Vincote - Nl-Status Report On Behalf of VROM Inspectorate PDF

Group VINÇOTTE
Head office : Business Class Kantorenpark Jan Olieslagerslaan 35 1800 Vilvoorde Belgium
Tel +32 (0)2 674 57 11 Fax +32 (0)2 674 59 60 pressure@vincotte.be www.vincotte.com
Safety surveillance approach

during the construction of
complex industrial
installations
Status report on behalf of

VROM Inspectorate
by
Vinçotte
March 2009
Preface
Preface
This status report treats the surveillance of safety aspects when constructing
complex industrial installations and more specifically the surveillance of these aspects
when constructing LNG terminals.
First of all, we would like to thank our client, the inspection service of the VROM,
for assigning this mission to us, and the trust it puts in our company. Our gratitude is
more particularly extended to ir. Henk van der Veen and ing. Harrie Werkman for the
constructive meetings, the efficient cooperation, and many interesting discussions.
To clearly delineate the contents of this status report and to create a larger basis,
three meetings were organised (two in Breda, one in Vilvoorde), where, in addition to a
presentation on the topics treated in this status report, a forum was offered to discuss the
approach and contents of the report. We would therefore like to take this opportunity to
thank the participants to these meetings, namely Harrie Werkman, Rob Poelman and Henk
van der Veen of VROM-Inspectorate, Koos Bouwmeester of the province Groningen, Luc
Vijgen, Wim Been, Mahesh Soedesh and Marieke De Koning of DCMR, Edward Geus of the
RIVM, Guy Mariën of Gate terminal, Bert Wijker, Pieter Boerma, and Anton Tol of the
Minszw, Frank Lelieveld and Maarten Van Abeelen of the fire department Rotterdam-
Rijnmond, Danny De Baere and Frank Verschueren of the FOD WASO and last but not least
Herman Lens and Francis Leemans of Vinçotte Nederland, for the constructive and
interesting conversations and for the remarks sent in writing, which have made an
important and not to be underestimated contribution to this status report.
The contents of this report are based on the knowledge, competence, and
experience of our experts and engineers. Therefore, we would like to thank colleagues Fop
van der Bie, Kristof Van Bael, Guy Doms, Daniel Bruyland, Willy Wijns, André Weyn, Dirk
Wyffels, Patrick Zandbergen, Joseph Cremer, Ben Verhagen, Jan Liesmons, Raphaël
Termote, Bart Vanbever, Guy Jacques, Koen Chielens, Rudy Vanden Berghe, Tom
Cauwelier, Geert Boogaerts, Kristophe Van Immerseel and Jean Muls for the texts they
contributed and their presentations during the meetings. Writing these extensive and well-
supported texts within the time requirements made and parallel to our daily activities was
a task not to be underestimated. Our special thanks are therefore extended to Mrs. Livine
Dubois, who was capable of always efficiently managing the lay-out and the numerous
adaptations and corrections.
This report came to be within a limited amount of time and on a limited budget,
and was based on the experience and competence present within our company; therefore,
we are not averring that this report covers all conceivable aspects that may occur during
the construction of complex installations.
However, it is our hope that this document will constitute a significant addition to
augmenting safety of complex industrial installations and this by optimalizing surveillance
during construction of these installations. We are also convinced that by using our
experience and know-how, not only can adapted inspection plans be drafted, but the
quality of those inspections can be optimised.
We wish you much enjoyment reading this report. Remarks on it are, as ever,
most appreciated.
Vilvoorde, 20 March 2009

The Technical-Scientific Coordinators
Ir. Frédéric Dewint Prof. Dr. Ir. Marc Van Overmeire

Department Manager Pressure Equipment Chief Research Officer
AIB-Vincotte International
Business Class Park, Jan Olieslagerslaan, 35
B-1800 Vilvoorde
Belgium
www.vincotte.com
Report VROM-Inspectorate  Vinçotte

Safety surveillance approach during the construction of complex industrial installations
Table of Contents
0.0. Introduction: Problem Statement
Chapter 1 : Legal Restrictions Pertaining to the Construction of (Complex)

Industrial Installations
1.0. Contextualization of the European Legislation
1.1. European Legislation
1.1.1 The Pressure Equipment Directive

1.1.2 The Machinery Directive and the Work Equipment Directives
1.1.3 The ATEX-Directive
1.1.4 The Seveso-Directive
1.2. National Legislation
1.2.1 The Situation in Belgium

1.2.2 The Situation in The Netherlands
Chapter 2 : Relevant Aspects for the Integrity and Safety of the Installations
2.0. Introduction
2.1. Risk Analyses
2.2. Design of Pressure-Retaining Parts
2.3. Materials for Pressure-Retaining Parts
2.4. Non-Destructive Testing on Pressure-Retaining Parts
2.5. Electrical Installations
2.6. Concrete Structures
2.7. Metal Structures
2.8. Coating and Isolation
2.9. Fire Safety Industrial Installations
2.10. Control and Safety Control Circuits
Chapter 3 : Approach and Inspection Philosophy in the Context of the First

Extension of the LNG Terminal in Zeebrugge
Chapter 4 : Concerns and Start of an Inspection Plan
4.0. Introduction
4.1. Concerns
4.2. Start of an Inspection Program for Industrial Installations
Chapter 5 : Conclusions
Annex 1 : Bibliography (standards for fire safety)

Annex 2 : Used Abbreviations
Annex 3 : Materials - Examples

Table of Contents
Introduction : Problem Statement
0.0. Introduction: Problem Statement
Energy supply in Europe is mainly dependent on natural gas. This natural gas is
transported in gaseous condition via pipelines or in liquid condition in specially equipped
ships and then stored in LNG terminals. These terminals are buffers in case that, because
of conflicts (for example, the recent gas conflict between Russia and Ukraine), the gas
supplying is interrupted. Belgium has a lot of experience in storing liquid natural gas. The
first gas terminal in Zeebrugge dates from 1984, and recently there have also been a
number of important expansions.
Our company has actively, and in a number of domains, assisted in these projects as
expert, as External Service for Technical Control (EDTC), notified body and Authorized
Inspection Organization, with the mission of surveying the many aspects of constructing
this gas terminal.
In the Netherlands, gas terminals are also being built. The construction on the Gate
terminal has started in 2007 and it is hoped that the terminal is operational by 2011. It is
self-evident that in the Netherlands sufficient surveillance cannot be disposed with. The
VROM-Inspectorate, in cooperation with the other surveying bodies, investigates for this
reason how the surveillance during the construction of LNG-terminals in the Netherlands
has to be organised. In this investigation, attention needs to be devoted to the question
to what degree quality certificates of equipment, materials, and activities are to be tested
for correctness.
In this context, we were contacted by inspection services of the VROM to write a report
on the surveillance technique that has proven its usefulness in, among other projects,
the extension project of the LNG-terminal of Fluxys in Zeebrugge. The question of VROM
Inspection concerns in the first place the safety aspects that have to be checked during
the construction of such complex installations. Other aspects such as environment,
company security and worker health are treated where there is a relation to safety. Our
experience with controlling the construction of this type of installations teaches us that
the problems encountered are of an identical nature, independent of the specificity and
application area of the installations, which means that the extent of this study goes much
further than just solely LNG Terminals.
In mutual agreement, the following topics were withheld:
The legal requirements for building complex installations, such as LNG-Terminals, and
the inspection systems.
The most important topics relevant for the integrity and safety of the installations:
risk analysis, design of pressure-bearing parts, materials for pressure-bearing parts,
construction and non-destructive testing of pressure-bearing parts, electrical
installations, structures (concrete and metal), coating and isolation, control circuits
and safety control circuits.
A description of the approach and inspection philosophy in the context of the first
extension of the LNG Terminal in Zeebrugge.
The points meriting attention that we have established during our surveillance
activities such as: the (international) systematics of inspection certificates and the
explanation of ‘weaknesses’ in said systematics, the role and limitations of ISO 9001
certified quality systems in such projects, etc.
A start for a focused inspection plan, which could be a starting document for possible
inspections to be executed.
To treat this very broad domain, we called upon the age-old expertise of our employees.
For the subjects enumerated for this purpose, we asked our experts to mention, in
addition to the theoretical background, the most important points meriting attention,
based on our practical experience. You will find the names of the experts, who
participated actively on this report, in the preface. The finished texts were proofread by

0.1
Introduction : Problem Statement
our two coordinators, edited and grouped in a number of chapters. We will know give a
short survey of these chapters.
After an introductory paragraph which sketches the general context of European

legislation, Chapter 1 looks at the main directives that apply when building complex
industrial installations. The Machinery Directive, the Pressure Equipment Directive (PED),
the Atex-Directive, and the Seveso-Directive are discussed in sequence. In addition to
the European (economical) directives, there are also social directives that make demands
in addition to the minimal requirements. That is why both the actual Belgian legislation
and the Dutch legislation are discussed.
Chapter 2 takes a closer look at a number of technical aspects, and directs attention as
well to a number of shortcomings in surveillance and regulation. The following topics are
discussed in this order: risk analysis, design, materials, construction and inspection of
pressure-bearing parts, concrete and metal structures and their coating, electrical
installations, control and safety control circuits and, finally, fire safety.
The inspection philosophy our company used for the extension of the LNG terminal in
Zeebrugge is discussed in-depth in Chapter 3.
Finally, we have collected all the points meriting attention related to surveillance in
Chapter 4 and have also made a start with a proposal for an inspection plan.
In all this, it needs to be kept in mind that only topics were addressed for which our
company possessed sufficient experience and knowledge. Additionally, we certainly do
not claim completeness for the topics discussed, partially because of the fact that this
study had to be conducted within a limited time and with a limited budget.

0.2
Legal Restrictions Pertaining to the Construction of (Complex) Industrial Installations
CHAPTER 1 : LEGAL RESTRICTIONS PERTAINING TO THE CONSTRUCTION OF

(COMPLEX) INDUSTRIAL INSTALLATIONS
1.0. Contextualization of the European Legislation
1.0.0 Introduction
The purpose of this introductory part is to clarify the background and the purpose
of the European legislative acts underpinning the current regulations related to
the safety of workers and of industrial installations. Other important issues such
as the protection of the consumer or the protection of the environment are not
dealt with
This preliminary step is important because two different types of regulatory acts
do have a direct impact on the everyday life. A lot of time can be saved by
reducing the misunderstandings about the purpose and the interfaces of these
mandatory requirements.
Basically, we will identify two families of regulatory acts (European regulatory
acts are directives, decisions and regulations: the nature and the importance of
these documents is described in Appendix 1)
1.0.1 The regulatory acts related to the free movement of goods.
The regulatory acts based on article 95 of the Treaty (previously article 100A).
The idea is that "the Council shall […] adopt the measures for the approximation
of the provisions laid down by law, regulation or administrative action in Member
States which have as their object the establishment and functioning of the
internal market". Since the basic Idea is to promote the free movement of goods,
these directives are sometimes called "economic directives" (DG Enterprises at
Commission level). But most of these directives are also aimed at promoting the
health and safety of European workers and consumers.
Member States are responsible for ensuring the health and safety on their
territory of persons, in particular of workers and consumers and, where
appropriate, of domestic animals and goods, notably in relation to the risks
arising out of the use of machinery.
Whereas 3 of directive 2006/42/EC of the European Parliament and of the Council

of 17 May 2006 on machinery, and amending Directive 95/16/EC (recast).
The vast majority of the published documents are based on the principles of the
"New Approach". Since there are still several operational questions on some
issues, we will illustrate the background and the recent evolutions
1.0.2 The regulatory acts related to the protection of the workers at

work
These regulatory acts are based on article 137 of the Treaty (previously article
118A). This is a result of the Single European Act (1987). It was the first time
health and safety at work had been dealt with in operational provisions of the EC
Treaty. The idea is i.e. that the Community shall support and complement the
activities of the Member States in the field of "improvement in particular of the
working environment to protect workers health and safety". For these reasons
the related set of directives is sometimes called "social directives" (DG
Employment and Social Affairs at Commission level). One should nevertheless not

I.1
forget that there is also an economical dimension: one of the purposes is to limit
the possibilities of Member States to make social dumping.
Whereas health and safety are, without doubt, key ingredients in employment
quality, represent one of the Union's most important social policy areas and
comprise a major economic dimension.
Council resolution of 3 June 2002 on a new Community strategy on health and

safety at work.
Regulatory acts adopted under article 95 and Article 137 are complementary.
Directives under article 95 are mainly intended to ensure the placing on the
market of safe products and under article 137 they are intended to ensure the
healthy and safe use of the products at the workplace.
Most of the directives are developed within the scope of the framework directive
89/391/EEC1 as amended by 2007/30/EC2. From now we want to indicate the
effects of the "Better regulation" as illustrated by directive 2007/30/EC. The
issue is quite simple: the Member States have to report on the practical
implementation of 17 particular directives referring to the framework directive.
For historical reasons, the provisions on reporting are sometimes inconsistent in
terms of both frequency and content. This situation is pure waste of time and
money for the Member States and in addition to that it makes exploitation of the
results much more difficult at Commission level. It might be seen as a detail but
in the regulatory world as in our individual lives, the devil is often in the details.
We will elaborate further on this issue in the section dealing with the Regulatory
Impact Analysis.
1.0.3 The “New Approach”: a revolutionary measure requested by the

