ATEX Directive 94/9/EC - Draft Questions and Answers

2011-08-13 23:13:00

APPLICATION OF THE DIRECTIVE:

End of transition period for ATEX Directive 94/9/EC - Draft Questions and Answers

At the ATEX Standing Committee held on 29 June 2001 the European Commission made it absolutely clear that there will be no extension to the transition period over that already prescribed. As stated, all products falling within scope of Directive 94/9/EC ("the ATEX Directive") will have to comply from the 1 July 2003.

It was considered by a number of Member States that further guidance might be required for those manufacturing spare parts held in stock purchased during the transitional period for use after this period ends.

On the basis of a number of questions presented, the following interpretations were discussed by the Committee.

The European Commission has issued guidance, ("the Blue Guide") on the interpretation of new approach Directives, of which the ATEX Directive is one. This may be helpful in interpreting the ATEX Directive, although definitive interpretation is for a court, ultimately the European Court of Justice. The Blue Guide formed the basis for the Standing Committee's discussions on this issue.

Q1 - What is meant by "Ready for Use", as used in the Blue Guide? The Blue Guide states that certain products that can be put into service after the end of the transitional period if ready for use at the time they are placed on the market. However most spare parts will require some work to install them. (ref. The Blue Guide, p.20)

Each spare part must be considered in its own circumstances and it is difficult to generalise out of context. However, for spare parts which are not equipment, a protective system, a component or a device according to Article 1 of the ATEX Directive the answer is provided for at Chapter 7 of the Commission's Guidance notes to the Directive, the ATEX Guidelines, 2001 Edition. Spare parts that are not equipment, protective systems, components or devices, as defined in the ATEX Directive, are not subject to the ATEX Directive. Therefore, there is nothing in the ATEX Directive to prevent them from being placed on the market any time after the end of the transitional period.

Spare parts which are equipment, a protective system, a component or a device according to Article 1 of the ATEX Directive will have to comply with the ATEX Directive when placed on the market after the end of the transitional period.

Generally, repaired products, which are within the scope of the ATEX Directive, need not be assessed against the requirements of the ATEX Directive after repair, as a repair does not substantially modify the product.

The Standing Committee considered that, although each case must be assessed on it own merits, in general terms "Ready for use" means the ability to be incorporated or installed without a change to the performance or safety characteristics as originally anticipated by the manufacturer.

Q2 - Can there be some relaxation on the use of safe but non-compliant spares that may be held by end-users for use during the foreseeable life of the equipment/ assembly?

In general, equipment, protective systems, components and safety devices, as defined in Article 1of the ATEX Directive which are spare parts and which are held by the end-user are likely to have been have been placed on the market already.

If the above spare parts were placed on the market prior to the end of the transition period and they were ready for use at that time then, according to the Blue Guide, they can be first used after the end of the transition period. Whether a product is ready for use must be assessed on a case by case basis and any subsequent alteration of the product would have to be taken into account in considering whether it was ready for use when placed on the market.

However, there may be spare parts falling within the scope of the ATEX Directive, which may be held by an end-user that may not have already been placed on the market. This is the case for equipment, protective systems or devices that are manufactured by the user for own use. In these circumstances the spare part will need to comply with the requirements of the ATEX Directive when it is first put into service.

Q3 - Can the installing of a spare part allow the freedom to ensure the overall continuing integrity of the system by using non-compliant parts subject only to the requirement to provide a satisfactory risk assessment under the relevant "Use" Directive?

The consequences of installing each spare part must be assessed individually. However, in general, equipment, protective systems, components or devices, as defined in the ATEX Directive, which are intended to be integrated into an installation will inevitably be placed on the market and/or put into service and consequently will have to comply with the requirements of the ATEX Directive at that time.

Q4 - After the end of the transitional period, will manufacturers be able to sell non- compliant stock to the owners of relevant installations, which are not in scope of the ATEX Directive? This would mean that these installations would only be subject to the relevant "Use" Directive (92/91/EEC, 92/104/EC or 1999/92/EC), requiring only an overall risk assessment?

See answer to Q3 above. If this stock represents equipment, protective systems, components or devices as defined in the ATEX Directive it must comply with the requirements of the ATEX Directive when placed on the market.

In respect of the second question installations are not covered by the ATEX Directive but are covered by the relevant "Use" Directive.

Q5.1 - Distributors are those in the distribution chain who are neither manufacturers nor end-users. At the end of June 2003 they may be holding stock which has been "placed on the market" but is not in the hands of end-users. This equipment may already meet national health and safety requirements applicable at the relevant date.

The circumstances of each piece of stock would have to be examined individually.

However, such stock would already have been placed on the market before end of the transitional period and would have complied with the relevant national health and safety provisions at that time, therefore such stock did not need to comply with the requirements of the ATEX Directive at that time. As regards putting into service the following approach could be considered:


- For spare parts see A2;


- In other cases (e.g. where the safety characteristics are altered through the nature of the installation) the obligation for compliance with the requirements of the ATEX Directive is unavoidable.

Q5.2 - Distributors who are part of the commercial chain of the manufacturer

It is clear from 5.1 that, on a case-by-case basis, equipment sold down the distribution chain may be considered to be placed on the market. However, there are cases when the distribution chain is part of the commercial chain of the manufacturer rather than a separate organisation. Footnote 31 of the Commission's "Guide to the New and Global Approach" recognises this situation and makes it clear that equipment moving down this type of distribution chain could also be considered as having been placed on the market. However, market surveillance authorities would need to ensure that a "transaction" had taken place even if the equipment was not as such "sold".

