Pressure Equipment Directive Compliance by Fire Industry Association

Guidance Note

1. Introduction

This Guidance Note has been prepared to give guidance on The European Union’s Pressure Equipment Directive in relation to vessels and pipework assemblies used in Fixed Gaseous Extinguishing Systems, Fire Suppression Systems, Portable Fire Extinguishers and Container based Watermist systems.

2. Scope

The EU’s Pressure Equipment Directive 97/23/EC (known as its acronym: PED) was introduced in the UK as the Pressure Equipment Regulations 1999, came into effect on 29th May 2002 and was updated by the EU Directive 2014/68/EU on 20th July 2016 (effectively making the PED a “Regulation”, although it is still referred to as a “directive”) .

Most pressure equipment and assemblies placed on the market in the EU had to comply with the Regulation, failure to comply could result in prosecution and carries the penalties of a fine or imprisonment, or both. Although The UK has exited the European Union, if items are being exported to the EU, they must still comply to the Pressure Equipment Directive. For Items being used in the UK, they must now comply to the UK’s Pressure Equipment (Safety) Regulation (See separate guidance document for details on the UK’s PE(S)R) fact file 2)

This Guidance Document is written to aid conformance to the EU’s Pressure Equipment Directive for Pressure Equipment being supplied to the EU.

With the exit of the UK from the European Union (Brexit), under the “Great Repeal Act”, all Directives/Regulations at the time of the Act were transferred into the UK’s equivalent Directive/Regulation.

Currently the route to compliance to the UK’s equivalent to PED, the Pressure Equipment (Safety) Regulation (PE(S)R) is the same route of assessment for items, but whereas relevant parts were marked with CE (as applicable), they are now marked with UKCA* (as applicable).

Where an EU Notified Body (NoBo) is required to assess and approve the Pressure Equipment for use in the EU and their NoBO number applied, for GB the UK Accredited Body (UKAB) is required to carry out this assessment and their UKAB number applied to the component.

* With the exception of Northern Ireland where (at the time of this document publication) markings can allow for CE with UKNI or CE and UKCA (as applicable).

The implementation of the EU Directive as it applies to items of pressured equipment components used in fire extinguishing, suppression, sprinkler and control equipment has historically been universally adopted for items of equipment used in such systems – such as pneumatic actuators, flexible hoses etc. With the ratification of the EU’s Construction Products Regulation which also covers such components, the higher levels of compliance and marking required, there is little or no concern about such items being supplied that are not in compliance.

harmonised standards to cover compliance within the EU’s Pressure Equipment Directive, there are no stated rules or practices which interested parties can follow to ensure compliance. This Guidance Document is therefore aimed specifically to address these two particular sectors – new systems and modified/refurbished equipment and systems.

This document is not intended to give guidance on the EU’s Transportable Pressure Equipment Directive (TPED) or Construction Products Regulation (CPR). However, these and all other relevant EU Directives & Regulations should also be complied with, when exporting items into the EU.

3. Definitions

3.1 Authorised representative

a European Authorised Representative serves as a legal entity designated by non-European Union manufacturers, to represent them in the EU and ensure their compliance with the European Directives

3.2 Container based Watermist systems

A high-pressure container based systems

3.3 EU Directive

a "directive" is a legislative act that sets out a goal that all EU countries must achieve. However, it is up to the individual countries to devise their own laws on how to reach these goals

3.4 EU Regulation

a "regulation" is a binding legislative act. It must be applied in its entirety across the EU.

3.5 New Product product placed on the European Market for the first time.

3.6 UK Regulation/Statutory Instrument

UK mechanism that is used to implement the European Legislation into UK Law.

3.7 Pressure Accessory

a device with an operational function and having an identifiable pressure-bearing housing - i.e. the device has a function additional to that of (as per the EU PED guidance note A-08) containing pressure. PEDPressure Equipment Directive is a European Community Directive which allows for the CE marking of pressure equipment. The Directive (2014/68/EU) applies to the design, manufacture and conformity assessment of pressure equipment and assemblies with a maximum allowable pressure greater than 0.5 bar. It covers vessels, piping, safety & pressure accessories. The Directive applies to components, sub-assemblies, and complete systems.

3.8 Sound Engineering Practice (SEP)

Good technical review, backed up with a technical file justifying the decision.

4. Abbreviations/Acronyms

4.1 NoBo

European Notified Body

4.2 OEM

Original Equipment Manufacturer

4.3 TPED

Transportable Pressure Equipment Directive

4.4 UKAB

United Kingdom Accredited Body

4.5 UKCA

United Kingdom Conformity Assessed, this is a UK product marking that is used for goods being placed on the market in Great Britain (England, Wales and Scotland). It covers most goods which previously required the CE marking, known as ‘new approach’ goods.

5. Who is affected by PED?

The Directive concerns parties who place pressurised equipment on the European Market, which could be the Original Equipment Manufacturer (OEM), or their agent. It applies to items such as components used in fire protection systems, the fire protection systems themselves, pressurised storage containers (that are not defined as “transportable”), portable fire extinguishers, watermist and industrial piping; it does not apply to pressure equipment (systems) installed or assembled by the end user.