Industry in order to promote the free circulation of goods
a) The Evolution of the European Doctrine for Harmonizing Legal

Demands on Products
The very recent publication of the Package on Internal Market for goods (August
2008) is the culmination of a process where lessons were taken from the past in
order to improve the regulatory tools. As will be seen the main issues are related
to the improvement of the efficiency of the system as well as the clarification of
the role and duties of the different operators, including the public authorities.
The basics of the different steps will be highlighted hereafter. The trends of the
evolution are illustrated in figure 1.0.1.
Basically, it goes about a mutual learning process. Every regulation (or lack of
regulation) introduces specific incentives for the economic operators. Sometimes,
the foreseen effects do not happen. In the beginning of the eighties, when the
"New Approach" was designed, one of the fears was an excess of market
surveillance at national level. There were a lot of reasons to expect it, hidden
protectionism was not the less significant. Actually this did not happen and the
new idea is that market surveillance should not be "tolerated" but ""mandatory".
In the same context of surveillance of the market, another important issue is the
1 Council directive of 12 June 1989 on the introduction of measures to encourage improvements in

the safety and health of workers at work – OJ L183, 29.06.1989
2 Directive 2007/30/EC of the European Parliament and of the Council of 20 June 2007 amending
Council Directive 89/391/EEC, its individual Directives and Council Directives 83/477/EEC,
91/383/EEC, 92/29/EEC and 94/33/EC with a view to simplifying and rationalising the reports on
practical implementation – OJ L165, 27.06.2007

I.2
clear definition of the role and duties of the economic operators. The concepts of
"putting into service" or "putting on the market" was not legally defined. The
definitions of the importer and the identification of its duties are inconsistent
between the directives. As a result, it is possible for an operator to say to the
authorities that he fully agrees with the fact that the product X is dangerous but
that he cannot be held as responsible because the product was not yet sold (put
on the market) and/or because the manufacturer is somewhere in the world and
that it is up to the authorities to try to get in touch with him and to tell him that
he is accountable.
The many contacts with the different operators have taught us that it is of the
highest importance to know “why one does something” (does one have to do it?)
before one can know “how to do it”.
The structure of Europe has its very own logic. This logic is often different from
the logic that underlies our national customs. A first step is thus to gain insight in
the general framework, and integrate the European doctrine in our thought
pattern.
One of the main objects of this paragraph is therefore to stress the understanding
of the exact extent of new regulative concepts introduced into the European
Union. The implications of the CE-marking, the use of harmonized standards, the
role (and responsibility) of the Commission, the role (and responsibility) of the
Member States, the role of accreditation, … these are all themes that have to be
mastered.
FREE CIRCULATION OF GOODS THE IMPORTANT STEPS IN THE

DEFINITION OF THE DOCTRINE
2008 Specific duties of Specific duties of Demonstration Duty of
Package on the notified the economic of competence surveillance of
Internal Market bodies operators and impartiality the market
for Goods (operational) Designation of
notified bodies
2005 Simplify existing
Better regulation
Regulation Regulatory Impact
Assesment
1989 Conformity Demonstration
Global Assessment of competence
Approach Standards EN Accreditation
45000 Series Preferred way
1985 Total Harmonised
New Approach harmonization standards as
Political definition regulatory tool
of the fundamental (technical)
requirements Mandate given
by the
Commission
1969 Rules defined at
Harmonisation European level
of technical
regulations
National and Standardisation Conformity Manufacturers Accreditation National
European Bodies Assessment Importers bodies Authorities
Regulators Bodies Distributors
Figure 1.0.1
The problem is that people often have the annoying tendency of only
remembering information that they like to hear. We have seen several involved
parties (including member states) defend with nail and tooth strategies that were
in fact disadvantageous to them. When one considers then that these parties
often turn to the wrong person, then what happens in the best case is a
considerable waste of money and time. The European industry, however, cannot
let opportunities pass by anymore.

I.3
In thus mess or “creative disorganisation”, it is of the utmost importance to have

at one’s disposition whole networks of informal contacts that allow the transfer of
ideas on all levels of the hierarchy and influence the development of compromises
reached by the Member States3.
To give an acceptable answer to the questions every one of us will ask ourselves,
it is important to create a guideline, to familiarize ourselves with a doctrine of
which all elements can be replaced in their context. One of the best means to
achieve this, is undoubtedly knowing how this doctrine has been conceived. It is
our intention to capture in a few words the success and the setbacks that have
made the European (Economic) Community to create the communal legislation
we are dealing with right now, even if we do not know it yet.
b) By Removing Technical Limitations Create an Instability that Creates

Opportunities
Program developed by the European Community for the build-up of the internal
market was certainly the most ambitious economic change planned in peacetime.
In fact, it was to be superseded later on by the opening of Eastern Europe in
1989/90.
In fact, Europe was out of options. The famous Cecchini-report, that was
published in 1988, is not named “The Advantages of Europe” but “The Costs of
Non-Europe”.
“We have to take our chances as they present themselves”, opportunists declare.
“We have to create the chances to succeed”, strategists say.
The opportunists are wrong.
H. Daems
c) A European Doctrine Built in Five Steps
As we have seen above, for the moment Europe is formed on the basis of a
doctrine that has strongly evolved since the signing of the Treaty in 1957. Five
steps can be distinguished. The first three correspond to a Council Resolution.
The fourth is a general philosophy (better regulation). The last and very
important step (August 2008) is based on a European regulation4 and a European
decision5.
Every one of these steps is a step ahead: always lessons are drawn from the
practical problems revealed during a previous step. Behind the technical terms we
see a thorough redistribution of responsibility and of regulatory obligations. After
describing each step we draft an operational balance: roles of the different
players, advantages and disadvantages of the existing structure.
We draw the reader’s attention to an important point. The redistribution of roles

has a considerable influence on the behaviour of the different economic
3 Ch. D DE FOULOY - "Guide pratique des lobbyistes européens" - European study service – 1994.
4 REGULATION (EC) No 765/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 9 July 2008 setting out the requirements for accreditation and market surveillance relating to the
marketing of products and repealing Regulation (EEC) No 339/93
5 DECISION No 768/2008/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
of 9 July 2008 on a common framework for the marketing of products, and repealing Council Decision
93/465/EEC

I.4
operators, whether they are the industry or the government or the accreditation-
institutions.
Starting Point: National Standards and Regulations
The Treaty of Rome gave an impulse to the internal market within the Community
by removing the two most constraining types of barriers of those days: customs’
rights and the import quota. Since then, a number of very founded concerns,
such as health protection, have pushed the Member States to impose a number of
technical requirements, that each constitute a technical limitation of free trade.
The community mechanisms dating from 1957 soon proved to be incapable of
handling with this evolution.
Usually, three kinds of technical limitations are distinguished:

• The first come into existence by the differences that exist between
national industrial standards (NBN, NEN, DIN, BSI, …), for which
compliance has an influence on the import, sale, or use of a product. The
limitations that these standards can impose on free trade can be very
subtle. Thus, it can happen that an insurance company only agrees to pay
damages caused by construction materials if those materials were certified
in accordance with a national standard.
• Other limitations are created by the differences between national
regulations. Here the limitations are not subtle at all anymore, regulations
have the force of law.
• A third kind of limitations is caused by the testing and certification
procedures that guarantee conformity of a product with national rules or
industrial rules. Free trade is limited every time the importing country
requires a certification in addition to the one given in the country of origin;
from this follow extra costs and slowdowns, that are well-known in a
sector such a pharmaceutical products.
Since originally provided community mechanisms have not lessened or prevented

those technical limitations, there have to be some good reasons why these
limitations happen. In fact, there are three kinds of reasons:
• Differences relating to the means that have to be applied to protect public

health, safety, or the environment. One could speak here of “cultural”
differences that are very normal between, for example, Scandinavian
countries and the Mediterranean. The implications of those differences are
not negligible, especially because they can touch the fundamental values
of individuals. And individuals are often prepared to devote a great
amount of energy to defend their fundamental values.
A classical example in this area is the judgement of the amount of trust

one can put into an operator of a machine to ensure one’s own safety.
That degree of trust can vary depending on the average education level
and the appraisal of human behaviour. Consequently, some countries
opine that the safety of machines can be partially ensured by calling upon
the responsibility of employees, whereas others will demand that security
is ensured in a constructive way by an intrinsic safeguard against any
carelessness, no matter how big. Thus, two different views on man lead to
two different views on machines. For free circulation of goods, however, it
is exactly the point that every machine is considered safe in every corner
of Europe. Therefore, a compromise will have to be found.

I.5
• Different traditions of standardisation, testing, and certification. We all

know the great force of deep-rooted habits. The force of habit can cause
economic operators to behave defensively towards products that comply
with criteria they do not know. It has become clear, by the way, that
differences between national standards are a reflection of a different
degree or a different rate of industrialization.
• But also, often hidden beneath the reasons mentioned above, there is the
will to protect the interests of the national manufacturers, or even a whole
industrial sector that is considered of strategic importance, despite the
European treaties.
The Players
• The national competent authorities (Ministry branch): establishes the

regulations, monitors its correct application, provides the interpretation for
the texts.
• Recognised bodies: appointed by local authorities to fulfil certain technical
tasks related to inspection and/or testing.
In case of standardization, the structure is very similar: there is a national organ

(NBN in Belgium) that delegates certain certification tasks to sector-bound
organs.
Evaluation
We are dealing with co-existent, independent regulating systems. The

disadvantages are well-known, the candidate-executor has to go through a
difficult process and present his product for approval to demands that are not
necessarily reconcilable. In practice, this can cause costs for filing, costs for
translation, for tests, for alteration of products, for supplies because of the
necessity of different “national” versions of the same model …
Yet the decision structure is simple if we do not consider the marginal cases of
direct lobbying at political institutions. That structure can be found in the
schematic below. (Figure 1.0.2)
COMPETENT AUTHORITY
MANUFACTURER RECOGNISED BODY
USER
Figure 1.0.2
In such a system the manufacturer, should he have questions, can directly

contact the responsible authorities, that are often fully qualified to make a
decision. That decision may be pleasing or not, but there is little legal insecurity if
the manufacturer abides by it.

I.6
First Step of the Harmonization: the Extrapolation of National Systems
1969 : harmonization of technical regulation
Basic Idea
The Member States have a technical regulation. Creating a harmonized European

regulation will solve the problems “other than tariff barriers”. The idea is that the
validity of attestations and certificates of compliance given by the responsible
authorities, given only under their responsibility and name, are recognized.
The Players
• Competent authority (Ministry branch): issues the certificates (and

withdraws them), maintains contacts with the other Member States. Is
responsible for the proper interpretation of the texts.
• Technical service: the laboratory that issues the testing report upon which
the certificate of the Ministry is based. Very promptly, and also for obvious
practical reasons, this function was expanded to an inspection function:
interpretation and follow-up of tests at the manufacturers.
Later (1992), the function also included the auditing of quality control
systems, designed to ensure the legal conformity of production.
Evaluation
This first step of the harmonization is today called the “old approach”. It is the
conversion on the community level of the system hitherto applied to national
levels. We have to keep in mind that these directives have led to a first important
redistribution of roles.
• Regulatory texts are drafted on a community level and no longer on the

level of the Member State.
• Since the 1970s, manufacturers can, where these directives exist, fulfil the
basic purpose of the free circulation of goods. No matter where he is
established in the world, any constructor can certify his product in any
country of the European Communities and that certificate is valid in all
countries belonging to said Communities.
Some of the directives applied, for example those related to toxic substances,
cosmetics, or additives for foodstuffs, are binding for everyone. Others, for
example in the automotive sector, were optional for the manufacturers, who
could choose to obey either national regulations or European directives. In the
second case, all national governments were forced to accept the European
certificates presented by the constructor.
This system works well, but has the major disadvantage that it is bulky, and thus
very slow.
These days, this old approach remains to be applicable for an economic sector of
the highest importance to the European industry: the car industry. Since 1992,
principles were slightly altered by some adaptations inspired by the rules of the
new approach: mandatory and no longer optional application; Monitoring of
conformity of production, …