This evidently needs to be considered by the market surveillance authorities of the Member States on a case-by-case basis. In effect, there is a general burden of proof on the manufacturer to show that the equipment has been given to the authorised representative distributor with the real intention of distribution and use rather than a mechanism of treatment of stocks.

Q6 - Who will become responsible for the purpose of the assessment of remaining stock against the requirements of the ATEX Directive after 1 July 2003, the distributor or the end-user?

The circumstances of each situation will have to be examined individually.

However, according to general principles of New Approach, the manufacturer would be responsible for conformity assessment (assisted by a notified body, if required). Further information is provided at Chapter 3 of the Blue Guide. The responsibilities on the manufacturer or his authorised representative undertaking the conformity assessment of products are laid down in the Annexes to the ATEX Directive.

Q7 - Products manufactured for "Own Use" are subject to the ATEX Directive, but will they be required to CE mark them and hold a signed DOC, in addition to the technical construction file?

Generally, though each case must be examined individually, persons manufacturing for own use will be putting the equipment, protective systems or devices into service and will be subject to those requirements of the ATEX Directive, which are placed on any other manufacturer.


How should the Directive be applied to filter units and vented silo bins? (revised version)

The following was discussed for filters at the ATEX Standing Committee held on the 1st of December 2005.

For the venting devices of silo bins it has been discussed at the ADCO-Group on the 21st November 2007 and 11th June 2008, as well as at the ATEX Working Group meetings on 25th June 2008 and 23rd January 2009.

Further revision has been approved at the ATEX Working Group meeting on 16 December 2009.

Most filters and silo bins will have an explosive dust cloud inside at some point during normal operation.

The inside may be areas in which an explosive atmosphere caused by air/dust mixtures are present continuously, for long periods or frequently, or areas in which such an atmosphere is likely to occur, depending on the operating conditions.

Many filters and silos are located in the open air, or in a room in a building which does not need to be classified as hazardous.
With the exception of 5)a) and 7) the description below of different cases assumes that filters and silos themselves will not be a source of dust release that would give rise to a potentially explosive atmosphere in the surrounding area.

This description also considers that many apparatuses with filters inside are fitted with explosion protection devices, such as vent panels, doors or suppression equipment.

  1. The filter or the silo bin has no moving parts or electrical equipment on the inside, and is located in a non hazardous area.
  2. The filter has moving parts inside that can be considered as mechanical equipment, such as a bag shaking mechanism, or a screw feeder to remove collected dust. The whole filter is located in a non-hazardous area.
  3. The complete filter or the silo bin has electrical equipment inside. In filters those electrical equipment may be a pressure switch, or level switch on the container that collects the dust, in silos level indicators are widely used.
  4. The silo bin or the complete apparatus with the filter is fitted by the manufacturer with explosion vent panels or doors, supplied by another manufacturer.
  5. The silo bin or the complete apparatus with the filter is fitted with explosion vent panels or doors produced and integrated into the filter or silo by the filter/silo manufacturer themselves.
  6. A - normally small - apparatus with only a filter sock, plastic collection bag and fan, but no metal enclosure.
  7. The silo or an apparatus with a filter is intended to be installed in an area, in which air/dust mixtures are unlikely to occur or, if they do occur, are likely to do so only infrequently and for a short period only.

1)The filter or the silo bin has no moving parts or electrical equipment on the inside, and is located in a non hazardous area.

Conclusion:

These filters or silos are not in scope of the Directive 94/9/EC.

Electrostatic hazards may exist from insulating surfaces inside the filter, from the filter elements or from cone discharges in silos. This risk depends for example on the properties of the dust being collected, and other operating conditions. But any electrostatic risks are not considered as giving the filter or silos its own potential source of ignition, so these filters or silos do not fulfill the definition of equipment in Article 1(3)a.

Remark: This filters or silos even do not fulfill the other criteria of the definition.

The electrostatic risks can be covered by other directives, for example the Machinery Directive when the filter is part of a machine. In this case the manufacturer of the machine is responsible to avoid this risk according to the regulations of the Machinery Directive. In all cases these risks must be controlled by the user under Directive 1999/92. The electrostatic risks are covered in EN 13463-1.

2)The filter has moving parts inside that can be considered as mechanical equipment, such as a bag shaking mechanism, or a screw feeder to remove collected dust. The whole filter is located in a non-hazardous area.

Conclusion:

The manufacturer must assess whether the moving parts create its own potential source of ignition. If the moving parts do not create any potential source of ignition, perhaps because they have low power, or move very slowly, the situation is the same as case 1, and the filter is not in scope of the directive.

Remark: Low power in this sense is not given, when for example the power source is strong and only the power inside the equipment is reduced by protection methods in order to avoid an ignition risk. There is a similar situation in case of the electrical type of protection the "intrinsic safety".

If the mechanical equipment on the inside does create an ignition risk, this equipment (as part of the complete apparatus) must comply with the Directive 94/9/EC (see chapter 4.1.2.3 of the Guidelines).

If inside the filter an explosive atmosphere caused by air/dust mixtures is present continuously, for long periods or frequently, according to Annex I for the equipment inside conformity with category 1 should be reached. But this will in respect of the state of the art not always be possible. In these cases according to

  • Annex II A technological knowledge must be taken into account

    and
  • Annex II 1.0.1 the principles of integrated explosion safety must be applied.

That means when it is not possible to prevent the ignition source sufficiently - according to the "state of the art" - to reach category 1, category 2 can be sufficient when the manufacturer takes additional measures "to halt it immediately and/or to limit the range of explosion flames and explosion pressures to a sufficient level of safety" (see Annex II 1.0.1 indent 3). It is in the responsibility of the manufacturer to take this decision.