It should also be noted that the Directive only applies to equipment, assemblies, or systems with a maximum allowable pressure greater than 0.5 bar; anything with a maximum allowable pressure of 0.5 bar or less, is exempt.

The Directive applies to new products placed on the EU market, existing products that are refurbished and modifications or extensions of existing systems that were already compliant.

Maximum allowable pressure

Throughout the Regulation and this Guidance Document reference is made to the maximum allowable pressure, maximum working pressure and working pressure.

In every instance, this must be taken as being the maximum pressure that the pressurised equipment can safely be exposed to.

Note:

Where the pressure comes from stored source(s) and the pressurised equipment is exposed to the full pressure of the stored source(s), such as containers, the pressure the equipment is reviewed, and assessment must be taken at the developed pressure in the stored source(s) at the maximum working temperature. For instance, the maximum allowable pressure for a 300 bar inert gas extinguishing system would be in the region of 360 bar and for a 25 bar halocarbon extinguishing system, in the region of 35 bar (depending on the specific agents).

For equipment exposed to a regulated pressure source(s), such as regulated valve outlets or pressure regulators, the pressure must be assessed to the maximum pressure the system can develop in a closed section of piping.

The maximum allowable pressure for other systems could also be derived from the set value(s) of the pressure relief device(s).

Specification In brief.

Pressure equipment to which PED applies must; -

• be safe

• meet essential safety requirements covering design, manufacture, and testing

• satisfy appropriate conformity assessment procedures

• be supplied with instructions to ensure the safe use of the product or system

• be supplied with a Declaration of Performance (if applicable)

• Carry the CE marking as applicable and any other defined information

To Comply with PED requirements, Pressure Equipment must be reviewed to ensure it is categorised correctly and the correct method of conformity is followed, key points to review to are:

- What medium is the item going to be exposed to: Fluid or Gas

- What is the cross sectional area /size of the item that is to be exposed to pressure

- What is the maximum pressure the item is to be exposed to

- What is the function of the item, is it a Safety critical function item (Category IV)

Once these questions have been answered, this will determine which category the item falls under and review as per the relative table/graph, this will then determine if the item can be self-certified.

See flowchart attached for assistance in determining the correct category table:

However, it is the adherence to the EU’s Directive for the completed systems which is where there may be varying levels of compliance – either incorrect compliance, or no apparent/obvious compliance – and the same is evident for refurbished or modified equipment, particularly portables. Since there are no harmonised standards to cover compliance within the EU’s Pressure Equipment Directive, there are no stated rules or practices which interested parties can follow to ensure compliance. This Guidance Document is therefore aimed specifically to address these two particular sectors – new systems and modified/refurbished equipment and systems.

6. PART 1 – REQUIREMENTS FOR NEW PRODUCTS AND SYSTEMS

6.1

APPLICABILITY

The Directive applies to the ‘manufacturer’ placing the pressurised equipment onto the European market.

With respect to fire extinguishing, suppression and control systems, this particularly applies to the party that engineers and installs the complete system, made up of OEM supplied parts with a fabricated distribution pipe network to make up the whole system.

There are several possibilities of who the responsible manufacturer for the complete system could be:-

• An OEM, who using their own equipment and employed staff, fabricate pipework and assemble/install the system.

o The OEM is then responsible for the compliance for the whole system.

▪ The completed system carries the OEM’s branding.

• A Fire Protection Company who buys OEM parts, sources a design from the OEM, engages a Fire System Installer to fabricate pipework and assemble/install the system.

o The Fire Protection Company is responsible for the compliance for the whole system.

▪ The completed system carries the Fire Protection Companies branding.

o The component OEM is only responsible for the individual components supplied.

o The Installer is engaged as a subcontractor to the Fire Protection Company and therefore contractually, are part of the Fire Protection Companies scope of supply.

• A Fire System Installer, who buys OEM parts/components, sources a design from the OEM, installs the system and sells it to another Fire Protection Company, or End User.

o The Fire System Installer is responsible for the compliance for the whole system.

▪ The completed system carries the Fire System Installers branding.

o The Fire Protection Company or the End User have not first placed the system on the market, so are not responsible for its compliance.

• An End User who buys OEM parts, sources a design from the OEM, uses their own staff to fabricate pipework and assemble the system.

o The system is not being placed on the market – i.e., it is not being sold to another party. PED Compliance is not specifically required; however, the system may still need to be reviewed for Pressure compliance, with some nations adopting the PED as the basis for this

Note that certification is required for each pressured assembly. A fire extinguishing, suppression, sprinkler, or control system may be installed in a protected area as a series of separate pipe networks, with the systems configured to operate simultaneously. Whilst this may be regarded as a ‘fire protection system for “this” protected area’, as each is a separate pressurised assembly, each one must be certified separately in their own right.

6.2 CATEGORIES

The Directive sets out differing levels of categorisation, based on the inherent levels of danger or risk associated with the product or system. For instance, the consequences of failure of a product containing a gas, pressurised to 50 bar would be much higher than for a product containing water at a pressure of 2 bar; the latter product would therefore have less stringent compliance requirements.

The categories define the level of assessment and marking required to achieve compliance with the Pressure Equipment Directive.

