment specimens. They are then
issued with a certificate testifying that they
can be placed on the market.
Different directives
The equipment is marked with the CE number
of the respective certification authority,
which distinguishes it as an approved product that has been manufactured to achieve
the required quality and performance characteristics.
This is the aim of the Pressure
Equipment Directive, which entered into
force on 29 May 2002. The Directive also
covers pressure equipment that is used in
respiratory protective devices (Article 3, 1.1),
which means that compressed air breathing
apparatuses, in the widest sense, can also
be regarded as pressure equipment. All
components of pressure equipment must
be subjected to a conformity assessment by
the manufacturer and, depending on their
operating pressure and volume, are assigned
to different categories. If this is applied to
those state-of-the-art compressed air breathing
apparatuses currently on the market,
only pressure vessels fitted with valves are
placed in a category which is subject to
marking in accordance with the PED. All
the other components of the compressed
air breathing apparatus which conduct compressed
air do not require marking on account
of their design. However, compressed
air breathing apparatuses also and not least
count as personal protective equipment
(PPE) and, as such, must comply with
European Directive 89/686/EC. Here too,
the general approval requirements apply
before PPE can be placed on the market,
and once again a CE mark is issued once
all conditions have been met. If certain types
of PPE – such as compressed air breathing
apparatuses – are to be used on ships, yet
another specific European Directive applies,
the Marine Equipment Directive (MED),
according to which the equipment must be
approved and marked. And if particular types
of PPE are intended for use in explosive
atmospheres, the ATEX directive comes
into play. However, not all Notified Bodies
across Europe are equally authorized to
verify the proper implementation of the
various directives. As a result, a device may
well end up with several different CE marks.
But now back to the pressure equipment.
Pressure vessels themselves are generally
approved and CE marked as individual
components, and the same is true of the
valves. If these components are subsequently
combined to form an assembly, the PED
says that pressure equipment requiring approval
has been created, so naturally it
must be issued with a CE mark. If this assembly
is now used in a compressed air
breathing apparatus marked as PPE, the
outcome is a compressed air breathing apparatus
that is regarded as pressure equipment.
In other words, there are already four
distinct types of CE marking – confusing?
Not really, if one is familiar with the background,
and yet the situation can be misleading
because not everyone can work their
way through all the details. According to
the European Directives, a single CE mark
would be more than sufficient, because one
basic principle that all directives share is
that all other applicable directives have to
be taken into account during testing. In an
ideal situation this could work if all Notified
Bodies in Europe were authorized to deal
with all directives. However, for as long as this ideal situation does not exist, Dräger
Safety has made it its job to give consideration
to national differences and to approve
and make available pressure equipment of
all kinds of different types – with pressure
vessels made of steel, aluminium or carbon
fibre-reinforced composite material – in its
Dräger compressed air breathing apparatus
series. A correlation matrix (see Appendix
B01001) shows the current range of Dräger
pressure vessels with their respective valves,
including those used in diving apparatus.
This matrix is constantly changing as new
types of pressure equipment are included
to widen the range of Europe-wide approved
Dräger pressure equipment.
Occupational Safety Ordinance
In Germany, another piece of legislation
exists in connection with the Pressure
Equipment Directive, namely the Occupational
Safety Ordinance (Betriebssicherheitsverordnung,
or BetrSichV). This ordinance
requires approved and CE-marked
pressure equipment to be checked by an
authorized body for compliance with all requirements
prior to being put into service
for the first time. This check is performed
by the German Technical Inspectorates
(TÜV). Dräger Safety also offers this check
as an optional service, meaning that compressed
air breathing apparatuses and
pressure equipment – i.e. compressed gas
cylinders with valve – supplied by Dräger
can be put into service immediately upon
delivery. Dräger Safety is also able to carry
out the repeat tests for pressure vessels
which are required by the German ordinance.
At European level, manufacturers'
associations, among them Dräger Safety,
have joined forces with user groups to bring
about the harmonization of the different directives.
Although this process is time-consuming,
there is certainly a chance, as far
as the device-specific standards are concerned,
to prove points of similarity between
at least two directives, the PPE and PED.
Consequently, just one CE mark affixed to
a device would be sufficient to demonstrate
compliance with a Europe-wide quality standard
– the ideal of every directive author.
Wolfgang Drews
Dräger Safety AG & Co. KGaA |
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Dräger Safety AG & Co. KGaA |
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Revalstrasse 1 |
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23560 Luebeck, Germany |
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Tel +49 451 882 0
Fax +49 451 882 2080
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