The explosion vent can be seen as an example of integrated explosion safety as described under Annex II 1.0.1.

In this case, and if the complete apparatus (filter with explosion vent panel or doors) is produced and integrated by the same manufacturer, not only the mechanical but all equipment inside falls under the scope of Directive 94/9/EC. Consequently the manufacturer takes the following measures:
- Preventing sufficiently the ignition source inside (according to the "state of the art");
- Selecting an appropriate protective system in order to limit the range of explosion flames and pressure;
- Designing the filter in such a way that it can withstand an internal explosion without rupturing (design for the reduced explosion pressure in conjunction with explosion pressure relief or explosion suppression).

3)The complete filter or the silo bin has electrical equipment inside. In filters those electrical equipment may be a pressure switch, or level switch on the container that collects the dust, in silos level indicators are widely used.

Conclusion:

This electrical equipment is equipment in the sense of Article 1.1 of the Directive 94/9/EC and therefore must comply with this directive.

4)The silo bin or the complete apparatus with the filter is fitted by the manufacturer with explosion vent panels or doors, supplied by another manufacturer.

Conclusion:

These panels or doors are 'protective systems' in the sense of the Directive 94/9/EC and the manufacturer of these systems has to apply the directive when placing this as an autonomous system on the market. That means the procedure set out in Article 8.2 has to be applied and they must be CE and Ex marked. Selecting the correct panel or door (for example: size, quality, function) depends on the application and has to be done by the manufacturer of the apparatus.

5)The silo bin or the complete apparatus with the filter is fitted with explosion vent panels or doors produced and integrated into the filter or silo by the filter/silo manufacturer themselves.

Conclusion:

For filters we have to distinguish two cases:
a) The complete apparatus is in the scope of the Directive 94/9/EC
b) The complete apparatus is not in the scope of the Directive 94/9/EC.

For silos, only case b) is applicable.

Case a)

These are not autonomous protective systems according to Article 1(3)b because they are placed on the market as a part of an equipment in the sense of Article 1(3)a and not separately. Therefore Article 8(2) has not to be applied. The protective system alone is not in the scope of the directive but the whole equipment. That means the conformity procedure of the equipment includes the protective system.

However, if the manufacturer sells complete replacement vent panels or doors as spare parts, these are autonomous protective systems, separately placed on the market and then he must apply the Directive 94/9/EC. That means they must for example be tested, CE and Ex marked in the same way as complete panels or doors separately placed on the market from other manufacturers.

Case b)

These complete apparatus or explosion vent panels or doors are autonomous protective systems according to Article 1.3 b because they are separately placed on the marked in the sense of the directive and therefore Article 8(2) has to be applied. That is because they are not placed on the market as a part of an equipment in the sense of Article 1(3)a.

Remark for filters: In case 4 or 5, the manufacturer in any case carries responsibility for ensuring that the body of the filter will not fail in the event of an explosion, even though it is not covered by specific EU legislation. Users should ask the manufacturers how they can be sure that the filter complies with the safety requirements of the Work Equipment Directive 2009/104/EC (that repealed the directive 89/655/EC amended by 95/63/EC and 2001/45/EC); especially Annex I, 2.7.

Remark for silos: Even protective systems such as vent areas which are integrated in the cell ceiling of silos or inserted lightweight constructions are protective systems for the purpose of Directive 94/9/EC and must be placed separately on the market as autonomous protective system and must therefore be treated as such with regard to assessment of conformity and marking.

6)A - normally small - apparatus with only a filter sock, plastic collection bag and fan, but no metal enclosure.

Conclusion:

If during the intended use a dangerous explosion pressure cannot be formed in such a small apparatus when a dust cloud inside the filter is ignited, the inside is not to be classified as a hazardous area and the equipment used inside is not in the scope of the Directive 94/9/EC.

This is the case with some filters used for collecting wood dust and wood-waste.

7)The silo or an apparatus with a filter is intended to be installed in an area, in which air/dust mixtures are unlikely to occur or, if they do occur, are likely to do so only infrequently and for a short period only.

Conclusion:

In respect of the complete apparatus the Directive 94/9/EC is only relevant for the manufacturer, if it is equipment in the sense of this directive. To find out if the whole apparatus is such equipment, the manufacturer of this apparatus for example must examine if it creates any possible sources of ignition, which can ignite an explosive atmosphere on the outside. When this can happen, he has to apply the Directive 94/9/EC.

The apparatus must in this case conform to category 3.

Remark: Equipment of this type may be needed if there are for example sources of dust release from other equipment nearby.

As silos have no own possible ignition source, which can ignite an explosive atmosphere on the outside, they will not conform to category 3.

General remark for autonomous protective systems:
Measures for the indirect explosion pressure venting at buildings, like for example windows, walls of lightweight construction or similar, do not fall within the scope of Directive 94/9/EC. The employer/operator himself is responsible to implement such measures. In doing so priority shall be given to the requirements according to the building regulations.


Application of the directive 94/9/EC to Gas Turbines - revised version
  1. It was accepted by all concerned that:

- Gas turbines on their own are not normally placed on the market as a single functional unit but are generally incorporated with other machinery before they can function, and will only function as intended once they are properly installed.

- Since 30 June 2003, manufacturers and users of gas turbines need to comply, in addition to the machinery directive, as appropriate with the requirements of both ATEX Directives 94/9/EC and 1999/92/EC respectively - relating to design and manufacture of such equipment and the health and safety of workers potentially at risk of explosive atmospheres.

- Gas turbine fuel supplies may give rise to a potentially explosive atmosphere in the vicinity of the turbine. Additionally, other sources of a potentially explosive atmosphere may also exist, e.g. lubricating oils. Equipment in category 3 of equipment-group II would usually be required in such areas.