Products and systems are assessed as falling into one of the following Categories: -

6.3 Sound Engineering Practice (SEP)

Equipment falling into this category must be designed and manufactured to ‘sound engineering practice’; where applicable British Standards exist for instance, complying with these requirements specified would qualify as meeting the requirements of SEP.

The equipment must also: -

• Be supplied with instructions for safe use.

• Bear identification markings of the manufacturer or authorised representative.

• NOT be CE marked.

Compliance for equipment falling into Category SEP is achieved by the manufacturer and/or authorised representative.

6.4

Category I

Equipment falling into this category must meet the requirements for design, manufacture, testing, labelling, marking, user instructions and materials which meet Essential Safety Requirements specified in the PED.

Assessment of equipment falling into Category I is achieved by self-certification, but the manufacturer and/or authorised representative must possess technical documentation (the Technical File) to cover the design of the equipment and internal production control for the manufacturing processes/procedures.

The Technical File must be retained for a period of at least 10 years after the equipment or assembly is placed onto the market and be available for inspection on 48 hours’ notice.

Equipment falling into Category I must be CE marked and be supplied with a Declaration of Performance.

6.5

Category II, III and IV

Equipment falling into these categories has the same basic requirements as Category I, but the conformity assessment is made by an EU Notified Body.

There are several alternative conformity assessment modules open to be used by Notified Bodies to certify products and will be product/application specific.

In addition to being supplied with a Declaration of Performance and being CE marked, the product must also bear the 4-digit numerical code to identify the Notified Body used.

From a practical standpoint, the necessity to engage a Notified Body involves additional certification cost and lead time. Similarly, the certification is based on a defined product, so therefore is not conducive for system approval, as every single different system configuration would require an individual certification of each one, individually. It is therefore recommended that system designs are tailored to ensure that the certification requirements remain within the bounds of SEP or Category I.

7. PRODUCT CATEGORISATION

The determination of which of the above categories a product or system falls into is based on several key characteristics: -

7.1 Fluid Type Liquid Gas

The above are based on the state of the fluid at standard atmospheric conditions.

Equipment containing a compressed gas is potentially more hazardous than that containing a compressed liquid – the requirements for fluid type gas systems are therefore higher.

Fixed gaseous fire extinguishing systems using inert gases, liquefied chemical agents (e.g. HFC 227ea) and Carbon Dioxide are therefore classed as fluid type gas.

Some products or systems may contain two different fluid types, such as:

• HFC 227ea liquified gaseous agent, super pressurised with nitrogen gas

• FK-5-1-12 liquid agent, Water Mist, AFFF or similar using nitrogen gas as the propellant

In such cases, the Fluid type is based on the worse case – i.e. gas.

Water based systems may create the fluid pressure using pumps or gravity tanks, such as:

• Water Mist

• Deluge

• Sprinklers

• Foam

Since such systems only contain water and liquid additives, the fluid type is liquid.

7.2 Fluid Group

1 (Hazardous) or 2 (Non-hazardous).

‘Hazardous’ includes fluids that are flammable, toxic, oxidising, unstable etc.

‘Non-hazardous’ is everything else but note that asphyxiation is not considered a hazard.

For all types of fire extinguishing, suppression and control systems or products and portables, containing a liquid or gaseous fluid (or both) the Fluid Group is 2

Note: Carbon Dioxide is not classed as hazardous, because it is only toxic in ‘high’ concentrations.

7.3 Pressurised Vessel or Piping

A Fixed Extinguishing System theoretically contains both the above – agent storage containers and distribution pipework. It should be noted that the containers comply with a different EU Regulation – The Transportable Pressure Equipment Directive (TPED) – and are therefore (as per section A-36 in the PED guidance document) it falls out of the scope of the PED. However, It does still need to be considered as it is a Pressure source that is going into the PED system.

For fixed gaseous fire extinguishing systems, the pressurised item type is piping.

Components used in the above system (such as flexible hoses, check valves, nozzles, pneumatic control/release equipment) all ‘convey’ a fluid, rather than ‘store’ it, so would also be classed as piping.

A Fire Suppression System, such as Water Mist, AFFF, Direct Low Pressure or Indirect Low Pressure, using stored (gas) pressure as the means of delivery and containing both a vessel and pipework is classified on whichever component carries the highest rating.

A Fire Suppression or Fire Control System, such as Water Mist, Deluge or Sprinklers, using liquid only where the pressure is created by means of pumps, water mains or unpressurised gravity tank, the pressurised item type is piping.

Portables are covered by pressurised item type vessel. There are also some unique requirements for portables, hence even those using a short discharge hose or pipe, will still fall into fluid type vessel.

Important notes on ‘piping’

This applies to all assemblies that are rated as a pressurised item type of piping – i.e., all fire extinguishing, suppression and control systems using pipework and/or flexible hoses.

• The rating of the ‘pipework’ assembly is based on the single largest pipe diameter of the system.

o Where a system contains pipework of both, for example DN 40 pipe and DN 20 pipe, the system is classified as Category I.

• The length of the biggest pipe in the pipework assembly is immaterial.

o If a container valve has an outlet port diameter of DN 40, but the pipework is reduced down to DN 20 with a single, or combination, of fittings, the system is still classified as Category I. This is despite the length of pipe in the assembly of DN40 perhaps being no more than for example, 20mm.