I.7
Today, we see another type of evolution. The automotive market is not European
but worldwide and the applicable regulation becomes more and more
international (based on the Geneva Agreement (United Nations)). This is a basic
request from the big industry: they do not want to sell at European level but
worldwide. This can have positive results: due to scale effects, the higher level of
requirement set on safety and environment can be brought without increase of
the cost at consumer level.
When I hear somebody sigh, "life is hard", I am always tempted to ask,

"Compared to what ?"
Sidney Harris
Second Step of the Harmonization: the New Approach
1985 : harmonization of technical regulations
+ the use of standards
Although the Council Resolution dealing with a new approach is already more
than twenty years old, it proposes a coherent whole of changes of which
economic operators do not always perceive the practical consequences. This topic
is important, and we go further into it in paragraph 1.0.4.
Basic Ideas
The harmonization of the technical regulations lead to a very bulky and thus very
slow and expensive approach, with very detailed technical attachments.
Furthermore, governments do not always have technical specialists at their
disposal. The two aspects of the technical regulation are thus kept apart.
• Political side reserved for regulation (the government): the objectives

which need to be achieved (for example necessity of a specific type of
protection, safety coefficient, tolerable sound levels, …)
• Technical aspect reserved for standardisation (private sector): means to
achieve those targets. Actually, the New Approach is a limited form of co-
regulation, one of the tools proposed under the European "Better
Regulation" mantra.
The legislative role is clearly defined: it goes about

• Setting objectives
• Ensuring compliance
• Protecting the public interest
• Guaranteeing accountability (this was not successful)
There is no de legation of legal responsibility

I.8
CAVEAT
- Consultation is not a substitute for democracy
- Institutional balance must be respected
- Legislation must guarantee procedures
- Representation must be transparent
- Access to results must be guaranteed6
The operators involved
• Competent authorities: are mainly responsible for appointing the notified

bodies. Have to be kept informed of critical situations (withdrawal of
certificates, refusal to issue a certificate, …)
• Notified Body: is responsible for all operational aspects, from issuing a

certificate of EC-type examination and dispatching certificates to the other
bodies. It can also be responsible for following-up production and/or “full
quality assurance” modules.
• Standardization organizations: this period has been a golden age for

European standardization organizations (CEN and CENELEC) whose
activities were merely confidential up to that time.
Evaluation
The new approach has added several dimensions to the simple decision structure
we showed in Figure 1.0.2. The rise in the number of intervening parties has
necessitated the creation of several coordination structures. These structures are
furthermore explicitly described in the texts of the new approach. The general
schematic can be presented as follows.
6 Enterprise Seminar 11 February 2003 – The future of the New Approach : Quo Vadis ?- Anne
Wilkinson - Brussels

I.9
Court of Justice - Strasbourg
Commission Member States
Working Group
Coordination of notified bodies
Standardization bodies CEN/CENELEC/ETSI
Manufacturer Notified bodies
User
Figure 1.0.3
From Figure 1.0.3, it becomes quickly clear that this structure can lead to a
game of complex interaction between the different players. These interactions can
become even more complex as a consequence of the interaction between
different directives applicable to the same group of products.
Another difficulty comes from the implicit need for a consensus, due to diverging
positions taken for historical reasons, it appears to be almost impossible to reach
a common position on some critical questions.
In a decision process, complex interactions often lead to contradictory points of

view. The manufacturer who wants to know what to do to have his product
comply with regulations, sometimes has difficulties seeing clearly through all this.
In an age of information, we establish with regret that whoever wants to put a

product on the market sometimes has difficulties to find a straight answer to a
question such as “Where do I begin?”. However, different valuable source of
information exist. We will explore them further in the chapter on the “official”
sources of information.
Third Step of the Harmonization: the Global Approach
harmonization of technical regulation
+ use of standards
+ validation of the conformity assessment
The “Global Approach” supplements and expands the principles of the “New
approach”.

I.10
Basic Ideas
With the new approach a doctrine is introduced to demonstrate the compliance

with regulatory requirements. That doctrine guarantees flexibility of the economic
operators. But guarantees remain to be given to the users. This implies that the
competence of manufacturers and third parties can be ensured. As with technical
regulations, there are two different aspects.
• Political aspect: the competent authorities notify the Commission (and

thus the other Member States) which body they have chosen to fulfil a
particular task. The word “notification” was chosen because sounds more
official than the word “designation”. The authorities can only notify bodies
for which it can demonstrate the competence. This element is treated
more thoroughly later on.
• Technical aspect: the competence of these bodies has to be assessed on

the basis of objective criteria and not on the aura of respectability
conferred to them by the approval of public authorities.. Just as there are
essential requirements for products, there are also essential requirements
for notified bodies. These requirements are defined in the annex to the
“new approach directives.. For a body complying to the EN ISO CEI 17000
(before EN 45000) series is identical to a presumption of conformity to the
requirements made in the annexes mentioned above. That condition is
insufficient, since the technical competence for the scope covered by the
relevant directives also has to be shown.
It was supposed that accreditation is an excellent means to display

competence. The Commission could not impose them in every Member
State (some “hesitate” very consciously) but strongly stresses the
principle. In many cases, accreditation bodies simply do not have a clue
how they should handle the issue. And Europe cannot function without
notified bodies.
The operators
• Competent authorities: their role is very similar to what was described

above. It needs to be pointed out, however, that they are obliged to bear
responsibility for the competence of the bodies they notify. Other
economic or political operators can not only dispute the validity of the
certificates but also the competence of the bodies.
• Notified body: its role and obligations are expanded upon.
• Accreditation bodies : being the top level of conformity assessment in the

Member States, the accreditation bodies are strongly empowered in order
to bring objective evidence of the competence of the conformity
assessment bodies.

I.11
Better Regulation : back to the basics – cutting the red tape
Figure 1.0.4 Cutting the red tape
We will not elaborate too much on this general issue but it is important to know
some of the background elements.
In 2005, the Commission wanted to reinforce its political ownership as well as the
overall coherence of the strategic political EU agenda. The Commisions then
launched a "better regulation project" with the aims to improve the quality of
new legislation, and update many existing rules to make them clearer. To that
end it is therefore:
• Withdrawing a number of pending legislative proposals. In fact, as
of March 2006, the Commission had withdrawn 67 legislative proposals
after screening 183 potential new laws that were pending ratification by
the Council and European Parliament.
• Implementing a strategy to simplify existing legislation
• Tackling the issue of administrative burdens, attacking "red tape" at EU

level (and stimulating such attacks at Member States level)
• Placing greater emphasis on the use of impact assessments and public

consultations when drafting new rules and regulations. The aim is to
assess how new legal measures could help or hinder the function of
Europe’s enterprises.
Basically, the issue is not deregulation but "smart regulation". To reduce the
height of the wall of the "acquis communautaire" is certainly a good thing
provided it is made according to transparent and proven methodology. One of the
difficulties is rased by statements made at the simplistic level of slogan-politics
and shallow journalism.

I.12
Proposals must be prepared on the basis of an effective analysis of whether it is

appropriate to intervene at EU level and whether regulatory intervention is
needed. If so, the analysis must also assess the potential economic, social and
environmental impact
White Paper on European Governance, 2001, COM (2001)428
Impact Assessment is or should be a key element in this revamping process. One

if the basic idea is to clearly define the problem to be solved and to carefully
analyse the alternatives to a new regulation.
There are three kinds of alternatives

- Status quo or baseline option. It is, for instance, stated that "The option of
‘no EU action’ should always be considered, except in cases where there is an
obligation to act laid down by the Treaties"7
- Alternative incentives : regulations are nothing more than incentive
instruments. Many incentives are possible. Are self-regulation or co-regulation
feasible options ? Could the same objective be met by securing a voluntary
agreement ? Is an information and education campaign sufficient ?
- More efficient regulatory design : once basic incentives are selected, the
design of regulation has enormous effect on the impact. The Commission has
invested a lot of energy in the strealining or simplification of existing
regulation (including codification of existing regulations).
Common regulatory problems : a web of systemic governance issues
√ Complexity and inconsistency

- Policy fragmentation, lack of coordination
- Confusion on the role of regulation in modern society
- Poor regulatory implementation capacities
- Inconsistent decisions and signals to the private sector
√ Good regulation can become bad regulation over time
- Immortality of regulations
- Technological change
- Social needs
Scott Jacobs – "Smart regulation for markets : The vision of regulatory

reform" – Regulatory Impact Analysis Training Course – College of Europe,
Brugge Campus – 10-14 March 2008
7 European Commission – Impact Assessment Guidelines – SEC(2005)791 – Edition 15 June 2005

with March 2006 update

I.13
1.0.4 The Internal Market Package for Goods : revamping the New
Approach
a) The New Legislative Framework (NLF) : modernisation of the New

Approach for marketing of products - published in the OJEU on 13
August 2008
The set of Regulatory acts published in the OJEU of 13 August 2008 is the result
of four years of high level and intensive discussions between the Commission, the
stakeholders, the European Parliament and the Council.
Basically, there are four objectives
- To consolidate the key concepts of the New Approach policy;
- To improve the evaluation and monitoring of conformity assessment bodies

(testing, certification and inspection laboratories) including the increased use
of accreditation
- To strengthen market surveillance
- It is expected that the credibility of the CE marking will be enhanced
The references of the regulatory acts are as follows (Regulation 764/2008 is quite
specific and will not be discussed later in this text)
- REGULATION (EC) No 765/2008 OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL of 9 July 2008 setting out the requirements for accreditation and
market surveillance relating to the marketing of products and repealing
Regulation (EEC) No 339/93
- DECISION No 768/2008/EC OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 9 July 2008 on a common framework for the marketing of
products, and repealing Council Decision 93/465/EEC
- REGULATION (EC) No 764/2008 OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 9 July 2008 laying down procedures relating to the application of
certain national technical rules to products lawfully marketed in another MS
and repealing Decision No 3052/95/EC
b) The Regulation on marketing of products will be applicable as from 1

January 2010
- It is binding in its entirety and directly applicable in all Member States
- It sets out the requirements for accreditation and market surveillance relating
to the marketing of products.
One of the great challenges induced by the Regulation is the duty of surveillance
of the market by the Member States.
- Member States shall identify the responsible authorities
- Member States shall establish and make publicly available surveillance
programs.
- The Commission shall develop and maintain a general archiving and exchange
of information system.

I.14
- Control of products entering the Community market (includes repeal of

Regulation 339/93/EEC).
- There is a black sheep in every flock. (Figure 1.0.5)
Figure 1.0.5 Where’s the black sheep ?

(acknowledgements to Edouard Cornelis)
c) The Decision on a common framework for the marketing of products

is addressed to the European regulators.
To be operational it needs to be fed into existing Directives when they are

revised. Two sectorial directives are currently under revision and will be aligned
with the decision (as much as possible)
- The toys directive
- The construction product directive (intended to become a regulation)
The Decision is a tool for the Commission’s Better Regulation policy. The rationale
is to ensure more consistency of the legal environment and to establish a
common “culture” of legislating. The identified inconsistencies: (different
terminology, different logic behind obligations of economic operators, duplication
of procedures,..) make it difficult and more expensive for economic operators to
comply with the legal requirements. On the other hand it should be kept in mind
that European regulatory acts are well implemented and that the improvements
induced by harmonisation can be out weighted by the (administrative) cost
induced by the requested changes.
1.0.5 The So-Called Social Directives – The Other Side of Safety
The directives “free circulation of goods” are but one of the aspects of the
growing Europe. The Single Act created new clear social responsibilities on a
European level.
Article 153 (previously article 137 and previously article 118A) gives the Council
the authority to adopt social directives. Apart from safety and health on the
workplace, those “social” directives mostly involve various aspects, from the free

I.15
circulation of workers to the equal treatment of men and women. Initially, the
tendency was to put the focus on safety and health in a narrow sense.8
Without further details, we point to the importance of the executive directive that
is aimed at the promotion of the amelioration of safety and health of workers.9
That framework directive is followed by several individual directives, of which we
have already introduced some.
Of particular interest here are the first three directives, with requirements for
workplaces, for the use of work equipment and for the personal protective
equipments.
A practical example can be found in the machine directive in which a number of

requirements are set out for machines that are put on the market. The “social”
directive on work equipment defines, among other things, the requirements that
apply to the existing equipment. Those requirements apply since January 1st,
1997.
That directive of 1989 was far from complete, and the Commission proposed an
amendment that introduced a significant number of changes.
For the technical side of things, we find an expansion of the minimum

requirements for specific work equipment such as woodworking machines,
presses, mobile work equipment, lifting devices and – accessories, scaffolds, …
Another change is in the obligation imposed on the employer to draft or have

another party draft a plan for the control of work equipment, dependent
upon the planned utilization and taking into account possible indications of
manufacturers. That plan has to make it possible that the employer sufficiently
complies with obligations defined in the directive.
- Make sure that the means of labour, the safety of which is dependent upon
installation conditions, are subject to a first inspection (after the installation
and before the first utilization) and an inspection after every installation on a
different location, to ensure that these work equipment have been correctly
installed and are working properly.
- Make sure that the work equipment that can cause dangerous situations when
damaged are subject to regular and exceptional inspections (after exceptional
events that might lead to dangerous situations).
The practical impact of this obligation to draft a plan for the inspection of the
work equipment is dependent upon its transposition to national law.
One of the new missions that the recognised bodies in Belgium have developed is
to help companies to put their machinery in order as determined in this directive.
Even more than before, everything will be a matter of accountability. In this the
employer will see the added value.
8 E. Vogel-Polsky en J. Vogel, "Het sociale Europa 1993: illusie, alibi of realiteit?", Uitgaven van
de Universiteit van Brussel, 1991
9 Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to encourage
improvements in the safety and health of workers at work O.J.. nr 183, 29-06-89