- In normal circumstances, a gas turbine could have hot surfaces above the auto ignition temperature of the fluids used. Operation under fault conditions may increase surface temperatures.

- A gas turbine which has surface temperatures that can lead to the ignition of a potentially explosive atmosphere cannot comply with the relevant provisions of directive 94/9/EC. In such circumstances additional measures are required.

  1. It should be noted that in all instances of the following guidance the general concepts described in chapters 4.1.2.3 and 4.1.2.4 of the Guidelines on the application of directive 94/9/EC will apply (e.g. ATEX compliant equipment must be used, where applicable, inside machinery).

- Although manufacturers must, to the state of the art, eliminate or control sources of ignition, it may not be technically possible to reduce the temperature of all hot surfaces to comply with the Essential Health and Safety Requirements of the ATEX Directive 94/9/EC(1).

- A number of alternatives are available for selection as a basis for safety, e.g. limitation of the volume of the explosive atmosphere by dilution ventilation(2), explosion relief, explosion suppression or a combination of these techniques.

- A supplier (this may be the turbine manufacturer, packager, installer, final supplier, etc. and in some cases the end user) delivering gas turbine machinery and associated safety devices is responsible for risk assessment and implementation of the chosen basis of safety under Directive 94/9/EC. Irrespective of the chosen basis of safety there is the potential for an explosive atmosphere to arise near the turbine, and proper consideration should be given to minimising the risk of ignition. The supplier as described above is also responsible for the communication of instructions for safe use and any residual risk to the end user sufficient for the completion of risk assessments under the relevant work place directives.

- Interested parties should consider Chapter 3 of the Commission guidance on the ATEX Directive 94/9/EC, which provides further information on the relevant responsibilities.

  1. a gas turbine as a complete machine the ignition sources of which have no interface to a potentially explosive atmosphere outside the enclosure does, however, not fall under scope of the ATEX Directive 94/9/EC and as such cannot be affixed with the special marking for explosion protection and other marking detailed at Annex II, EHSR 1.0.5. of the Directive.
  2. intended to be used in a potentially explosive atmosphere.

(1) Annex II, EHSR 1.3.1 "Potential ignition sources such as …, high surface temperatures, ..must not occur".

(2) Dilution ventilation reduces the size of any flammable cloud to below that which would result in a hazardous explosion if ignited. In order that the dilution ventilation ensures a negligible risk of an explosive atmosphere at all times, the ventilation system should have additional safety features such as e.g.: a 100% standby fan; an uninterruptible power supply to the ventilation fans; interlocks so that the gas turbine cannot start without sufficient ventilation; proven automatic isolation of fuel supply if ventilation fails.


Application of the directive 94/9/EC to Steam Turbines - revised version Steam Turbines
  1. It was accepted by all concerned that:

- Steam turbines on their own are not normally placed on the market as a single functional unit but are generally incorporated with other machinery before they can function, and will only function as intended once they are properly installed.

- Since 30 June 2003, manufacturers and users of steam turbines placed in a potentially explosive atmosphere need to comply, in addition to the Machinery Directive, as appropriate with the requirements of both ATEX Directives 94/9/EC and 1999/92/EC respectively - relating to design and manufacture of such equipment and the health and safety of workers potentially at risk of explosive atmospheres.

- Steam turbines cannot give rise to a potentially explosive atmosphere by themselves but may be installed in a potentially explosive atmosphere originating from external sources (e.g. when gaseous hydrogen used as a turbo-generator coolant, being released and mixed with the air, contributes to classification of zone around the turbine).

- In normal circumstances, a steam turbine could have hot surfaces above the auto ignition temperature of the external potentially explosive atmosphere. The surface temperatures depend on the temperature of incoming steam which is supplied by an external source such as a boiler.

- A steam turbine which has surface temperatures that can lead to the ignition of a potentially explosive atmosphere cannot comply with the relevant provisions of Directive 94/9/EC. In such circumstances additional measures are required.

  1. Given the above, the obligations of the manufacturer and user of steam turbines need to be considered. It should be noted that in all instances of the following guidance the general concepts described in chapters 4.1.2.3 and 4.1.2.4 of the Guidelines on the application of Directive 94/9/EC will apply (e.g. ATEX compliant equipment must be used, where applicable, inside machinery).

- The manufacturer can ATEX certify the steam turbine for use in external potentially explosive atmospheres with auto ignition temperatures above the specified maximum steam inlet temperature.

- Although manufacturers must, to the state of the art, eliminate or control sources of ignition, it may not be technically possible to reduce the temperature of all hot surfaces to comply with the Essential Health and Safety Requirements of the ATEX Directive 94/9/EC(1).

- The main measure for safety is to prevent the explosive atmosphere from being in contact with the hot surfaces of the steam turbine, e.g. by an over-pressurised enclosure.

- A supplier (this may be the turbine manufacturer, packager, installer, final supplier, etc. and in some cases the end user) delivering steam turbine machinery and associated safety devices is responsible for risk assessment and implementation of the chosen basis of safety under Directive 94/9/EC. Irrespective of the chosen basis of safety if there is the potential for an explosive atmosphere to arise near the turbine, and proper consideration should be given to minimising the risk of ignition. The supplier as described above is also responsible for the communication of instructions for safe use and any residual risk to the end user sufficient for the completion of risk assessments under the relevant workplace directives.

- Interested parties should consider Chapter 3 of the Commission guidance on the ATEX Directive 94/9/EC, which provides further information on the relevant responsibilities.