Important notes on ‘vessels’

The above references to vessels apply where these are not pressurised until installed in their final location –i.e. they are not pressurised while transported. This would for example apply to water mist system water vessels, which only when the system is activated, are pressurised from an external source such as from a nitrogen gas container.

Containers used in fire extinguishing and suppression systems are commonly covered by the Transportable Pressure Equipment Directive. The TPED applies because the ‘vessels’ (containers) are filled and then transported to the place of use in a pressurised state. This lifts the level of associated ‘danger’; therefore, the compliance requirements are more stringent than for a PED vessel of the same size, containing the same fluid.

8. PRODUCT CLASSIFICATION

The classification for a product or system (based on its category, fluid type and item type), is derived from Charts 1 to 9 published in the PED. The charts are summarised as follows: -

Chart 1 – Vessels for Group 1 gases

Chart 2 - Vessels for Group 2 gases

Chart 3 – Vessels for Group 1 liquids

Chart 4 – Vessels for Group 2 liquids

Chart 5 – Steam Generators

Chart 6 – Piping for Group 1 gases

Chart 7 – Piping for Group 2 gases

Chart 8 – Piping for Group 1 liquids

Chart 9 – Piping for Group 2 liquids

Not applicable

Applicable for Portables

Not applicable

Applicable for Fire Suppression/Control systems

Not applicable

Applicable for Gaseous Extinguishing/Suppression

Not applicable

Applicable for Fire Suppression/Control systems

8.1 Detailed Requirements

Reminder – the PED only applies to equipment with a maximum working pressure greater than 0.5 bar.

Chart 2 – vessels for Group 2 gases - applicable to Portables

Portables are covered by an exceptional requirement that states that all portables are classified in at least Category III (Annex II, section 4), regardless of volume or maximum working pressure.

Portables are classified as Category IV where:

• The maximum working pressure exceeds 3000 bar, or

• The maximum working pressure multiplied by the volume exceeds a value of 3000, or

• The maximum working pressure exceeds 4 bar, and the volume exceeds 1000 litres.

Chart 4 – vessels for Group 2 liquids - applicable to Fire Extinguishing, Suppression or Control systems where liquid media is stored in a vessel which is pressurised, typically by external, compressed gas containers, as a means of discharging the fluid.

Equipment is classified as Category SEP where:

• The maximum working pressure does not exceed 1000 bar, or

• The maximum working pressure multiplied by the volume does not exceed a value of 10000, or

• The maximum working pressure does not exceed 10 bar, irrespective of the volume of the vessel.

Equipment is classified as Category I where:

• The maximum working pressure exceeds 100 bar, but the vessel does not exceed 10 litres, or

• The maximum working pressure multiplied by the volume exceeds a value of 10000, but the maximum working pressure does not exceed 500 bar, or

• The volume exceeds 1000 litres, and the maximum working pressure is greater than 10 bar but does not exceed 500 bar.

Anything else intended for use at greater working pressures and volumes is classified as Category II. There is no higher Category for vessels for Group 2 liquids.

In practical terms for such systems, Category II systems are best avoided in order to remain within the remit of compliance by self-certification.

Chart 7 – piping for Group 2 gases - applicable to Fire Extinguishing, Suppression or Control systems where the media is either gaseous, liquified gas, liquid, or powder, which is propelled by its own pressure and/or a pressurised gas.

Equipment is classified as Category SEP where:

• The maximum pipe diameter is DN 32 or less, or

• The maximum working pressure multiplied by the pipe diameter does not exceed a value of 1000.

Equipment is classified as Category I where:

• The maximum pipe diameter is greater than DN 32, but is up to and including DN 100, or

• The maximum working pressure multiplied by the pipe diameter does not exceed a value of 3500.

Equipment is classified as Category II where:

• The maximum pipe diameter is greater than DN 100, but is up to and including DN 250, or

• The maximum working pressure multiplied by the pipe diameter does not exceed a value of 5000.

Any Group 2 gas system where the piping exceeds Category II is classified as Category III; there is no higher Category for Group 2 gas piping.

Limiting the maximum pipe diameter to DN 100 (for maximum working pressures of 35 bar or greater) keeps the system classification as Category I, thereby achieving compliance by self-certification. Should a large system need to be, and be capable of using, a single pipe of greater than DN 100, it would probably be cheaper and easier to install two smaller piped systems to avoid the cost and time required for a Notified Body system certification.

Systems having a maximum working pressure of less than 35 bar can use a bigger pipe diameter and still remain in Category I, subject to the pressure multiplied by nominal pipe diameter not exceeding a value of 3500.

Chart 9 – piping for Group 2 liquids - applicable to Fire Suppression or Control systems where the media is liquid (e.g., water, foam etc) and is pressurised by means of pumps or gravity feed – i.e., by all means other than a gas propellant.

Equipment is classified as Category SEP where:

• The maximum pipe diameter does not exceed DN 200, or

• The maximum working pressure multiplied by the maximum pipe diameter does not exceed a value of 5000, or

• The maximum working pressure does not exceed 10 bar, irrespective of pipe diameter.

Equipment is classified as Category I where:

• The maximum pipework diameters and maximum working pressure exceeds the limits of SEP, but the maximum working pressure does not exceed 500 bar.