I.16
There are a great number of individual directives
- Council Directive 89/654/EEC of 30 November 1989 concerning the minimum safety and health
requirements for the workplace
- Council Directive 89/655/EEC of 30 November 1989 concerning the minimum safety and health
requirements for the use of work equipment by workers at work
- Council Directive 89/656/EEC of 30 November 1989 concerning the minimum health and safety
requirements for the use by workers of personal protective equipment at the workplace
- Council Directive 90/269/EEC of 29 May 1990 concerning the minimum health and safety
requirements for the manual handling of loads where there is a risk particularly of back injury
to workers
- Council Directive 90/270/EEC of 29 May 1990 concerning the minimum safety and health
requirements for work with display screen equipment
- Council Directive 92/57/EEC of 24 June 1992 concerning the implementation of minimum safety
and temporary or mobile construction sites
- Council Directive 92/58/EEC of 24 June 1992 concerning the minimum requirements for the
provision of safety and/or health signs at work
- Council Directive 92/85/EEC of 19 October 1992 on the introduction of measures to encourage
improvements in the safety and health at work of pregnant workers and workers who have
recently given birth or are breastfeeding
- Council Directive 92/91/EEC of 3 November 1992 concerning the minimum requirements for
improving the safety and health protection of workers in the mineral-extracting industries
through drilling
- Council Directive 92/104/EEC of 3 December 1992 on the minimum requirements for improving
the safety and health protection of workers in surface and underground mineral-extracting
industries
- Council Directive 93/103/EC of 23 November 1993 concerning the minimum safety and health
requirements for work on board fishing vessels
- Council Directive 98/24/EC of 7 April 1998 concerning the protection of the health and safety of
workers from the risks related to chemical agents at work
- Directive 1999/92/EC of the European Parliament and of the Council of 16 December 1999 on
minimum requirements for improving the safety and health protection of workers potentially at
risk from explosive atmospheres
- Directive 2002/44/EC of the European Parliament and of the Council of 25 June 2002 on the
minimum health and safety requirements regarding the exposure of workers to the risks arising
from physical agents (vibration)
- Directive 2003/10/EC of the European Parliament and of the Council of 6 February 2003 on the
from physical agents (noise)
- Directive 2004/40/EC of the European Parliament and of the Council of 29 April 2004 on the
from physical agents (electromagnetic fields)
- Directive 2006/25/EC of the European Parliament and of the Council of 5 April 2006 on the
minimum health and safety requirements regarding the exposure of workers to risks arising from
physical agents (artificial optical radiation).

I.17
1.1. European Legislation
1.1.1 The Pressure Equipment Directive
a) The European Pressure Equipment Directive 97/23/EC
The “Pressure Equipment Directive”, henceforth called PED, is, together with the other
European Directives, a part of the unification process of Europe.
The PED is mandatory for vessels, pipes, steam generators, appendages, safety
appendages, and assemblies with a maximum operating pressure above 0.5 barg
that are put for the first time on the European market (one or more member states). The
directive is mandatory since May 29, 2002.
Despite many exceptions, more pressure equipment than ever before are subject to the
requirements of this directive
The most important exceptions are those subject to other European Directives or to other
national, regulations.
The PED is an economic Directive, founded on Art. 100 of the Treaty of Rome, in
opposition to the social directives founded on article 118 of the same Treaty of
Rome.
Economic Directives are addressed to manufacturers and applicable on products that
these manufacturers put on the European market for the first time.
Economic Directives introduce fundamental requirements of safety, health, and
environment.
Social Directives, on the other hand, are addressed to employers and owner/users of
installations and contain requirements concerning the safety and well-being of workers,
such as the Directive for work equipment 89/655/EEG.
In opposition to the economic directives, the social directives are not (yet) or not
completely transferred to the national legislations of the different member states.
This may give a strange feeling, as if “safety” is less important than economic interests.
Economic Directives have the purpose of guaranteeing the free circulation of goods
within the unified European market by eliminating all possible obstacles to this in the
process. For example, when the Directive for pressure equipment was implemented, the
member states were forced to withdraw their own national regulation related to pressure
equipment, so that, among other results, all national legal and regulatory obstacles were
removed in favour of the Directive.
The Directive thus guarantees the free circulation of goods within the unified European
market, independent of the origin of the equipment, and as far as the requirements of
the Directive are respected.
The first concepts that were adopted during the unification of the regulation for pressure
equipment, namely the fine-tuning of a European design and manufacturing standard
with very detailed technical contents, eventually led to nothing due to years of arguing
back and forth, an argument not at all devoid of chauvinism, between the member states
of that time. Because each one of these member states wanted to see its own vision on
safety and attendant regulation transposed to a European level.
These negative experiences, but also the rise of quality control and quality assurance
techniques and especially of the ISO 9000 and the EN 45000 standards, combined with
an ever stronger drive for unification, generated a new concept, one that was called the
“new and global approach”.
Thus, the European Directive for pressure equipment is a “new approach” Directive,
just like the Machinery Directive and the ATEX-Directive.
New approach Directives have some very specific characteristics, of which the most
important one are its essential health and safety requirements. These are crucial safety
Report VROM- Inspectorate  Vinçotte

I.18
requirements that mandatory have to be taken into account in the design and
manufacture of the pressure equipment insofar as the corresponding risk exist when the
equipment is used in reasonable conditions as expected by its manufacturer. To clarify
this, it is important to know that the Directives of the new approach are not only
concerned by safety, but also by health and environmental aspects of individuals, and
even of pets or goods.
The necessity for the manufacturer to care about “the reasonable conditions of use”
immediately introduces a second specific characteristic, one inherent to the Directives of
the new approach, namely the obligation to conduct a risk analysis to find out which
hazards exist on account of pressure.
He should than take into account the result of his analysis in the design and manufacture
of the equipment.
Thus, these directives are regularly called “risk-related directives”.
Conducting a risk analysis is not self-evident, certainly not for the classical equipment
manufacturers who have never gotten used to it. Furthermore, a manufacturer does not
always have all necessary data basic design information, or transients etc. of the
equipment at his disposal, and thus he will not always be able to cover all aspects.
The essential requirements are structured like most design and construction codes
and standards, and therefore start by stating generalities. Further on, aspects such as
design, materials, fabrication, inspection and tests are treated in independent
paragraphs. The essential requirements, however, do not give any technical
specifications for the design or manufacture of a pressure equipment.
They are expressed in very general terms that do not always facilitate their
understanding and application by manufacturers and other users.
Thus, the Directive prescribes:

- Pressure equipment must be designed in the correct manner, taking into account all
relevant factors to guarantee that the equipment is safe during its whole lifespan…
This implies, among other things, that for every pressure device the lifespan has to be
determined.
And what could constitute a relevant factor here…?
And moreover:
- In case the hydrostatic pressure test is harmful or impossible, other tests with a
recognized value can be carried out. For other tests than the hydrostatic pressure
test, additional measures such as non-destructive tests s or other equivalent methods
have to be taken before these tests are carried out.
One could wonder on what basis the equivalent value of other tests will be assessed?
And what are suitable methods of non-destructive tests?
Is it possible to check the structural integrity of a pressure device without actually
putting it under pressure?
Furthermore:
- The following prescriptions normally apply. But when they are not applied, such as in
the case of materials not referred to individually and no harmonized standards were
used, the manufacturer has to be able to show that fitting measures have been taken
to achieve an equivalent level of general safety
The lack of more clarity and objective criteria leads to very different interpretations of
this requirement!
In the last example that should illustrate the lack of clarity in the essential requirements,
the term harmonized standards was used.
In the time period when the Directive was being drafted – something lasted some 15
years – the idea also grew to create European standards, i.e. technical specifications and
requirements necessary for designing, manufacturing, inspecting and testing of pressure
equipment, which should allow one to meet essential requirements as well. For this

I.19
purpose, the CEN (European Committee for Standardization) got a mandate from the
European Commission to prepare standards that should allow coverage of the whole
range of products of activities related to pressure equipment, taking into account the
applicable essential requirements.
In this manner, a manufacturer using a harmonized standard, will automatically gain a
presumption of conformity with the essential requirements.
A European standard acquires the status “harmonized” when the standard passes the so-
called “formal vote” and is published in the Official Journal of the European Union. The
different member states are then supposed to give the standard a national status and at
the same time to withdraw possible national standards that could contradict the contents
of the harmonized standard.
The story of the harmonized standards is not a complete success story.
Drafting and approving the thousands of required standards consumed too much time,
among other reasons because of the necessary consensus that had to be acquired from
the different member states, each one with their own safety philosophy and chauvinism.
It hardly needs to be said that some of those member states could exert a lot more
lobbying influence than other, smaller, member states.
Some member states, for example, opted for low safety margins (read: safety
coefficients) with a relatively high frequency and strictness of inspection and control,
while other member states rather chose high safety coefficients, which then result in over
dimensioning and for which a relatively low amount of inspections and controls is
required.
Furthermore, the use of harmonized standards is not mandatory.
A manufacturer can use national and international standards at all times insofar as he is
able to demonstrate that all applicable essential requirements are respected.
Due to their non-compulsory nature, many companies maintain their old trusted
standards. On the one hand this is due to their year-long experience with these
standards. Thus, for example, almost all petrochemical installations are designed and
built according to API, ASME, and/or ASTM standards and codes. On the other hand the
principle “unknown is unloved” is at play here.
A next characteristic of these Directives of the new approach and of the pressure
directive in particular is the division in risk categories.
This division is based on, as we might suspect on the basis of the degree of danger or
risk, which in this case of course the pressure in the equipment. The directive is talking
about PS the maximum allowable working pressure for which the equipment is designed.
This can be the design pressure, but the design pressure can be higher than the maximal
operational pressure for a whole host of reasons, such as standardisation. The maximal
working pressure is mostly the set pressure of the overpressure safety device of the
equipment or of the installation. Furthermore, the type of fluidum has to be taken into
account. Indeed, a distinction is made between gases, vapours, and fluids with a high
vapour pressure on the one hand, and liquids on the other hand.
For both categories, a further distinction is made between dangerous and non dangerous
substances, using the classical categorization for dangerous substances (see also EC
Directive 67/548) found in most national regulations, namely, substances that are
explosive, very lightly inflammable, light inflammable, inflammable (with a maximum
allowable temperature higher than the flashing point), very toxic, toxic or oxidating.
Furthermore, one additional parameter is taken into account, namely the potential stored
energy (under the form of pressure) in the equipment. Depending on the type of
equipment, this is expressed in volume (in liters) for all kinds of vessels, or in nominal
diameters (thus without dimension, but derived in millimeters) for pipes and all kinds of
appendages for which it is common to express these in diameters.
Relative to these parameters, all types of pressure equipment are divided into risk
categories, from category I, the lowest, up to category IV, the highest.
It needs to be remarked that for every configuration an area “Art. 3.3” is prescribed. The
specification Art 3.3 of course refers to the paragraph from the Directive that explains it.

I.20
What is involved in the case of complex industrial installations are equipment for which
the maximum working pressure certainly is more than 0.5 bars, but for which the
combination of a relatively low pressure with a relatively low volume (or small diameter)
does not constitute a veritable risk. For these equipment, the essential requirements
should not be applied, and thus these equipment may not bear the CE-marking.
To illustrate this, one of the nine configurations is presented below in Figure 1.1.1.1.
This refers to table 2 of annex II of the Directive. The table applies to vessels intended to
contain a non-hazardous gas (such as pressurized air, nitrogen, or steam).
Figure 1.1.1.1
After determining the risk category, we proceed to the next step, which constitutes an
other aspect of the Directives of the new approach, namely the choice of the procedure
of assessment of compliance with the essential requirements.
The Directive provides a number of assessment procedures in annex III from which the
manufacturer can choose depending on the risk category, and by which he demonstrates
that he respects the applicable essential requirements.
Thirteen assessment procedures are available (cf. Table 1.1.1.1) that can be used on
their own or in combination with others.
The impact of the risk category is thus limited to the degree of conservatism and the
strictness with which compliance with essential requirements is assessed.
Indeed, most of the essential requirements are expressed in very general terms, and
contain few qualitative requirements. The need to apply higher “safety requirements” for
higher risk categories, mostly due to higher pressure and other loads, is actually taken
into consideration by the design and construction standards.
The manufacturer can, within the possibilities provided within the limitations of the
directive, select the assessment procedure he wants to apply. His selection will be
determined by, among other factors, whether or not he has a quality system in place,
and also whether he plans a one-time or serial production.
The table below sums up the relations between risk categories and assessment
procedures that can be utilized. On its left side, procedures are represented based on
traditional inspection such as review and certification of design, review of other technical
documents, witnessing manufacture, inspection and testing activities.
It is worth noting that no intervention of a recognized notified body is required in
category I.
The intervention of a third party, called notified body, is also a characteristic of these
new approach directives.