  1. In full application of the above guidance, a steam turbine as a complete machine the ignition sources of which have no interface to a potentially explosive atmosphere outside the enclosure does, however, not fall under scope of the ATEX Directive 94/9/EC and as such cannot be affixed with the special marking for explosion protection and other marking detailed at Annex II, EHSR 1.0.5. of the Directive.
  2. It is evident that a steam turbine, delivered as a complete machine by one supplier, is considered to be an assembly in the sense of Directive 94/9/EC and shall be marked accordingly, if it is intended to be used in a potentially explosive atmosphere.

(1) Annex II, EHSR 1.3.1 "Potential ignition sources such as …, high surface temperatures, ... must not occur".


Application of the directive 94/9/EC to Petrol pumps - revised version

This subject was discussed at the ATEX Standing Committee meetings on the 6th & 7th February 2003, and on the 30th November 2006. The following is a summary of those discussions.

It was recalled that, whilst Categorisation of equipment was always the sole responsibility of the manufacturer, the view of the majority of the ATEX Standing Committee considered that, under normal circumstances, petrol pumps may be suitably categorised as Category 2.

Given this, and the fact that the assembly is sufficiently complicated and includes an electrical motor - with an additional ignition hazard as a result of assembling pump and motor -, the majority of the members concluded that Notified Body intervention with respect to the completed assembly was required, in line with the complete conformity assessment procedures outlined in the ATEX Directive 94/9/EC (Annex III: EC-type examination). See also the ATEX Guidelines, 3.7.5 "Assemblies", point 2c).


Application of the directive 94/9/EC to Cables Should cables be marked according to the ATEX directive?

Cables are not covered by product related ATEX directives (neither as equipment neither as components) because in most cases they fall into the field of installations, and as such, cables have never been regarded as an ignition source of considerable risk in hazardous areas if protected properly in a mechanical and electrical manner.

Furthermore and with a view to the extreme variety of possible situations of application in equipment devices in the scope of directive 94/9/EC, a reliable and serious list of ATEX-conforming cables seems not to be practicable. End users and installers may choose cables according to the state of the art and according to the requirements of the Low Voltage Directive 73/23/EEC. Cables conforming to the latter Directive are considered to be adequate for use in products falling under the scope of Directive 94/9/EC.

Consequently, cables should bear no marking according to directive 94/9/EC.

 

 

 

 

 

 

 

 

 

 


 

Clarification for equipment with categories two or three

 

 

 

 

 

 

 

Application of the directive 94/9/EC to Rotating Mechanical Seals When a Mechanical Seal[1] is a Machinery Element and when an ATEX-Component

DEFINITION:

A mechanical seal is a device which prevents leakage of fluids along rotating shafts. Primary seal function is at right angles to the axis of rotation between one stationary ring and one rotating ring.

MACHINERY ELEMENT:

These are parts of machinery not defined within 94/9/EC.

Most mechanical seals are machinery elements. Typically these seals are:
• Catalogue mechanical seals and their parts, selected by the equipment manufacturer alone or with assistance from the mechanical seal manufacturer.
• mechanical seals stocked by the equipment manufacturer or end user for general applications
• mechanical seals used for applications where the service conditions are not closely specified
• non cartridge-seals and parts
• standard cartridge-seals.

Mechanical seals will also be machinery elements if a risk assessment by the mechanical seal or equipment manufacturer shows that the seal is not expected to be an ignition source even in the event of fault conditions.

ATEXCOMPONENT :

The following definition is taken from the European Commission ATEX Guideline (Second edition).

The two defining elements for components are that they,
are essential to the safe functioning of equipment and protective systems with respect to explosion protection (otherwise they would not need to be subject to the directive);
• with no autonomous function (see 3.8) (otherwise they would have to be regarded either as equipment, protective system or as device according to Article 1.2).

Engineered mechanical seals maybe classified and sold as ATEX components. Typical examples are:
• Mechanical seals for specific applications where close co-operation between mechanical seal manufacturer and equipment manufacturer is required and will often result in a specifically designed mechanical seal.
• Mechanical seals for some category 1 equipment.

In this case the mechanical seal manufacturer shall supply sufficient information about the performance of the seal so that the equipment manufacturer does not need to repeat unnecessary efforts such as tests or calculations concerning the mechanical seal in order to ensure that the equipment complies with ATEX requirements. The equipment manufacturer shall supply sufficient information about the intended application and equipment.

RESPONSIBILITIES:

A) Mechanical seal manufacturer:

Case 1: Mechanical Seals supplied as Machinery Element
It is normal practice that the manufacturer of mechanical seals supplied as Machinery Element provides complete documentation for safe use of his product i.e.:
instruction manual for incorporation into equipment, which shall include safety aspects and limits of operation.

Case 2: Mechanical Seals supplied as ATEX Components
Mechanical seals shall comply with article 8.3 of 94/9/EC ATEX Directive.
An ATEX component mechanical seal shall be supplied at least with the following information:
• all information/documentation given for case 1
• results of relevant calculations and/or tests that have been carried out
• a temperature rating as far as possible
• an indication of the category
• a list of ATEX essential safety requirements that the mechanical seal complies with
• what fault conditions have been considered for category 1 or 2 mechanical seal
• a close specification for intended use, for example gas group
• a certificate of conformity
• marking for components in accordance with the latest ATEX Guidelines

B) Equipment Manufacturer:

In all cases the equipment manufacturer is responsible for the entire package within his scope of supply and therefore it will be required to comply with article 8.1 of 94/9/EC ATEX Directive.

[1] This consideration paper does not consider mechanical seal control systems.

