European Pressure Equipment Directive
The European Pressure Equipment Directive or “PED” (European Commission Directive no. 97/23/EC) is similar to the ASME Boiler & Pressure Vessel Code in that it provides requirements for certain pressure equipment. However, there is one major difference between the ASME Code and the PED; as a directive, or European law, PED compliance is mandatory within the European Union (EU) and for components being sent to the EU, for work on pressure-retaining equipment as defined under that law. The PED applies to equipment with pressures above 0.5 bar (approx. 7.25 psi at sea level), with certain exclusions (water heaters, car radiators, etc.). The full text of the PED can be found online HERE. When using “non-destructive” in a keyword search of the PED, be sure to hyphenate the term, as used in Europe. The page numbers used in this document refer to the scrollbar page number.
The PED is made up of three main components: a general introduction, or preamble (pages 2-5); articles (pages 6-18), which are the main text; and annexes, or appendices (pages 19-58).
In the preamble, Item 16 (page 4) states in part, “Whereas in order to ease the task of demonstrating compliance with the essential requirements, standards harmonized at European level are useful, especially with regard to the design, manufacture and testing of pressure equipment, compliance with which enables a product to be presumed to meet the said essential requirements.”
The above is important because the European Norm (Standard) EN 473, Non-destructive testing - Qualification and certification of NDT personnel - General principles, is a “harmonized standard” and per Item 16, NDT personnel that hold EN 473 certification are automatically approved to perform NDT tasks under the PED.
In the PED articles and annexes, the word “non-destructive” is mentioned in the following paragraphs:
Annex I, paragraph 2.2.3(b) (page 20), where it is used in an example;
Annex I, paragraph 3.1.3 (page 23), which states that for pressure equipment in categories III and IV, NDT personnel must be approved by a third-party organization recognized by a member state pursuant to Article 13;
Annex I, paragraph 3.2.2 (page 24), Proof test, which allows NDT as an alternative to a potentially harmful hydrostatic pressure test;
Annex I, paragraph 7.2 (page 27), joint coefficients;
Annex III, Module B, paragraph 4.1 (page 40), which requires that a Notified Body (NB) must verify that the personnel undertaking the permanent joining of pressure equipment parts and the non-destructive tests are qualified or approved in accordance with sections 3.1.2 or 3.1.3 of Annex I;
Annex III, Module B1, paragraph 4.1 (page 42), which has the same NB requirement shown for Module B above;
Annex III, Module D, paragraph 3.2 (page 44), which states the NDT tests must be recorded in the QMS documentation;
Annex III, Module E, paragraph 3.2 (page 47), which states the NDT tests must be recorded in the QMS documentation;
Annex III, Module F, paragraph 4.1 (page 51), which has the same NB requirement shown for Modules B and B1; and
Annex III, Module H, paragraph 3.2 (page 53), which has the same wording as Module E.
Of particular interest to U.S. companies supplying components to the EU under the PED that require NDT is Annex I, paragraph 3.1.3, which states that for pressure equipment in categories III and IV, the personnel must be approved by a third-party organization recognized by a member state as described in Article 13, Recognized third-party organizations. A list of recognized third-party organizations (RTPOs) and Notified Bodies (NBs) can be found HERE.
NBs, which are described in Article 12, are basically at a higher level of accreditation than an RTPO; an NB may also be an RTPO, but an organization can be an RTPO without being an NB. On the list at the link above, RTPOs are listed first with a “3P” designator in the left column, and Notified Bodies are listed with “NB ####” in the left column. Examples of RTPOs are the British Institute of NDT (BINDT), TWI Certification LTD and Sector Cert GMBH. An example of an NB is TÜV Nord Systems GMBH & Co. KG, NB 0045, which is also an RTPO. To determine what portions of the PED an RTPO or NB is accredited for, click on the name of the body, in the row titled “97/23/EC Pressure equipment,” open the HTML or PDF file in the right column and scroll down that page. Bodies authorized to approve NDT companies under the PED will have “Approval of non-destructive testing personnel” listed.
In addition to the main PED document, there are Guidelines (similar to Interpretations for SNT-TC-1A) that are not a legally binding interpretation of the directive, but are the unanimous opinion of the member states’ experts and are designed to ensure the consistent application of the directive. The Guidelines are located HERE, and those that apply to NDT are in Section 6, Interpretation of the Essential Requirements on Manufacturing, HERE. In the PED Guidelines, “non-destructive testing” is mentioned in the following Guidelines:
- Guideline 6/9 (page 10) states that no accreditation is required for the manufacturer’s NDT or DT (destructive testing) laboratory or for the testing laboratory that the manufacturer may subcontract for NDT or DT.
- Guideline 6/13 (page 15) responds to this question: “For pressure equipment in categories III and IV, can Non-Destructive Testing personnel holding qualifications other than those satisfying criteria of the harmonized standards (e.g. EN 473:2000 General principles for qualification and certification of NDT personnel) be approved by RTPO notified by a member state under Article 13 paragraph 1?” The published answer is “Yes,” with the following additional information: “NDT personnel certified under standards, other than the harmonized standards, may be approved by a RTPO provided it is satisfied that certification criteria equivalent to the harmonized standards has been met, and that the scope of certification is relevant to the testing of permanent joints in pressure equipment.
“A RTPO may sub-contract part of its work, within the provisions of the New Approach guide, but shall keep the full responsibility and issue the approval. The approval of the personnel shall be done by a RTPO on an individual basis. “Note: Approval of an individual solely on the basis of a certificate issued by another body where no contractual arrangement exists with the RTPO does not fulfill the requirement of the Pressure Equipment Directive.”
What the above means to a U.S. supplier of pressure equipment goods to the EU is this:
There are two ways to satisfy the NDT certification requirement for approval under the PED:
- Have your NDT personnel get EN 473 certification;
- Have an RTPO approve your employer-based certification program for use under the PED. Several RTPOs provide this service, which requires that the RTPO or its authorized representative review the company’s Written Practice and written examinations, then witness those company-selected NDT personnel taking practical examinations. Upon successful completion of this process, the RTPO will issue the company a letter or certificate stating that those personnel have been approved to perform NDT work under the PED for that company. These approvals are usually for a period of three years and require surveillance in the intervening years. Should the approved personnel leave the company, their approval is terminated.
* For clarification, EN 473 certification and PED approval are not the same thing. EN 473 certification means that a person has met all of the requirements for certification under a third party (or “central”) certification program that complies with the European standard EN 473 and is administered by an accredited certification body. PED approval means that a person has been approved to perform NDT tasks under the PED in one of the three methods listed above.