Equipment is classified as Category II where:

• The maximum pipework diameter exceeds DN 200, and

• The maximum working pressure exceeds 500 bar.

There is no higher Category for piping for Group 2 liquids.

9. EQUIPMENT TYPES

9.1 Components

This includes items that are pressurised in use, such as

• container valves

• selector valves

• flexible hoses

• discharge nozzles or heads

• pneumatic actuators

Such items are placed on the market by OEM’s and the responsibly for PED compliance rests with such companies.

It should be noted that under CE marking rules (93/68/EC), a product cannot be CE marked more than once; where a product falls under more than one Regulation, compliance with both must be achieved, but the marking and overall attestation is by the most stringent of the applicable Regulations.

Many components used in fire extinguishing, suppression and control systems also comply with the Construction Products Regulation (CPR). Compliance with such requires assessment to a defined harmonized standard (e.g., the EN 12094 series). Since there is no defined standard for Pressure Equipment Regulation compliance, and the compliance requirements for CPR compliance are more stringent, components are generally compliant and marked in accordance with this Regulation by the OEM.

From a ‘system builders’ perspective, the compliance for the components used is the responsibility of the OEM.

9.2 Assembly

The ‘pressurised assembly’ for a fire extinguishing, suppression or control system consists of multiple individually compliant components, which typically may include, storage tanks/containers, pumps, flexible hoses, pipeline valves and nozzles etc.

These are built into an assembly by incorporation into a pipework network. It is this site fabricated/erected pipe assembly combined with the OEM components that the PED compliance is required for.

10. CONFORMITY ASSESSMENT PROCEDURES

The Directive specifies a number of alternative ‘conformity assessment modules’ by which pressurised equipment can achieve compliance.

10.1 Fire Extinguishing, Suppression and Control Systems.

As stated above, these systems generally fall into the Categories of SEP or I – and as manufacturers of such systems are advised that it may be better to engineer systems such that they do not exceed these Categories, the information provided in this Guidance Document relates to systems of no higher that Category I.

SEP systems do not have any conformity assessment procedures or modules.

Conformity assessment module for Category I: -

Module A

• Design: technical documentation.

• Production: internal production control.

10.2 Portable Fire Extinguishers

As stated above, these are exceptionally classified as at least Category III or IV and the certification must be conducted by a Notified Body.

Conformity assessment modules for Category III: -

Modules B1 + D

• Design: design examination.

• Production: quality assurance for production, final inspection and test.

Modules B1 + F

• Design: design examination.

• Production: product verification.

Modules B + E

• Design: type examination.

• Production: quality assurance for final inspection and test.

Modules B + C1

• Design: type examination.

• Production: monitoring of final assessment.

Module H

• Design: quality assurance for design.

• Production: quality assurance for manufacture, final inspection and test.

Conformity assessment modules for Category IV: -

Modules B + D

• Design: type examination.

• Production: quality assurance for production, final inspection and test.

Modules B + F

• Design: type examination.

• Production: product verification.

Module G

• Design: unit verification.

• Production: unit verification.

Module H1

• Design: quality assurance for design with design examination.

• Production: quality assurance for manufacture, final inspection and test, and monitoring of final assessment.

11. COMPLIANCE REQUIREMENTS

11.1 Maximum allowable limit.

This is the maximum working pressure, or temperature, that the equipment can be exposed to and remain safe – i.e., without exceeding the maximum pressure rating for the equipment.

For systems that use stored pressure containers, the filling pressure is achieved in a factory/controlled filling environment and is not variable by the user, or application. The operating pressure is therefore defined, but the developed pressure will vary due to the ambient temperature. The user of such systems cannot directly control the contained pressure, but can influence the ambient temperature that the equipment is exposed to, indirectly affecting the pressure. A user for instance could expose a pressurised system container to a temperature which would cause a developed pressure greater than that for which the container and system was designed for.

Therefore, for systems using stored pressure containers such as the following, the maximum allowable limit is temperature.

• Gaseous fire extinguishing systems

• Water mist and foam systems using nitrogen gas containers

• ILP and DLP suppression systems

As an example, the maximum operating temperature range stated by BS EN 15004 for a fixed gaseous fire extinguishing system is -20°C to +50°C; the maximum allowable limit is therefore +50°C, as this corresponds to the highest working pressure.

For systems that use pumps or other variable means of creating the pressure, it is the operation or setting of the equipment that sets/limits the maximum working pressure that the user can affect, the temperature having little or no effect on the achieved pressure. For example, changing the setting of a pressure relief valve on a pumped system could achieve a working pressure greater that the system was designed for.

For systems using pumps or regulated/variable pressure supply/setting such as the following, the maximum allowable limit is pressure.

• Sprinkler systems

• Water mist and foam systems using pumps

• Deluge systems

• Gaseous fire extinguishing systems using regulated output flow*

The maximum allowable limit for pressurised equipment must be stated – both on the pressurised equipment and in the Technical File.

* Note: If any equipment is connected directly to the main pressure source of the container and not the reduced output pressure, then it needs to conform to the maximum allowable limit of the stored pressure, therefore would have the maximum allowable limit of that item would be defined as temperature.