 


Application of the directive 94/9/EC to Safe Openings Safe Openings - Annex II, 1.2.6

Annex II, Essential requirement 1.2.6 reads as follows:

1.2.6. Safe opening

If equipment and protective systems are in a housing or a locked container forming part of the explosion protection itself, it must be possible to open such housing or container only with a special tool or by means of appropriate protection measures.

Even though there is now only "special fastenings", the three historic levels of "safe opening" are not precluded by the essential requirement 1.2.6 and it is not the intention of directive 94/9/EC to require a level of safety higher than that required by the third editions of EN 50014 series of standards for the equivalent zone of risk.

Level 1, the use of "Special Tools" e.g. on fasteners with hexagonal socket heads can still be used as specifically described by 1.2.6.

Level 2, the use of fasteners which require some form of tool to open the door e.g. a simple screwdriver, an adjustable spanner, or a key, are allowed in 1.2.6 where the additional "appropriate protection measure" would be the presence of a warning label requiring the operator to "De-energise before opening" or similar text.

Note : To qualify for Level 2 a "key" operated fastener (if used) should be used in conjunction with a lock mechanism that automatically locks the door in the closed position when the door is closed. The use of a lock which requires the use of a key to lock it in the closed position is not allowed for Level 2 since the operator may choose not to lock the door again when the door is closed and the additional protection required is no longer provided.

Level 3, the use of a door fastener which would allow the operator to open the door of the enclosure without the use of any tool i.e. with the "bare hands", is also not prevented by 1.2.6. However because of the increased personal and explosion risk additional measures have to be applied e.g. the use of an electrical or mechanical interlock to de-energise automatically the interior of the enclosure as well as the conspicuous presence of the warning label used in Level 2 above.


Application of the directive 94/9/EC to Bucket Elevators How are bucket elevators to be treated within the framework of Directive 94/9/EC especially in respect that in the surrounding area of bucket elevators potentially explosive areas are not necessarily present?

In addition to Chapter 4.1.2 of the Guidelines the following can be said:

The intention of Directive 94/9/EC is to avoid the ignition of potentially explosive atmospheres by equipment, protective systems and components. According to the potential hazards and the prevention measures the products are divided into categories.

Directive 94/9/EC defines a potentially explosive atmosphere as an atmosphere, which could become explosive due to local and operational conditions. This means that the potentially explosive atmosphere is either present from the beginning or develops during the working process (e.g. in relation with the conversion of energy or the processing of materials).

In bucket elevators the potentially explosive area is limited in general by housings and/or sheathings, whereby a multiplicity of potential ignition sources can become effective due to construction, for example by rubbing and flapping sparks or by inadmissible heating.

A manufacturer of bucket elevators has to analyse all potential ignition sources (e.g. belts, buckets, angle wheels, drive units, regulating devices) and preventive measures according to design, transported material, transport speed etc. under the aspect of the intended use of the equipment.

The necessary level of protection of equipment and components inside the housing (e.g. category) depends on the frequency and the occurrence of the explosive atmosphere inside this housing.

According to the necessary level of safety, depending on their incorporation in the housing and the disturbances or equipment faults which have normally to be taken into account, some components (presenting a higher risk) might be assigned to categories different to the entire category of the bucket elevator.

If some ignition sources can not be avoided by the design of equipment or components, the manufacturer of the bucket elevator has to avoid the transmission of explosion to all the process.


Application of the directive 94/9/EC to Fork lifts trucks - revised version Fork lift trucks intended for use in potentially explosive atmospheres (revised version)

Fork lift trucks intended to be placed on the Community market for use in a potentially explosive atmosphere are considered assemblies (see chapter 3.7.5 of the Guidelines to ATEX Directive 94/9/EC). They must also, where relevant, comply with other applicable directives (e.g. Machinery 98/37/EC, Electromagnetic Compatibility 89/336/EEC).

A fork lift truck, which complies with all applicable directives, must be placed on the market by a single responsible person. More than one CE marking, EC-declaration of conformity, etc. makes it unclear who is responsible for the compliance of the final product and is not acceptable.

The responsible person must have the means to show that there is full compliance with all applicable directives, also those dealt with by possible subcontractors.

Selection of the conformity assessment procedures

The conformity assessment procedure according to directive 94/9/EC depends on the category of the product. In the all well-known cases explosion-proof fork-lift-trucks are to be assigned to the categories 2 or 3.

Fork lift trucks can be regarded for the selection of the conformity assessment procedure as combined equipment which if necessary contains a internal combustion engine, as well as different electrical and non electric devices.

Fork lift trucks category 2:

- Internal combustion engines and the electrical equipment must be submitted to the conformity assessment procedure in accordance with Art. 8.1 (b) i of the directive 94/9/EC; for both, the procedure of the EC conformity assessment procedure according to the Art. 8.1 (b) i is to be accomplished by an notified body in any case.

- The manufacturer has to ascertain that there are no additional ignition risks due to the combination of electrical equipment. This means for example a change of the temperature class. Usually the combination of components (EC Type Examination Certificate of components) does not fulfil these requirements.

- The combined equipment (fork-lift truck) is neither electrical equipment nor another internal combustion engine, therefore Art. 8.1 (b) ii of directive 94/9/EC applies to the conformity assessment procedure for the category 2: The manufacturer must use the internal production control in accordance with appendix VIII (including design and production) and deposit the technical documentation with a notified body in accordance with Art. 8.1 (b) ii ; the notified body has to confirm the receipt of these documents immediately.

Fork lift trucks category 3:

For category 3 the manufacturer must use the procedure of the internal production control in accordance with Annex VIII to Directive 94/9/EC.

All fork lift trucks categories:

In all categories, the manufacturer can choose to use the procedure of the EC individual examination according to Annex IX to Directive 94/9/EC.