I.21
In category II, this intervention is required but only in the construction phase and not in
the design phase, and only by sampling.
For categories III and IV, the assessment of design and construction is required at all
time.
The design review under the form of a pure and formal design approval under module
B1, or under the form of a type examination under module B. In addition to the pure
design, a type investigation will also assess the physical realisation based on one or more
prototypes for aspects such as manufacture, inspection and testing activities.
In some cases, the Directive allows to intervene by sampling, such as, for example,
under the modules A1 and C1, in category II, respectively in category III, in conjunction
with a type examination.
Furthermore, it needs to be remarked that for the procedures based on a quality

system assessment, the different parts of the ISO 9000, 1994 edition, are referred to,
not because this certification standard applies in its 1994 version, but to distinguish
between the different requirements made by the directive and those dependent on the
risk category, namely, a quality system that only covers final control and testing
(modules E and E1) or a quality system that covers both fabrication and final control and
testing (modules D and D1), and then finally a complete quality system that also covers
the design activities (module H and H1).
In the frame of procedure H1, the directive requires, and this despite the fact that a
complete quality system is implemented, that the notified body conducts a formal design
review and also devotes specific attention to the final control. The reference made to the
ISO 9000 standard is, as said before, not really binding. The Directive requires that the
quality system in question has to demonstrate in a binding way that it meets the
essential requirements. The ISO 9000 standard is but one of the possible means to
achieve this.
In principle, every assessment procedure or combinations of it should have the same

“weight” within a certain risk category.
By a mere comparison of the procedures with and without a quality system assessment
(left and right side of the table, respectively), important differences result due to the
complete difference in approach. It is not easy to compare and assess activities such as
reviews, inspections or tests as to their conformity with a standard or specification, with
the assessment of the related quality system.
The common introduction of quality systems for all kinds of reasons has in a way created
a vacuum in the world of quality auditing.
To check conformity with technical and other requirements via quality audits, one
certainly has to be familiar with the design and construction of pressure equipment, and
in practice it shows that few auditors are competent and qualified for this. One can only
be sure of equivalence between the two parties around the table if one has an efficient
and effective appraisal of the quality system at one’s disposal.
Within an identical table half, it is hard to speak of advantages and disadvantages. It all
amounts to choosing the most flexible and economically justified choice for the
manufacturer. An adequate choice of a type can, for example, have a considerable
number of long-term advantages if the manufacturer has to deal with only minor
variations that feature unimportant deviations of the earlier approved design or type.

I.22
Without quality assessment With quality

assessment
Serial One-off Serial One-off
CATEGORY I A
internal manufacture control
CATEGORY II A1 D1 of E1 (ISO 9002+ of ISO 9003+)
interne manufacture control with unexpected production quality control or product quality control
checks on the final control
CATEGORY III B + E (ISO 9003+)
B + C1 B1 + F EC-type examination +
EC-type examination EC-design product quality control H (ISO 9001+)
+ examination B1 + D (ISO 9002+) complete quality assurance
conformity with the + EC-design examination +
type product inspection product quality control
CATEGORY IV B+F G B + D (ISO 9002+) H1 (ISO 9001+)
EC-type examination EC-unit verification EC-type examination complete quality assurance
+ + with formal design approval
product inspection production quality control and sharpened supervision on
final control
Table 1.1.1.1 Relations between Categories and Evaluation Procedures
A constant in all this is the compilation, by the manufacturer, of the technical design and
construction file in which he gathers all elements that demonstrate that all applicable
essential requirements have been satisfied.
It is primarily the manufacturer who takes the responsibility of putting his devices in
conformity with the Directive, to evaluate them and to finally declare conformity with the
Directive, with or without the help and confirmation of a notified body.
From different legal cases in the framework of this Directive it appears that the
appropriate courts of law have the tendency to assert shared responsibility in the case of
the intervention of a notified body, as far as the latter is judged to be in error.
Therefore, it is important that the notified body take its responsibility, obviously
dependent on the selected assessment procedure, very seriously.
This message is even more important when dealing with certain procedures (B1, B, G
and the design review under H1) where the notified body is asked to support a formal
conformity with the Directive. We’d like remark here that the notified body is not a
designer, nor a pressure vessel manufacturer and that the means at its disposal to
conduct its evaluation, are per definition (as a third party) rather limited.
In the frame of other assessment procedures such as A1, C1, F, but also for other
procedures founded on quality system assessment, the situation is less clear-cut. What is
at stake here is more than merely formulating observation and objective self-evidences,
and it needs to be remarked that the reports published not necessarily conclude formal
conformity with the Directive, nor can they be seen as a certificate or attestation of
conformity.
In what preceded, it was mentioned a couple of times that from category II onwards, a
third party intervention, the notified body, is required for a number of configurations.
The notified bodies are designated by one of the member states on the basis of minimal
requirements imposed by the directives and further by the individual appraisal of each
member state.
The notified body conducts a number of assessments, ranging from simply attending the
final inspection by sampling, to the formal assessment and certification of the design and
manufacture of a category IV pressure equipment (module G) or the assessment of the
conformity of a quality system with respect to the requirements of the Directive.
Depending on the selected assessment procedure, the notified body delivers a report or a
certificate.

I.23
From that moment onwards, the manufacturer is allowed to attach a nameplate with a
CE marking to the equipment and also (obviously only from category II onward) the
identification number of the notified body that was involved in the manufacture
phase.
Both of these features constitute, together with the declaration of conformity drafted by
the manufacturer, a kind of passport for the free circulation of the pressure equipment on
the European market.
The declaration of conformity is truly a very important element in this context because it
implies the formal responsibility of the manufacturer or of his representative residing
within the European Community.
Theoretically considered, it is not required to deliver the declaration of conformity
together with the pressure equipment. The only requirement is that the manufacturer
files this declaration for ten years after putting the product on the market, and keeps it
at the disposition of the authorities whenever they may need it. Yet there does exist a
guideline 9/16 explaining this and “recommending” the delivery of the declaration of
conformity. “Guidelines” are official interpretations and clarifications of the Directive.
They are phrased and prepared by the forum of notified bodies on the requirement of all
possible users, and submitted for approval by the “Working Group Pressure” of the
European Commission. These guidelines are published on the official website of the
Commission.
(http://ec.europa.eu/enterprise/pressure_equipment/ped/directive/index_en.html).
The recommendation to deliver the declaration of conformity together with the

equipment anyway is not a major indulgence since the exploiter of the pressure device
has to be able to show, in the context of the social Directive work equipment, that all
economic Directives applicable to the “devices” were respected. As we will see further on,
this is also necessary in the case of assemblies.
The declaration of conformity gives some of the following information:
- the identity of the manufacturer or his representative residing within the European
Community;
- the description of the pressure device or assembly;
- the selected assessment procedure
- the identity of the notified body or bodies:
- the technical documentation (standards and codes) that were used to respect the
essential requirements;
- in case of a assemblies , the declaration of conformity has to mention every individual
pressure equipment integrated in this assembly ; this is necessary to ensure that
each individual equipment was judged for its conformity with the directive by their
respective manufacturers;
- when applicable the references of design- or the type-examinations
- when applicable the references of other European Directives that apply, provide very
important information for the end user;
- the identity of the signer of the declaration of conformity.
However, when introducing the product on the market, the manufacturer will have to
deliver a user manual, which, as its name implies, explains to the user how the
equipment is to be used in a save manner, but that also needs to mention all residual
risks that could occur during the expected usage of the equipment.
For the sake of completeness, it is important to explore some further aspects, such as:
- The Technical Construction File
This is a file in which a manufacturer has to file all self-evident information that
demonstrates that all applicable requirements for the equipment in question have
been respected. This file, together with the declaration of conformity, is to be filed
and kept at the disposition of the authorities for ten years after the device is put on
the market.
A table of contents of such a technical file can be found in the Directive.

I.24
- Application of other economical Directives

An equipment (for example a mixer under pressure, powered by an electrical motor)
can be subject to several European Directives (machine directive, low-voltage
directive, directive of electro-magnetical compatibility, the ATEX-Directive for
equipment destined to function in potentially explosive zones, …).
It is important to realize that a CE-marking on a device means that all applicable
directives were complied with. In such cases it is thus also important that this is
confirmed by the declaration of conformity.
- Market supervision
The Directive obliges member states to organize a market supervision in such a way
that all actors and products on the market are surveyed. The supervision of free
circulation is included in this.
- Materials
For pressure-bearing materials, the Directive provides two alternative procedures in
the cases where no European harmonized standards are utilized. These are assessing
procedures (European material approval and Separate Material Evaluation)
specifically developed for checking conformity with the applicable essential
requirements.
- Final Inspection
The directive provides for a final inspection in all cases, by the manufacturer and the
notified body (from category II onwards), whether in a sampling manner or not.
The essential requirements represent in a very detailed way which aspects have to be
reviewed during that final inspection.
- Assemblies
The directive also applies to assemblies (different pressure equipment assembled as
an integrated and functional whole by the manufacturer).
For the assessment, the Directive provides a special assessment procedure that,
apart from the status of the individual equipment, is mostly concerned with
compatibility and interfaces, and also with the safety of the assembly against the
exceeding of acceptable operating limits. Pressure is one possible applicable
parameter, but also other parameters such as temperature, level, flow, etc. can
apply.
- Industrial Installation
This term is used to distinguish an assembly assembled by the user from the
assembly assembled by the manufacturer. In opposition to assemblies, industrial
installations are not subject to the Directive but to national legislation.
Something is called an industrial installation when the integration (assembling) of
different individual pressure devices happens under the responsibility of the user on
his site.
Reason: In opposition to the first part of guideline 3/1, which confirms that the
Directive also applies to equipment manufactured by a user (for his/her own use), the
second part of this guideline states that this is not the case for assemblies of
equipment, who are for this reason called industrial installations.
- Numerical values
In the essential requirements, we can find some numerical values, such as the
pressure to be applied for the hydrostatic pressure test, the minimum impact value of
27 joules, safety coefficients to be applied in the calculations …
Due to the regular usage of non-European harmonized standards, it happens that
these values cannot be applied or respected right away.
The “taking measures to achieve an equivalent safety level” as the Directive
prescribes, is not always a simple exercise.
b) Shortcomings or Weaknesses of the System
The directive imposes legal obligations.

It imposes obligations on the manufacturers and on the notified bodies.

I.25
It also imposes obligations on the member states, such as the supervision of those actors
involved but also on the products.
We are not qualified and have not enough information to judge the efficiency of
supervision in Belgium and other member states.
On the other hand, we are regularly confronted with administrative anomalies (contents
and form of declarations of conformity, contents and form of material certificates) but
also with technical shortcomings (not reaching the prescribed material characteristics,
undetected deficiencies in material or welding joints …).
These anomalies often have two main causes.
On the one hand, there is the factor of competition since neither the unity prices nor the
inspection or assessment programs are unambiguously set. Manufacturers of pressure
equipment (such as all economic players in any market) are tempted to work with the
cheapest “suppliers”.
Also, by opening up the European market (also for notified bodies), the monopoly
position of some national bodies was broken.
Another cause that can influence the cost of an intervention is for example the size and
means of the inspection company.
Bigger and more experienced inspection companies often have a staff of experts on non-
destructive analysis, in metallurgy, possibly a laboratory, tools and human resources for
design review and approval … It is self-evident that the possibility to call upon such
experts, internal as well as external, also affects unity prices. Young, small inspection
companies with a relatively small staff and limited action radius do not have to deal with
these costs to the same degree.
The total costs of an assessment by a notified body depends to an important extent to
the number and duration of the interventions.
Not rarely are we confronted with a trimmed intervention program.
Since the task is to observe and supervise, it is obvious that the effectiveness and
efficiency of the interventions are directly influenced by their duration and frequency.
In addition to the effects of competition, an insufficient nature of the interventions

obviously also has an important impact on the “quality” and thus on the guarantee that
the equipment were designed and manufactured in conformity with the Directive.
This insufficiency can then be further split up, on the one hand in insufficient competency
and experience of the inspectors and engineers conducting the assessments and
inspections, and on the other hand in deficient quality systems (ISO 9001 or others).
From our year-long experiences, not only with the pressure directive (since 2002) but
also in the nuclear sector, with the usage of section III of the ASME code (since 1975)
wherein quality criteria are integrated in design- and construction requirements, we have
noticed that many users (both manufacturers and inspectors) have a lot of trouble with
seamlessly integrating product quality criteria with system quality criteria. Regularly,
fundamental quality parameters and thus also conformity parameters are treated poorly.
All this results in non-conformities and all kinds of anomalies that can be divided into
three groups:
- Incomplete, incorrect basic materials
A conservative estimate, supported by objective evidences and research, is that
30% of the 3.1 certificates (which number above 200) was issued erroneously,
due to the fact that the products they are supposed to cover correspond
incompletely or absolutely not to the criteria required.
Fraud by material manufacturers and suppliers when certifying materials.
An investigation by the Belgian welding institute involving the brittle breaking
behaviour of flanges in SA 105 materials established that 50 to 60% of the
flanges acquired for testing corresponded incompletely or absolutely not with the
certificates that applied to them.