11.2 Materials

In general terms, a fire extinguishing, suppression or control system consists of a container, tank or other source of agent storage or supply and other pressurised devices which is connected to nozzles or release mechanism by a pipework network. Since the OEM suppliers of system components are responsible for the compliance of the equipment they supply, the area of most concern is the pipework assembly.

The following guidance therefore apples to the compliance requirements for the materials used for the pipework assembly – i.e. the pipe and fittings.

The PED requires that the system installer/manufacturer includes in their technical documentation proof that the materials used are in compliance with the PED.

This can be done by one of the three following methods: -

11.2.1. Using materials that comply with harmonised standards. Meeting a harmonised standard provides a presumption of conformity to a directive or regulation. Harmonised standards are prepared in response to a standardisation request from the European Commission and become harmonised when it is listed in the Official Journal of EU. It should be noted that just because a standard may be published as a BS EN, it does not follow that the base EN standard is harmonised under the PED.

The manufacturer must verify this for the materials being used.

11.2.2. Using materials covered by a European approval of pressure equipment materials. This covers materials used for pressure equipment which do not have harmonised standards, but whose use may be common that one or more users of the material may have obtained an approval using a Notified Body.

11.2.3. Particular Material Appraisal.

This process is used where a material is to be used in a pressurised system, for which the material carries neither of the above approvals.

This alternative appraisal method can be provided by the manufacturer, where the pressure equipment does not fall into Category III or IV.

The Particular Material Appraisal must state key data on the material, such as the grade, its state of supply, minimum material properties and limitations on use (such as maximum working pressure).

An example of a pipe material which would need a Particular Material Appraisal could be pipe fittings to BS 3799.

It is the responsibility of the system manufacturer to verify if the pipe and fittings materials comply with harmonised standards or have a specific European approval; where this is not the case, the pressure equipment manufacturer is responsible for creating a Particular Material Appraisal for each material.

Whatever process the pipe and fittings materials achieve compliance by must be recorded in the Technical File for the pressurised equipment.

12. Manufacture.

For the purposes of a fire extinguishing, suppression or control system, this constitutes the process of installing the system agent containers, tanks, pumps and the fabrication/erection of the distribution pipework and fitment of other pressurised equipment such as pneumatic actuators and discharge nozzles/heads.

Since the system components are provided by an OEM and are simply ‘assembled’, the manufacturing process is therefore primarily the construction of the pipework; the relevant manufacturing processes therefore particularly relate to the joining of pipe sections.

The process used in the preparation of the pipe section ends for joining (e.g. forming screw threads or rolled grooves) must not cause defects, cracks or otherwise adversely affect the ability of the system to safely withstand the maximum allowable pressure defined for the system.

Specific requirements apply for welded pipe sections, but only for Category II, III and IV systems; welded fabrication of pipework would normally be subject to an inspection process and welder certification anyway.

13.Final assessment and pressure testing.

The Regulation requires that post manufacture, the pressurised equipment is subject to a final assessment. This is specified in two stages – a final inspection and a proof test.

The final inspection consists of a visual assessment of the pressured equipment and a review of the documentation. This can be done as a rolling process during manufacture and would be construed as normal commissioning activities for a fire extinguishing, suppression or control systems.

The proof test required by the Regulation is that the pressurised equipment or assembly must be hydraulically pressure tested, which for a fire extinguishing, suppression or control systems, would be required as a final assembly of the competed system. However, it is qualified that where hydraulic testing is potentially harmful, or impractical, and an alternative test of recognised value is available and conducted, hydraulic testing can be waived.

The hydraulic testing of an entire fixed gaseous fire extinguishing or suppression system is impractical. As these systems are frequently installed in areas containing live electrical or (moisture sensitive) IT equipment, the loss of water from pipework from a hydraulic test of the pipework could be catastrophic for the protected area.

For fixed gaseous fire extinguishing systems, BS EN 15004 and BS 5306-4 specify requirements for the pressure testing of pipework, using a 3 bar pneumatic test for open section pipework and hydraulic testing for closed section pipework.

Since the extent of the closed section pipework in a fixed extinguishing system is usually quite small and is generally outside of the protected area, the risk of consequential damage is greatly reduced.

Therefore, fixed gaseous fire extinguishing systems, complying with the pressure testing requirements of BS EN 15004 and BS 5306-4 can be considered as an alternative test of recognised value, and therefore avoids the full hydraulic testing requirements.

For Direct Low Pressure fire suppression systems, the detection tube is pressurised in use; pressure testing the detection tube is not appropriate as it would adversely affect its properties, or may not be possible.

Indirect Low Pressure fire suppression systems could by inference be treated as a combination of both of the above; the pipework could be pressure tested as per BS EN 15004 (which invariably would only be the 3 bar pneumatic test), and the detector tube as per DLP systems.

Fire control system pipework may also be subject to pressure testing by defined standards, which is different to that specified by the Regulation. The same exemption can be applied.

14.Traceability.

The Directive requires that the pressurised equipment manufacturer must obtain certification from the materials manufacturer as proof that the materials supplied comply with the required specification.

Essentially, for a fire extinguishing, suppression and control systems manufacturer, this means they must obtain material certificates for the pipe and fittings supplied. Suppliers of pipework and fittings routinely supply the necessary certification, which often can be generic as it does not need to be batch specific.