Other directives applying

The manufacturer has to fulfil the requirements of all directives appropriate to his product. In particular, the manufacturer has to guarantee that the fork lift truck complies with the essential health and safety requirements of the Machinery Directive 98/37/EC in the case of conversion to an explosion proof fork lift truck.

EC declaration of Conformity

Preferably the manufacturer should draw up a conformity declaration which summarizes the conformity declarations for all directives applying. Alternatively the conformity declaration according to Directive 98/37/EC and/or EMC guideline can be issued separately.


Application of the ATEX Directive 94/9/EC to transportable, pressurised cabins ("modules") intended for use in hazardous areas

This Consideration Paper deals with the application of the ATEX Directive 94/9/EC to transportable pressurised cabins (or "modules"), as such goods are considered to be in-scope of 94/9/EC.

Cabin description

Such cabins are often intended for use in a Zone 1 or Zone 2 hazardous area and are used at both onshore and offshore sites (e.g. fixed drilling platforms). The cabins are pressurised with breathable air both to exclude ingress of flammable gas and to provide a safe atmosphere for operators to work inside the cabins.

The cabins are supplied to meet a variety of purposes, e.g. laboratory, control cabin, office or workshop. They are placed on the market in their finished state, ready for use, but "empty" - suitable for the customer to install and use their own equipment inside the cabin.

The design includes the incorporation of a number of ATEX-certified items, such as fire and gas detection systems, automatic shutdown systems and ventilation fans.

The design ensures positive pressure inside the module to prevent the ingress of flammable gas. As long as there is no internal source of release, this allows the enclosed area to be regarded as a non-hazardous area (reference, for example, UK Institute of Petroleum Code IP 15, section 6, 2002).

The cabin interior is often fitted with unprotected electrical fittings such as luminaires, switches and socket outlets. Should the cabin suffer a loss of pressure, these items have the potential to be exposed to an ingress of flammable gas which may form a potentially explosive atmosphere.

Therefore, the cabins are designed with many safety features to prevent this situation, such as smoke and gas detectors and alarms and the automatic shut down of non-certified electrical equipment being used inside the cabin.

Application of 94/9/EC

Where a manufacturer assembles and supplies a product which includes a number of ATEX-certified items (as is the case here), they are responsible for assuring that the process of design/ manufacture has not introduced any additional ignition sources or other relevant hazards and for having the assembly ATEX certified.

The ventilation system for these cabins should be viewed as a protection device, from the definitions in the directive. A pressurisation fan and a long length of ducting are incorporated, so that the fan can be deployed in a remote, safe area. Therefore, the safe operation of the pressurisation system also needs to be assured. The module itself forms the pressurised enclosure and must therefore be subject to conformity assessment, which would need to demonstrate the effective application of the pressurisation concept (including consideration of the safety integrity of the pressurisation control system) so as to meet the essential requirements of Directive 94/9/EC.

EN 50381:2004 ("Transportable ventilated rooms with or without an internal source of release") covers the essential health and safety requirements of 94/9/EC and applies to the cabins covered in this paper. "Ventilation" in this standard is used as a means of explosion protection. ("Ventilation" is also being used in these particular modules to ensure adequate air quality for personnel working inside. However, this aspect is out with the scope of the standard.)

An alternative route to compliance is for the manufacturer to demonstrate that the essential health and safety requirements of 94/9/EC have been met. This would include demonstrating the effective application of the pressurisation concept, including consideration of the safety integrity of the pressurisation control system.

It is stated in EN 50381:2004 that it is not the intention of this standard to cover stationary analyzer houses according to EN 61285:2004.

User's responsibilities

The installation of the cabin in accordance with the manufacturer's instructions is common to many ATEX products and shouldn't require further certification by/for the end user. The only circumstances when the end user would need to undertake ATEX conformity assessment under 94/9/EC would be if they made any changes which affected the explosion safety features of the product or if they needed to install it in a manner which was not in accordance with the manufacturer's instructions. These instructions should also state any limitations on the use of (non-protected) equipment inside the cabin.


Application of the ATEX Directive 94/9/EC to transportable, pressurised cabins ("modules") intended for use in hazardous areas

This Consideration Paper deals with the application of the ATEX Directive 94/9/EC to transportable pressurised cabins (or "modules"), as such goods are considered to be in-scope of 94/9/EC.

Cabin description

Such cabins are often intended for use in a Zone 1 or Zone 2 hazardous area and are used at both onshore and offshore sites (e.g. fixed drilling platforms). The cabins are pressurised with breathable air both to exclude ingress of flammable gas and to provide a safe atmosphere for operators to work inside the cabins.

The cabins are supplied to meet a variety of purposes, e.g. laboratory, control cabin, office or workshop. They are placed on the market in their finished state, ready for use, but "empty" - suitable for the customer to install and use their own equipment inside the cabin.

The design includes the incorporation of a number of ATEX-certified items, such as fire and gas detection systems, automatic shutdown systems and ventilation fans.

The design ensures positive pressure inside the module to prevent the ingress of flammable gas. As long as there is no internal source of release, this allows the enclosed area to be regarded as a non-hazardous area (reference, for example, UK Institute of Petroleum Code IP 15, section 6, 2002).

The cabin interior is often fitted with unprotected electrical fittings such as luminaires, switches and socket outlets. Should the cabin suffer a loss of pressure, these items have the potential to be exposed to an ingress of flammable gas which may form a potentially explosive atmosphere.

Therefore, the cabins are designed with many safety features to prevent this situation, such as smoke and gas detectors and alarms and the automatic shut down of non-certified electrical equipment being used inside the cabin.