I.26
Incorrect execution of destructive testing (size testing bars, bending over a less
conservative calibre diameter, bending of 90° instead of 180°…).
“Foul play” by inspection agencies with 3.2 certification.
3.1 certificates are only countersigned and, if necessary, integrated in a document
with the heading of the inspection agency itself.
- Insufficient non-destructive analysis
The quality certificates of the operators are no guarantee that the non destructive
testing technique/parameters are sufficient to detect the expected
deficiencies/indications or flaws (especially when dealing with ultrasonic, eddy
current, but also with radiographic and even magnetic and dye check testing). A
qualification or validation of the method would not be advisable here.
The Directive does not require a formal approval of the non destructive testing
procedures by the notified body. On the other hand, many notified bodies do not
have sufficient competency to check or approve such procedures.
- Non-conform design
Use of erroneous allowable stresses or other design input data.
Incoherent data.
Use of configurations not accepted by the standard.
Lack of as built conformity assessment. It is common that during manufacture of a
pressure equipment, there is a deviation from the design approved in advance, for
different reasons. Not rarely, such deviations can have an impact on the stress
calculations. Without a final comparison between the situation “as designed” and
the situation “as built”, this cannot be called an acceptable situation.
As mentioned earlier, the quasi-exponential growth of ISO 9001 certification is not an

undivided success. Not only due to the need of a large number of quality system
auditors, but also because a number of those auditors have to possess sufficient
competency and experience, proper to the technological aspects of design and
manufacture of pressure equipment.
In essence, the possibility that the Directive offers to adopt a quality system route when
demonstrating conformity really leads to a kind of auto-certification and thus leads to a
decrease of the interventions of the notified body.
It is frustrating to see that the majority of the manufacturers do not only lack
understanding of the ISO standard, but are also incapable of putting down and applying
the individual requirements of the PED in a quality system, while it is expected of the
notified body to drastically reduce its interventions and mainly focus on system
supervision, rather than product supervision.
A very specific deficiency, but one really generated by the Directive itself, are the
assemblies of equipment that are compiled under the responsibility of the exploiter on his
own site and are therefore called industrial installations and are as such not subject to an
assessment required by the Directive, due to the non-necessity of CE-marking and
intervention of a notified body.
The reasoning here is that in such cases there is no economical act being conducted.
However, the first part of guideline 3/1 is clear. When an exploiter/user assembles
himself with different parts (heads, flanges, nozzles …), this equipment does require an
assessment of conformity with the Directive. We have never understood the legislator
when he makes the distinction between assemblies and industrial installations, were it
not that thereby he provides the possibility of deviating from the Directive.
Assessing assemblies, as is specifically required by Article 10 § 2 of the Directive, is
indeed a logical step in checking the assembly for safety, as it applies for the individual
equipment.
Especially the third part of the global conformity assessment procedure and the
assessment of the safety provisions is for most assemblies a burdensome task and we
cannot grasp at all why users are trying to avoid third-party assessments here.
Because if we look further in the tangle of European laws and Directives, we then see
that there does exist something like a social Directive (cf. the beginning of this

I.27
paragraph). For example, the Social Directive for work equipment requires that a user
makes sure that all applicable Directives have been respected for all work equipment he
puts at the disposition of his workers, thus closing the circle in the end.
Indeed, assemblies (or industrial installations) can be as dangerous as individual
equipment, and furthermore we may think that it has never been the intention of the
authors of the Directive that assemblies were to be built that did not conform to the
safety requirements to which individual equipment are subjected.

I.28
1.1.2 The Machinery Directive and the Work Equipment Directives
a) Machinery Directive (98/37/EC)
Scope:
What is a machine in the framework of complex installations?
To gain an insight in the application of the machinery directive and the directive
on work equipment, it is important to take a closer look at the scope of the
machinery Directive.
Art. 2. The Directive’s definition of:
Machine:
What is a machine according to the Directive?
- an assembly of linked parts or components, at least one of which moves,

with the appropriate actuators, control and power circuits, etc., joined
together for a specific application, in particular for the processing,
treatment, moving or packaging of a material,
- an assembly of machines which, in order to achieve the same end, are
arranged and controlled so that they function as an integral whole,
- interchangeable equipment modifying the function of a machine, which is
placed on the market for the purpose of being assembled with a machine
or a series of different machines or with a tractor by the operator himself
in so far as this equipment is not a spare part or a tool;
Safety component:
What is a safety component according to the Directive?
- a component, provided that it is not interchangeable equipment, which the

manufacturer or his authorised representative established in the
Community places on the market to fulfil a safety function when in use
and the failure or malfunctioning of which endangers the safety or health
of exposed persons.
Simple machines:
The application of the Machinery Directive does not only depend on the definition,
but also on:
a) The mechanical risks present:
- When the risks are for example mainly of electrical origin, only the low
voltage directive applies (art. 1.5)
- When no risks are present, in other words if none of the essential
requirements apply, the directive will de facto not be applicable.

I.29
b) the exceptions (relevant for complex installations):
- machinery whose only power source is directly applied manual effort,

unless it is a machine used for lifting or lowering loads;
- steam and pressure vessels;
Manual shutters, storage tanks and pipelines, for example, are covered by this
and are thus excluded from the Directive.
Assembly of machines:
The directive, according to the definition of a machine, also applies to an

assembly of two or more machines, working together (cf. article 2 § a definition):
This means that an assembly of machines must also comply with the essential
requirements of the annex I of the machinery Directive.
For sizable complex installations, it is not always simple to determine whether we
are dealing with an assembly of machines or not.
Even if we assume that installations are not machines in the sense of the
Directive, it seems logical that this should not make any difference to the
requirements for an overall assessment of safety. The only difference is
administrative, namely the question whether the installation needs an additional
declaration of conformity and whether a CE-marking is to be attached.
In practice, a complex installation can be mostly subdivided in a number of
“machines” that work independently (for example an air treatment installation:
although the installation can be part of a larger whole, it can be considered stand-
alone in most cases).
In many (process) installations, there are a number of individual machines

according to the definition of the machinery Directive. Those machines are
connected by a process. The different machines in the process should therefore,
to the extent that they can function independently, bear a CE-marking, and be
accompanied by the declaration of conformity by the manufacturer of the
machine.
The safety aspects of the process itself will normally be the topic of a risk analysis
(for example a HAZOP) as required by the frame directive for safety at work
(which applies to the user – cf. infra).
The Safety Components:
These are equivalent to machines and the directive should be applied to safety
components that are put separately on the market.
Application Example of the Directive Machines:
- Pumps
A pump contains moving parts that imply mechanical risks. The directive usually
applies.
- (gas) shutter
A motorized shutter accords with the definition of machine. Should mechanical

risks be present, the directive will apply.
A manual shutter (for example for a bypass) is not in the scope of the directive.

I.30
- Pressure controller
The amount of moving parts is limited here. The mechanical risks are thus limited
as well. We are of the opinion that the directive is not applicable if the risks are
limited.
- Compressor
A compressor contains moving parts which imply mechanical risks. The directive
normally applies.
- Assembly of machines (for example a gas decompression station, …):
A combination of different machines should be considered as one machine in

some cases. Cf. supra.
Division in Risk-Categories
The Machinery Directive makes a distinction between machines that are included
in Annex 4 and machines that are not included in annex 4. Annex 4 covers 17
types of machines, for which a specific procedure applies (cf. infra).
The machines in annex 4 are mostly manually fed machines (with manual
intervention of the operator) and a number of very specific cases involving special
risks (for example hydraulic lifts for vehicles, lifting equipment for persons,
household refuse collecting vehicles, etc.).
For a complex installation, annex 4 will never apply.
Conformity Procedures
The machinery Directive contains two conformity procedures for machines,

namely the procedure for machines in annex 4, and the procedure for the other
machines.
For the machines of annex 4, an intervention of a notified body is mandatory in

some form (EC-type examination, forwarded construction file, …).
Due to the fact that complex installations are not referred to in annex 4, we limit
ourselves here to the procedure for non-annex 4 machines.
The procedure for the non-annex 4 machines is the following:
- Step 1: the machine must be built in conformity with the essential

requirements of annex 1
- Step 2: the proof of this conformity must be written down in a technical
construction file by the manufacturer (annex 5)
- Step 3: The conformity must be declared by the manufacturer in the
declaration of conformity (annex 2A)
- Step 4: The conformity must be shown through the CE-marking (annex 3).
Step 1: Conformity with the Essential Requirements
Every machine must be in compliance with the essential requirements of

annex 1 of the directive.
To establish which essential requirements apply, the manufacturer must
conduct a risk analysis on his machine.
The importance of standards:

I.31
In order to comply with the essential requirements, the European

harmonized standards should be followed. If these standards are followed,
they provide a legal presumption of conformity with the aspects (essential
requirements) that are covered by the standard.
Although application of the European harmonized standards is not
mandatory, it is important for manufacturers of machines to take them
into account.
The standards are divided into three types:
- type A are general applicable standards (for example EN 12100 general

design principles, EN ISO 14122 risk assessment, …)
- type B are standards for common aspects (B1) (for example EN 60204:
electrical equipment of machines) and safety components (B2) (for
example EN ISO 13850 emergency stop: principles for design)
- type C are standards on the level of the machines themselves (for
example EN 1114-1 extrusion machines) or families of machines (for
example EN 692: mechanical presses).
A list with the European harmonized standards is available on the website

of the European Commission (www.newapproach.org).
Step 2: the Construction File
Before a machine can be placed on the market, or put into service, the
manufacturer must compile a technical file according to annex 5 § 3a. This
file must contain the following elements:
a) A Technical Construction File:
a technical construction file comprising:
— an overall drawing of the machinery together with drawings of the

control circuits,
— full detailed drawings, accompanied by any calculation notes, test
results, etc., required to check the conformity of the machinery with the
essential health and safety requirements,
— a list of:
— the essential requirements of this Directive,
— standards, and
— other technical specifications, which were used when the machinery
was designed,
— a description of methods adopted to eliminate hazards presented by
the machinery,
— if he so desires, any technical report or certificate obtained from a
competent body or laboratory (1),
— if he declares conformity with a harmonized standard which provides
therefore, any technical report giving the results of tests carried out at
his choice either by himself or by a competent body or laboratory (1),
— a copy of the instructions for the machinery;
b) for series manufacture, the internal measures that will be

implemented to ensure that the machinery remains in conformity with
the provisions of the Directive.