The pressurised equipment manufacturer must verify that the certificates confirm that the materials supplied match the specification required.

The Directive also requires that the production process includes a procedure to identify the receipt of (pipe) material certificates, and which would also include the Declaration of Performance and product documentation for pressure equipment supplied by an OEM (e.g. flexible hoses, discharge nozzles/heads). It is also required that there is certification of the final test of the pressurised equipment, produced by the system manufacturer, but this would be no more onerous than normal practice.

The above certification must be retained and would most likely be included in the project file.

15.Instructions for safe use

The pressurised equipment must be placed on the market with instructions that will ensure the user can operate the equipment in a safe manner.

For all fire protection systems, this would constitute the Operation and Maintenance Manual.

For all fire protection system components, this would constitute the Product Data Sheet or user instructions.

The instructions must detail how the equipment is used and for all fire protection systems is little more than has been existing normal documentation practice.

However, the user instructions must include sufficient information to ensure the user is aware of the maximum allowable limit, and actions which may be necessary to ensure the equipment is not used in a way in which this could be exceeded.

The instructions must also include warnings covering common or foreseen misuse. Examples of this could include:

• Do not expose the containers to direct sunlight

• Do not strike the containers

• Do not adjust the pressure relief valve or pump outlet pressure settings.

16.Marking

The pressurised equipment must be marked with:

• The CE mark (93/68/EC) (category I, II, III or IV only).

• The 4-digit code of the Notified Body used for conformity assessment (category II, III or IV only).

• The name and address (or other means of identification) of the manufacturer (or their authorised representative).

• The year of manufacture.

• Identification of the pressure equipment:

o Product type.

o Series, batch, or serial number.

▪ For individual systems, this could be the order number, project number etc.

• The essential maximum/minimum allowable limit.

* Post Brexit, it is intended that the UKCA mark is to be used in place of the CE mark. The pressure equipment manufacturer must verify the prevailing requirements at the time of completion.

The correct shape of the CE mark is to be clearly defined – information on the correct marking can be found in Directive 93/68/EC. The minimum size of the marking is stated as being 5mm high. Incorrect application of the marking (e.g. if the letters C and E are too close together) constitutes a breach of the legal marking requirements.

Additional markings may be necessary to ensure safe installation, operation, maintenance and periodic inspection; for a fire extinguishing, suppression or control system, this could include:

• The nominal size of the largest pipe diameter.

• The test pressure (bar).

• Date of pressure test.

• Intended use.

• The product group.

The markings must be applied to the pressurised equipment or assembly. For a fire extinguishing, suppression or control system where the pressurised equipment is in affect the entire pipework assembly with OEM parts (containers, hoses, check valves, nozzles etc), it will be more convenient to apply the marking by means of a tag or signage fixed to the pipework. The best place for this would be where the most part of the system equipment is located – e.g. on a container bank manifold, by a primary pump set etc.

It is important to note that where such a tag or signage is used, it must be physically attached to the actual pressurised assembly – i.e. the pipework, or a pressurised component which forms part of the pressurised assembly (such as an agent container). Affixing the tag or signage to other parts of the system – such as container racking, adjacent wall, fire control panel etc – is not in compliance with the Directive.

Historically, many UK manufacturers of fire extinguishing, suppression and control equipment have chosen to apply the markings to the documentation (data sheets, Operation and Maintenance Manuals, or system drawings) instead of physically on the pressurised equipment.

Whilst such practice is not strictly in accordance with the Directive, it could be argued that the limitation of using a tag or signage attached to the pipework for a system that could extend over many rooms or floors in a building is of limited value.

17.Declaration of Conformity

This document is required for all systems which fall into Category I, II, III or IV and which are therefore CE marked.

The Declaration of Conformity must state:

• The name and address of the manufacturer (or/and authorised representative).

• A description of the pressure equipment.

o E.g., BRAND NAME Fixed Gaseous Fire Extinguishing System.

• In the case of assemblies (i.e., fire extinguishing, suppression or control systems), a description of the pressurised equipment constituting the assembly.

o E.g., A pipework network connected to OEM supplied components compliant with the Pressure Equipment Regulation.

• The conformity assessment procedure followed.

o E.g., Module A

• Technical standards or specification used.

o Particularly important where alternative pressure testing has been used.

o E.g. BS EN 15004, BS 8489, LPS 1666.

• The signature of the person authorised to sign the legally binding declaration on behalf of the manufacturer.

• The details of the signatory.

o E.g., Name, position etc.

The following should also be included on the Declaration of Conformity, if applicable:

• The name and address of the Notified Body/UKAB used for the compliance assessment of the pressurised equipment.

o Since it is recommended that systems do not exceed the limitations of Category I, this will not be required.

• The name and address of the Notified Body/UKAB monitoring the manufactures quality assurance system.

o Since it is recommended that systems do not exceed the limitations of Category I, this will not be required.

• References of any harmonised standards used.

• References of any other Community Directives applied.

• Reference to the EC/UK type-examination certificate, EC/UK design-examination certificate or EC/UK certificate of conformity.

18.Technical File

The manufacturer must compile a technical file for the pressurised equipment which must cover the design concept (i.e., pressure ratings/calculations), manufacture and operation of the pressure equipment.

