New Irish pressure systems regulations major step forward 05 November 2013

The new regulations for pressure systems that came into force in Ireland on 1 January 2013 have been a major step forward, according to HSB Engineering Insurance Services.

Designated SI 445 of 2012 Safety, Health and Welfare at Work (General Application) (Amendment) Regulations 2012, they now encompass the requirements of the previous Factories Act and regulation 30 of the Safety, Health and Welfare at Work regulations 2007.

They also broadened the scope to include specific requirements for design, construction, safe operation, examination, testing, reporting and maintenance of pressure equipment that was not previously covered.

Further, the new regulations increased both the range of pressure equipment to be examined (from the Factories Act covering steam boilers, steam receivers and air receivers) and the locations of pressure equipment –from factories to all places of work.

They were also brought in very quickly, with the timeframe for all due or overdue examinations having to completed within three months – by 31 March 2013.

Equipment now coming within the scope of the new pressure systems regulations and requiring periodic examination of pressure vessels includes: hot water boilers operating at 110C or above; expansion/pressurising vessels, air/oil receivers, nitrogen receivers, medical autoclaves, CO2 vessels, hydraulic accumulators and ammonia vessels.

Unlike the UK PSSR (Pressure Systems Safety Regulations), however, there is no requirement for a written scheme of examination (WSE), detailing scope and periodicity of examinations. Instead, examination periods are specified at 14 months for steam-generating equipment and 26 months for all other pressure vessels.

For example minor pressure systems, such as a small air receiver in a workshop, would use the 26 month examination, just as it did under the previous regulations.

There is also some flexibility for varying the frequency of examination by written justification from a competent person or using manufactures instructions.

A typical example here would be an air or oil receiver with the SAFed justification. Then the frequency could be extended right up to 72 months. Also, only the pressure vessels and protective devices require examinations and reports. Other equipment, such as pipework, comes under more general use of work equipment requirements.

Employers who are owners or users of pressure equipment have a responsibility under the regulations to ensure the following: the equipment is properly designed and constructed and suitable for use; safe operating limits have been established; suitable information and instructions are provided to operators.

They must also ensure that: a maintenance file is kept for each pressure system; the competent person is consulted before significant repairs are undertaken; new equipment is examined by a competent person prior to being put into use.

And finally, they must ensure that: periodic examinations are carried out when due; reports of examination are kept; a register of pressure vessels is maintained; pressure vessels are properly marked; and information is forwarded on if equipment is sold.

The compilation of a register of all pressure vessels has proved to be quite difficult for some companies that now find they have twice as many statutory vessels as they had previously.

Some of the equipment may be as much as 40 years old and manufactures may have ceased trading, so sourcing original documentation may not be possible. If there is sufficient information on the name plate that can be used initially –although, if that is sited beneath insulation, it may be hard to find. Where no information can be found then design re-verification may be the only option.

That said, there is no standard reporting period given for the competent person to supply his report to the owner and user, compared to 28 days with PSSR in the UK. The reporting of immediate cessation of the use of a pressure vessel is also different in that the competent person must send a copy of the report of the examination to the authority within 20 days of the examination. PSSR imminent danger reports also have to be supplied to the enforcing authority within 14 days.

As for written schemes of examination, some larger sites in Ireland are seeing the advantage of scheduling pressure systems in this way. Information in the written scheme inventory could be used to populate the register and produce the periodic justification required under the pressure systems regulations.

Some of larger companies also have an international policy of using risk-based inspection (RBI) methodologies to ensure that the scope of the examination takes into account duties and plant operating conditions.

The necessary information to meet the pressure systems regulations register requirements can be gleaned in a similar way to that of the written scheme of examination.

"At HSB Engineering Insurance Services, we have been ensuring that our engineer surveyors, brokers and clients are aware of the changes," says the company's Alan Richards (pictured).

"We have given advice and support identifying additional items of pressure equipment that requires examination and carrying out periodic justification for those items that can benefit from that process," he continues.

"Commissioning examination and periodic examination are on-going, as are approval of significant repairs and modifications. We believe that by assisting our clients in this way we are helping them to ensure that their statutory obligation has been met."

Brian Tinham

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