I.32
The file can be considered as the proof of compliance of the machine

according to the manufacturer (and under the his responsibility).
The file must kept available for the authorities (who can request it if there
is a sound reason for it) at the manufacturer for a period of ten years
(after the last produced machine of a certain type). As such, the file is not
delivered with the machine.
Step 3: The Declaration of Conformity
The Directive machines distinguishes between three types of declarations:
- annex 2a: declaration of conformity

- annex 2b: declaration of the manufacturer for machines intended to be
build in or to be assembled with other machines
- annex 2c: declaration of conformity for safety components.
The declaration of conformity (annex II point a)
For all machinery that is placed on the market or put into service, the
manufacturer must deliver a declaration of conformity. This declaration
is a legal document that engages the responsibility of the
manufacturer.
The declaration of conformity contains the following elements:
- name and address of the manufacturer

- description of the machine
- all relevant provisions complied with by the machinery (so not only
the machinery Directive, but other applicable directives as well,
such as the low voltage directive, the pressure equipment directive,
…)
- identification of the person empowered to sign on behalf of the
manufacturer or his authorized representatives.
The declaration of the manufacturer (annex 2 point b):
For machines meant to be built in or assembled with other machines,

and which cannot operate independently, a declaration of the
manufacturer according to annex II § b of the Directive machines is
required.
It is important to note that these declarations do not provide any
guarantee on conformity, but only contain a warning that the machine
may not be put into service before the conformity of the whole has
been established by the final manufacturer (this can also be the
user/exploiter).
Such a declaration of the manufacturer can thus in no case be

considered as the final declaration. Therefore, it is always necessary,
that a declaration of conformity, according to annex II § a of the
Machinery Directive, is drawn up by the ‘final’ manufacturer.
The final manufacturer has in these cases an interest in obtaining the
necessary guarantees by contract from his supplier(s). These
guarantees include, for example, conformity with the essential
requirements that can be applied, the existence of a construction file
that proves the above, and instructions for a safe building-in or
assembly (it should be noted here that the new machinery Directive

I.33
2006/42/EC (applicable as from 29/12/2009) will make these

requirements mandatory for the suppliers of machines meant to be
built in or assembled with other machinery (the so called ‘partly
completed machinery’).
In practice, such II b declarations are very common.
Although not included in the directive, combined declarations (annexes

2a and 2b) are also very common. In such a case, the manufacturer
declares conformity with the Directive, and mentions the interdiction of
putting into service as well. This is often a paradox as the machine can
either be used independently or assembled as a part of an installation.
In the latter case the essential requirements are dependent on the
correct assembly and this should require conformity of the ‘whole’
installation.
The declaration of conformity for safety components (annex 2 point c):
Same as for annex 2 a but without the CE-marking.
b) The framework Directive and the Directive on Work equipment
These directives are considering the users (employer/employee) and aim to

prevent accidents at work.
The framework Directive (89/392/EEC):
Includes a general obligation to conduct a risk analysis and the taking of proper
measures, taking account of state of the art technology and techniques.
The Directive on the use of Work equipment (98/655/EEC amended):
In general: work equipment is defined as follows:
'work equipment': any machine, apparatus, tool or installation used at work.
What are the obligations of the user in this context:
Art. 3 (Acquiring new work equipment: selection)
The employer shall take the measures necessary to ensure that the work
equipment made available to workers in the undertaking and/or establishment is
suitable for the work to be carried out or properly adapted for that purpose and
may be used by workers without impairment to their safety or health.
In selecting the work equipment which he proposes to use, the employer shall
pay attention to the specific working conditions and characteristics and to the
hazards which exist in the undertaking and/or establishment, in particular at the
workplace, for the safety and health of the workers, and/or any additional
hazards posed by the use of work equipment in question.
Where it is not possible fully so to ensure that work equipment can be used by
workers without risk to their safety or health, the employer shall take appropriate
measures to minimize the risks.

I.34
The general principle is that, to ensure health and safety for his employees,
the employer ensures that the work equipment he puts at his employees’
disposal is suited to perform the intended work or is sufficiently adapted to do
this,
- taking into account the labour circumstances and the foreseeable risks
- if not, the employer should take appropriate measures
This principle applies to all work equipment, not only to technical equipment
such as machines.
Art. 4: Rules concerning work equipment
Without prejudice to Article 3, the employer must obtain and/or use:
(a) work equipment which, if provided to workers in the undertaking and/or

establishment for the first time after 31 December 1992, complies with:
- the provisions of any relevant Community directive which is applicable;
- the minimum requirements laid down in the Annex, to the extent that no other
Community directive is applicable or is so only partially;
Here the connection is made with the ‘economic’ directives. The user, too, has
an obligation to choose work equipment that has a CE-marking, as far as it
applies. If no directives are applicable (or if none exist), the user will have to
guarantee conformity with the work equipment directive.
If we apply this principle to a complex installation on which the machinery

Directive is not applied as an assembly, the user must take into account that
in this case the obligation of applying annex 1 of the work equipment directive
becomes his own responsibility.
Depending on the situation, this obligation can be contractually transferred to
the manufacturer, but the responsibility cannot be transferred-that will remain
with the owner. This will for example be a possibility in a project with a single
prime contractor (turnkey construction contract). In the case of a project
where the user makes individual purchases of discrete machines or
components, this may not be possible.

I.35
1.1.3 The ATEX-Directive
a) Introduction
In what follows, the ATEX-Directives are succinctly presented. ATEX is an

acronym derived from the French “ATmosphere EXplosible”. When we use the
term ATEX, we are referring to two European directives dealing with explosion
protection.
In addition to a directive (ATEX 95 directive, 94/9/EC) that describes the

conformity of materials, there is also a directive (ATEX 137, 1999/92/EC) that
includes the obligation to assess the explosion risks by performing a risk analysis,
and to control said risks by drawing up an explosion protection document.
The ATEX-Directives describe on the one hand the technical requirements for
equipment that is used in a potentially explosive atmosphere, i.e. an atmosphere
that can become explosive because of local or operating conditions. On the other
hand, they describe requirements to exploit the workplace in the safest way
possible.
As to ATEX, and more particularly explosion protection, we will focus on the

approach of process safety. This implies that we utilize the same methodology as
we use to analyse risks…
Important in all this is that this risk analysis becomes integrated in the general
process safety study, in order to conform to the requirements of the directive.
This only makes sense, however, if we are working in a process environment or
another complex environment regarding processes or substances. For process
installations, the ATEX-Directive plays on the overlap between individual safety
on the one hand, and process safety on the other.
ATmosphere EXplosible
An explosive atmosphere is defined in the ATEX-Directive as “a mixture with air,

under atmospheric conditions, of flammable substances in the form of gases,
vapours, mists or dusts in which, after ignition has occurred, combustion spreads
to the entire unburned mixture”.
b) Gas or Dust Explosion
A gas, vapour, or dust explosion is a sudden ignition, combined with a pressure

build-up caused by the ignition speed and the volume in which the explosion
takes place. For this type of explosion, two things are required. The right air-fuel
proportion and an ignition.
If the sudden ignition does not take place in a confined space, a fireball or jet fire
may appear.
Explosions are roughly divided into gas explosions and dust explosions. Dust
explosions are not treated any further in this context.
When gas or vapour is released, it mixes with air and will eventually dilute to a
such degree that the explosion danger disappears. Obviously this can only occur
when a good (natural) ventilation is present. Only where the proper gas/air
proportion (LEL) exists, there is a possibility of explosion in the case of ignition.

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c) The Economic Part (ATEX 95 Directive, 94/9/EC) and the Social Part
(ATEX 137, 1999/92/EC)
The ATEX-Directive is a European directive. The European Union expects of each

member state that they transpose this European directive into national
regulations. The ATEX-Directive is intended to achieve a total harmonization of
European standards for the use of all equipment and safety systems in an
explosion-hazardous area.
As already mentioned above, the ATEX-Directive consists of two directives. The
first one describes minimum safety requirements for equipment and protective
systems intended for use in potentially explosive atmospheres (ATEX 95,
94/9/EC) while the second describes requirements to ensure the safety of the
worker in the best way possible (ATEX 137, 1999/92/EC). The directive contains
minimum requirements for improving the safety and health protection of workers
potentially at risk from explosive atmospheres.
Division of Equipment
The directive divides the equipment and protective systems, which involves more
than just electrical material, into groups and categories with different protection
levels.
Category 1: includes equipment and protective systems that have to ensure the
required safety level, even in case of an exceptional equipment failure.
Category 2: includes equipment and protective systems that have to ensure the
required safety level, even when dealing with frequent failures or predictable and
accountable deficiencies in the operation of the device.
Category 3: includes equipment and protective systems that ensure the required
safety level when operating normally.
Classification into zones
An important element of the ATEX-Directive is the composition of a risk inventory,

which leads to the classification of areas where hazardous explosive atmospheres
may occur into zones. Within these zones, ATEX 95-approved equipment must be
applied.
These areas can be divided into the following zones:
Zone 0: A place in which an explosive atmosphere consisting of a mixture with

air of flammable substances in the form of gas, vapour or mist is present
continuously or for long periods or frequently.
air or flammable substances in the form of gas, vapour or mist is likely to occur in
normal operation occasionally.
air of flammable substances in the form of gas, vapour or mist is not likely to
occur in normal operation but, if it does occur, will persist for a short period only.
The classification into zones takes no account of the consequences but is solely
based on the probability of an explosive atmosphere occurring. The directive
demands the prevention of the formation of explosive atmospheres; and if this is
impossible ignition should be avoided; if the nature of the activity does not allow
this, the detrimental effects of an explosion have to be mitigated so as to ensure
the health and safety of workers.

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The idea behind zoning is the estimation of the likelihood that explosive
atmospheres occur. After an estimation of the probability, ignition sources should
be avoided so that the probability of an explosion becomes acceptable.
Classification into zones does not take consequences into account. When
classifying into zones, it is important that the product properties are known and
that danger sources are taken into account (for example where gas can be
released).
The ATEX 137 directive also applies to machines, via the explosion protection
document.
c) Explosion Protection Document
According to the directive, the employer is obliged to draw up and maintain an

explosion protection document.
This document needs to contain at least the following information:

• Identification and evaluation of explosion risks
• Classification of workplaces into zones
• Description of installations, processes, and/or activities
• Description of used materials/safety parameters
• Measures for protecting against explosion hazards
• Organizational measures, safety instruction of workers
• Marking of the explosion-hazard areas
• The name of the individual responsible for the drawing up and
maintenance of the document.
d) Interaction with Other Directives
ATEX and the EMC-Directive
In principle, a product has to conform to all applicable directives. Thus, in case of

the ATEX-Directive and EMC-directive (Electro Magnetic Compatibility,
89/336/EEC), both directives have to be conformed to. An example: an
acceptable EMC-emission for equipment that emits electromagnetic waves can
cause an explosion danger. In that case, ATEX takes priority.
ATEX and the Low Tension Directive
Products to be used in a potentially explosive atmosphere are explicitly excluded

from the low voltage directive (73/23/EEC). All low voltage requirements have to
be covered by the ATEX-Directive. Parts intended for use outside of the
potentially explosive atmosphere, but that contributes to the safe functioning of
equipment and safety systems, have to meet both the ATEX and low voltage
requirements.
ATEX and the Machinery Directive
The relation between ATEX and the machinery directive (89/392/EEC) is different.
The ATEX-Directive is a specific directive in the sense of the machinery directive
and contains very specific and detailed requirements to prevent any risk caused
by a potentially explosive atmosphere. The machine directive only contains a
general determination of the explosion risk. For the risks caused by a potentially
explosive atmosphere, the ATEX-Directive takes priority and must be applied
supplementary.

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1.1.4 The Seveso-Directive
a) Introduction
The expression “major accidents” refers to the “Directive 96/82/EC of the

council of December 9, 1996, on the control of major-accident hazards involving
dangerous substances”, also called Seveso II directive.
The Seveso II directive is a review of the so-called Seveso I directive: the
“Council directive of 24 June 1982 on the major-accident hazards of certain
industrial activities 82/501/EEC”.
Where the Seveso I directive departed from a given industrial activity, the
application area of the Seveso II directive is based on the nature and quantity of
the dangerous substances present in an establishment, whatever its activity may
be.
The Accident in Seveso in 1976
The name of the Seveso-Directive stems from the city of Seveso in Northern
Italy, where an accident occurred in the pharmaceutical manufacturing plant of
the Swiss group Hoffman-Laroche.
The plant produced trichlorophenol. In a chemical reactor, the reaction became

uncontrollable, pressure and temperature built up and tetrachlorodibenzo-para-
dioxin (TCDD) got dispersed in the atmosphere via a safety valve. This accident
caused no direct deaths. 400 to 500 people outside the factory, however, were
exposed to the then little known toxic dioxin, and there were many victims
among cattle and pets. Large amounts of soil, polluted with dioxins, had to be
carried off. This soil, stored in vessels, got lost, which led to a Directive on the
supervision and control within the European Community of the transfrontier
shipment of hazardous waste (84/631/EEC).
An important characteristic of this accident that eventually led to the directive is

the fact that neither the company, nor the police or the fire department were
actually aware of the dangers of the product that got dispersed. It was only after
several days that dioxin was discovered on discoloured leaves. Only afterwards,
evacuation of the population commenced.
The directive therefore came into being as a consequence of ignorance, anxiety,

insecurity, and fear of the employer and his employees, as well as of the general
public and the government.
Several other accidents are also at the basis of this directive, namely the
explosion followed by fire in Flixborough, England, in 1974.
The main conclusions of the investigations of these accidents were that the
potential dangers associated with industrial activities were underestimated and
that legislation was no longer adapted. Because of the rising complexity, increase
in scale, and the high technological level of the industrial activities, the
government realized that it was hard to elaborate a detailed legislation that was
applicable at any given time. It was decided that legislation had to attempt to
achieve a self-regulation of the industry. The dangers had to be controlled by the
industry and everybody had to be informed of what could happen and what the
proper response should be.