The purpose of this document is that if there is any future suspicion that the system is inadequate, or there is an incident with it, the technical file is used by manufacturer to provide documentary evidence that can be scrutinised by a regulatory body (e.g. Health and Safety Executive) that the equipment placed on the market met the requirements of the Directive. It must therefore state all relevant information that such as assessment can be made by an outside scrutiniser that would only regard the system as a pipe network and have no knowledge or expertise of how fire extinguishing, suppression or control systems work, or their requirements.

The Technical File is therefore created and retained by the manufacturer of the pressure equipment – i.e. the fire extinguishing, suppression or control system.

Such inspection of a Technical File can be demanded on 48 hours’ notice; it is therefore strongly recommended that the creation and maintenance of the Technical File is not neglected by the manufacturer. For a manufacturer of fire extinguishing, suppression and control systems, a single file, or files, should be produced to cover multiple generic system types. For instance:

• A manufacturer of inert gas and chemical agent fixed extinguishing systems could cover the requirements of both in the same Technical File, referencing the different maximum allowable system pressures and pressure strength calculations.

o i.e., Group 2, gas, systems.

• If the above manufacturer also provided Sprinkler systems, these would require a sperate Technical File.

o Being Group 2, liquid, systems.

Using a generic document avoids the need to create an individual Technical File for every individual system provided.

The Technical File therefore needs to contain: -

• A general description of the pressure equipment.

o Where the manufacturer of the systems is not also an OEM, the Technical File should also detail the extent of the system they manufacturer – i.e. the pipework and assembly of OEM parts onto it.

• Conceptual design and manufacturing drawings

o For fire extinguishing, suppression and control systems, these will need to be generic representations of typical system configurations.

• Descriptions and explanations of the drawings and operation of the pressurised equipment to enable an assessor to gain an adequate understanding of the pressurised equipment.

• Details of the standards – harmonised or not – applied to the pressurised equipment.

• Descriptions of the solutions adopted to meet the essential safety requirements where harmonised standards have not been used, or do not exist.

• Design pressure strength calculations used to verify the materials, grades and wall thicknesses etc used in the pressurised equipment.

o E.g. pipe wall thickness requirements for each system type, method of pipe jointing and open/closed section pipework

• Production or type examinations carried out.

o E.g., pipework pressure testing

• Any specific test reports.

The Technical File must be retained for a period of 10 years from the date of the supply of the pressurised equipment. However, where a manufacturer is supplying systems, this is academic as the Technical File is required continually.

19.Project file

Manufacturers of fire extinguishing, suppression and control systems invariably will maintain a file for each individual system supplied. This document can be used to provide contract specific information, to back up the Technical File.

The information particularly relevant to the Directive which should be retained in the project file includes: -

• System design drawings.

• System design calculations – particularly the maximum developed pressure.

• Certificates for the pipe and fitting materials.

• If used, the manufacturers type rating certificate for BS EN 10242 malleable iron fittings, where used on systems having a maximum allowable pressure of >20 bar.

• Certification to cover the pressure testing and final test/inspection.

• A copy of the Declaration of Performance.

As this document contains supplementary information to support the Technical File, it should also be retained for 10 years.

20.REQUIREMENTS FOR REFURBISHED OR MODIFIED PRODUCTS AND SYSTEMS

20.1 APPLICABILITY

The Directive applies to changes made to the compliant equipment already placed on the market; the ‘changes’ made must also be compliant. See Fact File 94 for an explanation of the requirements

20.2 FIRE EXTINGUISHING, SUPPRESSION AND CONTROL SYSTEMS

The Directive applies to existing compliant systems where the original system is subject to modification that extends or adds material to the system.

Examples could include: -

• A fixed extinguishing system where the location of the nozzles is to be changed to suit a new equipment layout, requiring a new pipework layout, the addition of a container and extension of the existing pipework, with new nozzles.

• A sprinkler system where the size of the protected area has been increased, requiring the installation of additional pipework and discharge heads.

Since the changes primarily relate to adding more OEM equipment, which is already supplied compliant and additional pipework, it is the new pipework which is the primary consideration.

The requirements are that the ‘manufacturer’ of the new pipework is responsible for the compliance of just that new pipework, in accordance with all of Part 1 of this Guidance Document, the manufacturer being as defined in Part 1.

In practice, this means that the new sections of pipework need their own marking and certification etc. The easiest way to achieve this may be by creating an addendum which can be inserted in the original systems Operation and Maintenance Manual. This could include a new system drawing specifically to highlight the new/modified sections of pipework; such a drawing would need to be produced for the installer regardless.

Should the new pipework fall into Category I (i.e., be DN 40 to DN 100 in diameter), the new sections would require their own individual CE marking and Declaration of Performance. Adding one or more marks onto an existing CE marked pipework network may be confusing. Applying a differentiating paint finish, or other markings to the new pipe sections may be one way of achieving this.

It should be noted that in modifying the system, the party doing so CANNOT be responsible for the originally installed system. Nor can the new pipework sections be ‘added’ to the existing system certification. The only exception to this would be if the party modifying the pressurised equipment also originally installed it.

If the modification only required the removal of material – e.g. removing one or more discharge nozzles/heads and some pipework, as the pressurised assembly does not contain new/more material, no new compliance would be required.