The first deadline for the new PED: The CLP alignment

Colin Pimley – Technical Manager, Lloyd’s Register Verification

Inspection - PED revision logo - 306x172

The first deadline in the transition to the new Pressure Equipment Directive (2014/68/EU) is June 1st, 2015. Pressure equipment placed on the market on or after this date must use a new basis to determine whether the fluid  falls in Group 1 or not. The new basis is the Classification, Labelling & Packaging (CLP) Regulation No. 1272/2008, and it replaces the Directive 67/548/EEC. 

As we mentioned in our first article on the PED revisions, this is one of the two key drivers for revising the PED, and it will have the earliest impact on manufacturers.

In this article, we’ll take a closer look to provide you with an overview about how the basis works. Using this, you can verify whether your fluid or fluids will change from Group 1 to 2 or vice-versa under the new rules.

The fluid classification in the PED is critically important, as it is one of the key parameters which determine the ‘hazard category’ of the pressure equipment, and hence the conformity assessment requirements. While it is worth noting that the impact assessment conducted by the EU Commission concluded that the majority of substances would be unaffected, manufacturers have a duty to satisfy themselves and, in appropriate cases, their Notified Body, that the fluid classification is correct according to the new criteria.

The current process

gas cylindersThe current basis in the PED is in Article 9, which defines the overall process for determining the ‘hazard category’ of pressure equipment and requires the following inputs:

  • Type of equipment (vessel, steam generator, piping)
  • Design pressure (PS)
  • Volume and/or Nominal size (DN)
  • Fluid state (ie ‘liquid’ or ‘gas’)
  • Fluid group (1 or 2)

Users of the Lloyd’s Register PED Category Selection app will note these are the first inputs required in the app. Once these input parameters are known, the appropriate Table in Annex II can be identified and the hazard category determined, a feature the app does automatically based on those inputs. 

It is worth noting at this point that it is only the last bullet point that is affected by the CLP alignment; all other elements remain the same including the Hazard Tables.

To illustrate the current process for determining if a fluid is Group 1, we should remind ourselves of PED Article 9 (2.1);

Group 1 comprises dangerous fluids. A dangerous fluid is a substance or preparation covered by the definitions in Article 2(2) of Council Directive 67/548/EEC of 27 June 1967 on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances.

Group 1 comprises fluids defined as:

  • explosive
  • extremely flammable
  • highly flammable
  • flammable (where the maximum allowable temperature is above flashpoint)
  • very toxic
  • toxic
  • oxidizing

So how do we determine if a fluid falls under one of these groups?

The first step is to identify the basic hazard ‘symbol’ for each of the above and this comes from Section 2.2 of 67/548/EEC Annex VI as follows:

  • explosive  = ‘E’
  • extremely flammable  = ‘F+’
  • highly flammable  = ‘F’
  • flammable (where the maximum allowable temperature is above flash point)  = ‘R10’
  • very toxic  = ‘T+’
  • toxic  = ‘T’
  • oxidizing  = ‘O’

To illustrate how this works in practice let’s take a real example, carbon monoxide. From the Material Safety Data Sheet (MSDS) publicly available from a major gas manufacturer/supplier we see the following:

2014-PED CLP MSDS label

We can therefore see that this fluid is both extremely flammable and toxic, either of which make it PED Group 1. Note that it also carries the symbol ‘Repr. Cat 1’ meaning that it is toxic for reproductivity, but if it only carried this symbol, it would not be Group 1. This shows us that although a substance is classified as ‘dangerous’ under 67/548/EEC, it may not be considered dangerous under the PED Group 1 classification.

How does the new process work?

The new requirements are defined in Article 13 of the ‘new’ PED 2014/68/EU which states;

Classification of pressure equipment

1. Pressure equipment referred to in Article 4(1) shall be classified by category in accordance with Annex II, according to an ascending level of hazard.
For the purposes of such classification fluids shall be divided into the following two groups:
(a) group 1 consisting of substances and mixtures, as defined in points (7) and (8) of Article 2 of Regulation (EC) No 1272/2008, that are classified as hazardous in accordance with the following physical or health hazard classes laid down in Parts 2 and 3 of Annex I to that Regulation:
(i) unstable explosives or explosives of Divisions 1.1, 1.2, 1.3, 1.4 and 1.5;
(ii) flammable gases, category 1 and 2;
(iii) oxidising gases, category 1;
(iv) flammable liquids, category 1 and 2;
(v) flammable liquids, category 3 where the maximum allowable temperature is above the flashpoint;
(vi) flammable solids, category 1 and 2;
(vii) self-reactive substances and mixtures, type A to F;
(viii) pyrophoric liquids, category 1;
(ix) pyrophoric solids, category 1;
(x) substances and mixtures which in contact with water emit flammable gases, category 1, 2 and 3;
(xi) oxidising liquids, category 1, 2 and 3;
(xii) oxidising solids, category 1, 2 and 3;
(xiii) organic peroxides types A to F;
(xiv) acute oral toxicity, category 1 and 2;
(xv) acute dermal toxicity, category 1 and 2;
(xvi) acute inhalation toxicity, category 1, 2 and 3;
(xvii) specific target organ toxicity – single exposure, category 1.
Group 1 comprises also substances and mixtures contained in pressure equipment with a maximum allowable temperature TS which exceeds the flashpoint of the fluid;

As now, Group 2 is anything that is not Group 1.

The first thing we notice is that although there are now many more classifications listed compared to the current PED, we can still recognise that they fit into the same broad groups. For example, (i) corresponds to ‘explosive’, (iii) corresponds to ‘oxidising’, etc.  Therefore, basic types of substances considered by PED as Group 1 have not changed and the above list simply represents the best mapping to the new CLP criteria.

Of course we still have to understand how the new criteria work. The first step is to look at parts 2 & 3 of CLP Annex 1. In a similar way to how we identified the basic hazard ‘symbol’ for the current PED (e.g. explosive = ‘E’), we can identify the corresponding ‘hazard statements’ associated with each of the new categories. Here are some examples:

(i) unstable explosives or explosives of Divisions 1.1 – 1.5

Table 2.1.2  shows the following (blue highlights are our own);

CLP Table 2-1-2-02

  • Unstable explosive - H200 
  • Division 1.1 H201

(ii) flammable gases, Category 1 and 2

Table 2.2.2  shows the following;

CLP Table 2-2-2-02

  • Category 1 = H220
  • Category 2 = H221

So if we now look at the MSDS for carbon monoxide again we find the following CLP designation;

2014-PED CLP MSDS label_CO

We can thus confirm that this fluid remains as PED Group 1.

It is also worth noting that CLP Annex VII provides a ‘translation table’ from 67/548/EEC to CLP and shows the correspondences, where they exist. 

Other sources of information:

Lloyd’s Register Energy is continuing to examine the wording of the new PED to fully understand the implications for us as a PED Notified Body as well as for all economic operators. If you’d like to stay up to date on future articles about the changes and how they’re going affect the European pressure equipment market, register to receive updates here. For more information about getting your equipment PED certified, contact your local Lloyd’s Register office.

About the author:

Colin Pimley is the Technical Manager for Lloyd’s Register Verification, which is the entity within the LR Group that holds numerous Notified Body appointments including for PED. A Chartered Mechanical Engineer, he has worked in the pressure equipment field for over 30 years, initially as a design engineer, and subsequently moving into independent conformity assessment.  Representing LR on both the UK and European PED Notified Body groups, he is well placed to inform and guide not just LR, but also other stakeholders, through this important transition.