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Health & Safety Executive / Local Authorities Enforcement Liaison Committee


Local Authority Circular

Subject: Pressure Systems
Open Government Status: Open
Revised: September 2000

LAC Number: 66/8

Keywords: Gas Cylinders
Review date: September 2005

To: Directors of Environmental Health/ Chief Environmental Health Officers of London, Metropolitan, District and Unitary
Authorities and Chief Executives of County Councils.
For the attention of: Environmental Services / Trading Standards / Fire Authorities / Other
This circular gives advice to local authority enforcement officers


1 Enforcement officers will wish to be aware of these interpretations as supplementing existing
guidance so that a consistent approach to enforcement can be taken nationally.
2 References are to individual regulations and, where appropriate, the ACoP relating to those
3 The information is intended to give practical guidance to enforcement officers rather than to set
rigid standards to be followed in every case.
COMPETENT PERSONS (reg 2 definition)
4 A "competent person" legally cannot be an individual employee but can be an inhouse inspection
department within a user's or owner's company. The inhouse department can be staffed by just
one individual although larger complements are normal. Such departments must have a proper
degree of independence from the operating functions of the company. So, for example, individuals
within inhouse inspection departments who carry out functions in addition to their
competentperson duties, should be separately accountable under their job descriptions for those
competent person duties. Individuals should not be subject to commercial or financial
responsibilities which conflict with their competent person duties.
5 As regards the attributes of the person drawing up or certifying the written scheme there is no
need for that individual to be of chartered engineered status provided he/she acts under the
direction and supervision of a chartered engineer, or engineer of equivalent status.
MOBILE SYSTEM (reg 2 definition)
Application of the Regulations to rail tankers transporting LPG
6 The regulations will apply to tankers transporting LPG by rail and the tankers themselves would
be defined as "mobile systems".
PRESSURE SYSTEM (reg 2 definition)
7 The definition in reg2 has 3 clauses (a), (b) and (c) which should be read as alternatives.

Domestic LPG installations

8 The Regulations will apply to LPG tanks whilst they are being installed or filled because then there
is "use at work".
RELEVANT FLUID (reg 2 definition)
9 Hot water above 1100C is a relevant fluid.
10 Pressure systems operating between 1000C and 1100C should be considered by enforcement
officers under the regulations. Users should be asked for clear evidence that such systems do not
contain (and are not liable to contain) steam under foreseeable operating conditions and that the
temperature is not liable to exceed 1100C.
11 If evidence is not forthcoming, the advice of HSE specialists may be necessary if enforcement
action is contemplated (via the ELO).
Aqueous solutions
12 For an "aqueous solution" to be a relevant fluid the liquid must contain dissolved gases which
generate pressure above 0.5 bar by the evolution of the gas at either the actual temperature of the
liquid or 17.50C.
Methyl bromide
13 Methyl bromide used for fumigation is a relevant fluid and the regulations will apply when its
vapour pressure is greater than 0.5 bar above atmospheric pressure.
Distinction between "transportable gas container" and "mobile system"
14 Occasionally, enforcement officers may come across equipment which falls within the definition
of "transportable gas container" but could also be regarded as a "mobile pressure system" for the
purposes of the regulations. When considering these cases, enforcement officers should bear in
mind that:
the words "designed to be transportable for the purpose of refilling" have been interpreted by
HSE's solicitor to mean that the container so described should be designed so that it can be
removed from its appliance when it is empty and transported to another place where it can
be filled.
15 Advice may be obtained via the ELO in the normal way in cases of doubt.
Transportable cryogenic (deeply refrigerated) gas containers
16 These containers come within the definition of "transportable gas container" because:
(1) the containers are for a relevant fluid; and
(2) the containers are designed to be transported for the purposes of refilling. The
fact that they may occasionally be used for static storage is immaterial.
Chlorine drums

17 Chlorine drums in the UK are typically 864 kg and 1000 kg both of which have capacities below
3000 litres. The drums are of mild steel construction either rollerforgewelded or fusion welded.
The roll forged drums have inverted ends convex to pressure. There are two internal pipes with
external stop valves.
18 These chlorine drums should be treated as transportable gas containers and subject to the
positive approval requirements of part V of the regulations.
19 Providing that the vessel is marked in accordance with reg 5(4)) it is not necessary for the
marking to be readable at all times. If the plate is iced up or covered by insulation and needs to be
viewed then the ice or insulation should be removed. Furthermore, the supporting documentation for
the vessel should be available. If it is necessary for the information to be readable at all times, this
can be achieved by fixing the marking plate to a bracket which is proud of the vessel itself.
20 "Imminent danger" can only be declared by a competent person as a result of carrying out the
examination in accordance with the written scheme.
21 If the written scheme only applies to the plant when it is not in use then that would limit the extent
of reg 10. If the scheme of examination covers inservice examination then the competent person
need only declare imminent danger if it is discovered during the examination. At all other times, the
discovery of faults in the operational condition of the plant, whether considered to be of imminent
danger or not, comes within the scope of reg 12 on maintenance. In this situation, the competent
person or any other employee would need to comply with HSW Act s.7(b), which would require
cooperation so far as is necessary to enable the employer to comply with reg 12.
EXCEPTIONS (Schedule 2, Part 1)
Refrigeration systems (Exception 18)
22 Specification of safe operating limits for refrigeration plants should be in the form of maximum
and minimum coincident pressures and temperatures.
23 The minimum design temperature is an important design criteria which ensures that materials
selected to subzero use in refrigerating systems have the required fracture toughness properties at
their operating conditions to resist brittle fracture.
24 There is an exception from the regulations for any vapour compression refrigeration system
incorporating compressor drive motors (including standby motors) having a total installed power not
exceeding 25 kw. The exception would apply to separate systems intended to operate as integrated
units by means of electrical connections to one common controller only if the total power is below 24
Prime movers (Exception 20)
25 Exception 20 excludes prime movers from the regulations. The definition of "prime mover" at
section 176 of the Factories Act 1961 should be used in interpretation. By this route cylinders with
an integral piston or ram actuated by steam or compressed air are excepted from the regulations.
Fire extinguishers (Exception 24)
26 Exception 24 relates to portable fire extinguishers with a working pressure below 25 bar at 600C
and having a total mass not exceeding 23 kg.

27 The exception embraces halon fire extinguishers mounted within racing cars and operated
remotely by the driver in the event of an emergency.
Handheld tools (Exception 25)
28 Exception 25 only applies to parts of a handheld tool which are pressure vessels and not to the
tool itself.
29 The handheld lance of an oxyacetylene welding set is not a pressure vessel because it only
"contains" a relevant fluid in the sense of directing gases to the flame; there is no storage of gas.
30 The handheld lance should be considered part of a pressure system as "pipework to which a
transportable gas container is, or is intended to be connected".
ASSESSMENT OF INSPECTION ORGANISATIONS (including inhouse organisations)
31 Voluntary accreditation scheme for inspection bodies (see ACOP para 43).
32 The assessment is made by UKAS.
33 If enforcement officers doubt the competency of any inspection body they should consult the