Application of 94/9/EC

Where a manufacturer assembles and supplies a product which includes a number of ATEX-certified items (as is the case here), they are responsible for assuring that the process of design/ manufacture has not introduced any additional ignition sources or other relevant hazards and for having the assembly ATEX certified.

The ventilation system for these cabins should be viewed as a protection device, from the definitions in the directive. A pressurisation fan and a long length of ducting are incorporated, so that the fan can be deployed in a remote, safe area. Therefore, the safe operation of the pressurisation system also needs to be assured. The module itself forms the pressurised enclosure and must therefore be subject to conformity assessment, which would need to demonstrate the effective application of the pressurisation concept (including consideration of the safety integrity of the pressurisation control system) so as to meet the essential requirements of Directive 94/9/EC.

EN 50381:2004 ("Transportable ventilated rooms with or without an internal source of release") covers the essential health and safety requirements of 94/9/EC and applies to the cabins covered in this paper. "Ventilation" in this standard is used as a means of explosion protection. ("Ventilation" is also being used in these particular modules to ensure adequate air quality for personnel working inside. However, this aspect is out with the scope of the standard.)

An alternative route to compliance is for the manufacturer to demonstrate that the essential health and safety requirements of 94/9/EC have been met. This would include demonstrating the effective application of the pressurisation concept, including consideration of the safety integrity of the pressurisation control system.

It is stated in EN 50381:2004 that it is not the intention of this standard to cover stationary analyzer houses according to EN 61285:2004.

User's responsibilities

The installation of the cabin in accordance with the manufacturer's instructions is common to many ATEX products and shouldn't require further certification by/for the end user. The only circumstances when the end user would need to undertake ATEX conformity assessment under 94/9/EC would be if they made any changes which affected the explosion safety features of the product or if they needed to install it in a manner which was not in accordance with the manufacturer's instructions. These instructions should also state any limitations on the use of (non-protected) equipment inside the cabin.

 


Directive 94/9/EC: different categories within one product, or mixes of equipment and protective systems Which conformity assessment procedures have to be performed in the case of different categories within one product, or mixes of equipment and protective systems according to Article 1.3 b ?

If a product is made of parts which are assigned to different conformity assessment procedures it will be up to the manufacturer to decide how these parts and the whole product shall be placed on the market. The manufacturer can decide to realise the appropriate conformity assessment procedures for each part or for the whole product, even if he decides to place the product as an entity on the market. In the case of separate conformity assessment procedures for each part of the assembled equipment (called assembly in the Guidelines to Directive 94/9/EC), the manufacturer may presume conformity of these pieces of equipment and may restrict his own risk assessment of the assembly to those additional ignition and other hazards, which become relevant because of the final combination. If additional hazards are identified a further conformity assessment of the assembly regarding these additional risks is necessary.

If the manufacturer explicitly asks a Notified Body to assess the entire product, then that conformity assessment procedure has to be applied, which covers the highest requirements. The involved Notified Body shall include into the EC-type examination all aspects of the product. Existing conformity declarations of the manufacturer for parts of the product should be considered.

The Notified Body should inform the manufacturer about the possibilities of separate conformity assessment procedures for each part of the assembly as pointed out by the Guidelines to Directive 94/9/EC.

Any certificate issued by the Notified Body should make clear which aspects of the product have been assessed by the NB, and which have been assessed by the manufacturer alone.

Example: Vapour recovery pump for petrol stations

(a) The pump is sucking the petrol vapour-air mixture from the atmosphere and is conveying it in pipe-work attributed to zone 0. Accordingly it is connected at its inlet and outlet to a potentially explosive atmosphere classified as zone 0.
The pump itself is placed in a one 1 environment.
With regard to the inlet and outlet connection the pump then has to comply with the requirements for category 1 equipment. The corresponding EC-type examination (equipment) has to be carried out by a Notified Body.
With regard to the remaining (outer) body and integrated parts of the pump the Notified Body includes the necessary category 2 assessment into the certification, even if there are only non-electrical ignition sources to be considered.
Both categories shall be indicated in the EC-type examination certificate, making however clear which aspects of the product have been assessed by the NB, and which have been assessed by the manufacturer alone, and in the marking.
For those category 2 parts of the pump, which show only non-electrical ignition sources and which are placed separately on the market, and for which the technical documentation has been communicated to a Notified Body, an EC declaration of conformity (for equipment) or a written attestation of conformity ( for components) of the manufacturer are sufficient.

(b) Often the pump is expected to prevent the passage of a deflagration flame from the inlet to the outlet connection, as typical vapour recovery pumps contain flame arresters in the inlet and outlet pipe. In this case the pump simultaneously may qualify as protective system (in-line deflagration arrester).
A Notified Body - after having carried out a corresponding assessment of the flame arresting capability - may then issue a separate EC-type examination certificate for the pump as protective system.
In case that both aspects (equipment and protective system) have been assessed by the same Notified Body, only one EC-type examination certificate may be released.


Certificates and CE marking without the name of the original manufacturer

Case 1: Authorised Representative

The manufacturer applies for assessment and the certificate, if granted, is in the name of the manufacturer.

The EC declaration of conformity and the application of the CE marking may be effected either by the manufacturer or his authorised representative, but not by both. Required marking shall show the manufacturer's name and the number of the notified body involved in the manufacturer's production phase shall appear be placed after the CE marking.

Any person who is not an authorised representative is not allowed to issue an EC declaration of conformity or to apply the CE marking.

An authorised representative is assimilated with and regarded as an extension of the manufacturer's operation. The name of the manufacturer shall be on the rating plate.

Case 2: De facto Manufacturer

Any p

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