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b) Purpose
The purpose of the directive is the prevention of major accidents in which

dangerous substances are involved, and the limitation of the consequences of
this for man and environment. Thus, a high level of protection of the whole
community can be guaranteed in a coherent and effective way.
This goal is aimed for both for the protection of employees, the population and
the environment. The directive only concerns major accidents.
In the Seveso II directive, the stress is no longer on the risk of major accidents,
but on controlling the hazards here of. Furthermore, no distinction is made
anymore between different industrial activities, but “major accidents” are only
dependent on the presence or the potential presence of dangerous substances. It
does not matter whether production, storage or laboratory activities are involved.
The Seveso II directive has come into force in Flanders in the environmental
licenses policy (Vlarem I, Chapter IV) in 1999, and federally, in 2000, by means
of the Seveso “Cooperation Agreement” (Samenwerkingsakkoord in Dutch,
hereafter abbreviated to SWA).
On 31/12/2003, the Official Journal of the European Union published the directive
2003/105/EC that amends the Seveso II directive. (first amendment of the
Seveso II directive) This amendment of the Seveso II directive was transposed
via an adaptation of the Cooperation agreement (2006) that came into force on
06/05/2007.
c) Implementation and Amendation of the Seveso-Directive
Below, a short overview is given of the most important changes introduced by the
first amendment:
• Lowering the threshold values for the category “dangerous for the
environment”
• Separate addition rule for substances that are dangerous for the
environment (no longer in combination with the (very) toxic substances)
• Adaptation of the definition of an explosive substance
• Addition of the definitions of gas and liquid
• Extension of the list of carcinogenic substances
• Adding potassium nitrate to the list of the named substances
• Classification of ammonium nitrate in the list of named substances
• Classification and clarification of “Gasoline and other oil fractions” and the
lowering of threshold values
• Processing activities and the related storage of dangerous substances
related to exploitation of minerals are also within the area of application of
the directive
d) Legislation in the Netherlands vs. Flanders
Environmental Legislation
In Flanders, the Department of Environment, Nature, and Energy is responsible

for environmental legislation related to the Seveso II directive. In the
Netherlands, the VROM (the ministry of Public Housing, Spatial Planning en
Environmental Management) is responsible for this. The VROM has the following
priorities: creating a pleasant living environment, conducting a spatial
development policy and development of a durable future.

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In the Netherlands, the Environmental Management Act (Wet milieubeheer or

Wm) acts to protect the environment. This is the most important environmental
law, which is based on the principle of “duty of care”. The Environmental
Management Act gives general rules for various topics, from substances and
waste products to enforcement, right of access to environmental information,
environmental licenses, and modalities of appeal. The Wm came into force on
March 1st, 1993. The Act is constantly amended by the VROM, with the purpose of
ameliorating and reducing regulations. The Wm contains the general
requirements for environmental management, while more specific requirements
are elaborated in decisions.
The Activities Decree (Activiteitenbesluit)(in effect from 01/01/08) is a decision
included in the Wm, which imposes general requirements on companies. These
companies do not need an environmental license (anymore). The decision
reduces administrative load for the industry. Companies are divided in three
types (A, B, or C) of which only companies of type C have the obligation of having
an environmental license. More and more companies fall under the general rules
and do not need an environmental license (anymore). In the future, only
companies that fall under the European Council Directive of 24 September 1996
concerning integrated pollution prevention and control (IPPC Directive 96/61/EC),
will need an environmental license.
Safety Legislation
In the Netherlands, the Decree Major Accidents (Risks) 1999 (BRZO 1999) and
the Hazards of Major Accidents Regulation are transpositions of the Seveso II
directive. All companies to which the BRZO 1999 applies have to do everything
necessary to prevent and limit the consequences of major accidents. BZRO 1999
applies to installations in which dangerous substances, according to the Wm
license, can be present or can be created in certain quantities as a result of
runaway reactions in an industrial chemical process.
In Flanders, the Seveso II directive was transposed to the Cooperation

Agreement.
Installations that fall under a BRZO 1999 have to have a Prevention Policy Major
Accidents (PBZO) and a Safety Management System (VBS) in any case.
Information duty also applies. In addition, companies from the high risk category
(VR-duty-bound) have to draft a safety report (veiligheidsrapport or VR), an
internal emergency plan, and an updated substance list. These duties are the
same in Flanders, except for some minor differences. In Flanders, a VR consists of
a SWA-VR and an OVR. An internal emergency plan is complusory in Flanders for
all (low and high threshold) installations, which differs from the situation in the
Netherlands. The Commission Prevention of Disasters by Dangerous Substances
(CPR) has published a number of reports in which the methods for QRA-
calculations have been included. These reports have been integrated in the
publication series “Dangerous Substances” (PGS). The Flemish legislation refers
to these publications and these methods have to be followed completely in some
cases.
When drafting a QRA to determine the external human risk, the “Manual Risk
Calculations Bevi” is consistently referred to, which is the replacement of the no
longer used Purple Book.
For some topics, Flanders refers to its own publications, such as the Handbook
Probability Rates.
Thus, it can be concluded that both Flanders and the Netherlands have the same
goal in mind, but that their practical ways of reaching it are slightly different.

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1.2. National Legislation
1.2.1 The Situation in Belgium
a) The Nuclear Legislation and the Ministerial Decree of Deviation V4087
There exist two regulations that apply to equipment and installations classified as
nuclear in Belgium:
On the one hand the regulation dealing with the danger of ionising radiation
for the workers and population.
On the other, the regulation dealing with the danger of losing structural
integrity of pressure equipment for the workers and population.
In the context of this overview, we will obviously limit ourselves to the second
part.
Due to the lack of any relevant legislation but also due to the lack of design and
construction requirements, Belgium pleaded, at the moment that it was decided
to build nuclear power plants, for the adoption of the American regulation of the
USAEC (United States Atomic Energy Commission) and the USNRC (United States
Nuclear Regulatory Commission), such as § 50-55a of the 10 CFR 50 (Code of
Federal Regulation) and the Regulatory Guide 1.26. These prescribe sections III
and VIII of the ‘ASME Boiler and Pressure Vessel’ code for nuclear ‘safety classes’
A, B, C en D.
In that period (1974), something like the ARAB (General Regulation for Labour
Protection) did exist in Belgium, a regulation that, among other things, provided
prescriptions for the design and construction of steam devices, but that certainly
was not sufficient for this new form of steam generation and power production.
Legally, this was arranged by drawing up ministerial decrees that contained a

deviation from ARAB in favour of the ASME code(s), something that was repeated
for every new plant that was to be constructed.
In addition to the aspect of supervision on new constructions, the aspect
supervision in exploiting and the periodical inspections, replacements, reparations
and alterations were regulated via the same deviations, this time in favour of
section XI of the ASME code.
After several evolutions of the Belgian national legislation for steam devices (the
earlier ARAB), a new all-inclusive ministerial decree was drawn up and approved
in 1993 (M.D. V4087 of 11/6/1993) for the seven Belgian plants in service at the
moment.
In an appendix, this ministerial decree provides some practical modalities in

relation to the interfaces and division of responsibilities between the different
intervening supervising organisations:
for the section protection against ionising radiation, a recognized body of class
1 is responsible (something that has also been changed by now);
for the protection against the loss of structural integrity of pressure
equipment, an authorized organisation qualified for evaluating steam devices
is responsible.
To make the use of American regulations and construction codes go smoothly in a

Belgian context, a number of conversions were set down. Thus, a document
called “Transposition of the ASME III code to the Belgian context” and another
one called “Transposition of the ASME XI code to the Belgian context” were drawn
up.

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In both these documents, a number of administrative, organisational, registerial

and technical conversions are described that render the application of the ASME
codes possible.
Thus, for example, the supervision by an AI (Authorized Inspector, member of an
Authorized Inspection Agency in ASME III) and by an AII (Authorized In-service
Inspector in ASME XI) has been replaced by the supervision of an inspector of the
authorized body for steam devices.
The extent of the supervision of the third party was adjusted too. Thus, in the
Belgian context the authorized body for steam devices will also conduct the
quality audits of ‘manufacturers’, ‘installers’ and ‘engineer organisations’, instead
of ‘The ASME Society’ as in the American context.
Other conversions are not discussed here.
Due to the fact that the ministerial decree of deviation in favour of the ASME
codes is a deviation of the Belgian steam legislation, what precedes obviously
applies to ‘steam devices’.
For that reason, the amendment explicitly stated what is to be considered a
steam device.
In the context of the Belgian PWR-plants, these are the reactor vessel and the
primary loop with all devices and branch connections up until the second shutter
organ, and also the secondary side of the steam generators and the secondary
loop with all devices and branch connections up until the first shutter organ. This
whole is referred to as the ‘nuclear steam vessel’.
Furthermore, there are some individual devices that in themselves, due to their
design and operating conditions, are also subject to Belgian regulation.
Obviously such a PWR plant consists of a lot more than a nuclear steam vessel
and some devices…
Analogous to the ‘steam’ part, all other pressure-bearing devices, pipes and
installations, subject to ASME III or ASME VIII code are subject to supervision by
a Belgian authorized body, depending on their quality class (A, B, C, D or D+)
(there are some variants to this, but these are irrelevant to the current
discussion).
The authorized organisation mainly intervenes in the following stages to check

the structural integrity of the equipment and installations:
Design Review
Evaluation of QA-programs of ‘engineer organizations’

Review of technical specifications;
Review of design drawings and calculations;
Review of execution drawings and execution procedures;
Drawing up of inspection programs;
Supply of Materials, Accessories and Equipment
Evaluation of QA-programs of manufacturers;

Review of manufacturing and control programs and of fabrication procedures
(forming, heat treatment …);
Review of destructive and non-destructive testing procedures;
Identification of the materials and review of the corresponding material
certificates;
Supervision and evaluation of qualification tests of welding procedures and
welders and of non-destructive testing procedure and personnel;
Supervision of the execution of destructive tests and evaluation of results;
Supervision of and evaluation of manufacturing activities;

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Supervision of the execution of non-destructive testing and evaluation of the

results;
Supervision of the strength and tightness tests;
Visual and dimensional examination;
Review of technical documentation;
Marking and certification;
Supervision During Construction
Evaluation of QA-programs of ‘installers’;

Review of manufacturing and control programs and of manufacturing
procedures (welding, heat treatment, …);
Review of destructive and non-destructive testing procedures;
Identification of the materials and review of the corresponding material
certificates;
Supervision on and evaluation of qualification tests of welding procedures and
welders and of non-destructive testing procedures and personnel;
Supervision on and evaluation of manufacturing activities;
Supervision on the execution of the non-destructive testing and evaluation of
the results;
Supervision of strength and tightness tests;
Review of technical documentation;
Marking and certification;
Inspections During Operation
Evaluation of QA-programs of ‘service organizations’;

Evaluation of programs for replacement and repair;
Supervision of repairs, replacement and evaluation of the results;
Review of inspection programs for verifying the structural integrity;
Supervision of the qualification of non-destructive testing procedures or
personnel and evaluation of the results;
Supervision of the execution of non-destructive testing during the exploitation
and evaluation of the results;
Expertise of damage cases.
Remark: the publication and conversion of the European Directive for pressure
equipment (EC 97/23) has up to this day brought about no change in the Belgian
legislation applying to equipment and installations classified as nuclear.

I.44
b) The steam legislation – RD-MD 1991
Steam legislation in Belgium had, for a long time, been set down in the ARAB (the
General Regulation for the protection of workers).
The ARAB regulated a lot more than just matters related to the surveillance and
inspection of new pressure equipment but also it regulated the putting into
operation and periodical inspections of steam equipment and installations.
In 1991, the regulation of steam applications was altered in a Royal and a
Ministerial Decree. The regulation of other applications than steam was also
arranged via Royal Decrees.
However, the transposition into the Belgian Law of the European Directive for
pressure equipment EC 97/23 abolished all paragraphs related to the
manufacture of new equipment in favour of this Directive. This was accomplished
via Royal Decree.
Certain chapters of the Vlarem (a regulation in Flanders) were abolished too.
In this manner Belgium has formally aligned itself with the European legislation,
namely that when implementing a Directive all national regulations dealing with
its substance must be abolished.
However, the prescriptions for putting into service and periodical inspection were
not abolished since the European Directive only applies to the introduction on the
market of new pressure equipment

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c) Law of 12 April 1965 (Gaslaw)
The law of 12 April 1965, and the subsequent amendments to it, regulates
transport and transit of dangerous substances via pipelines and establishes a
number of requirements that apply to transportation companies and
transportation installations.
It is a federal matter that is the responsibility of the federal minister responsible

for energy (FOD Economy).
The term “transportation installations” applies to all pipelines, including direct

pipelines and upstream-installations, and all means of storage, LNG-installations,
buildings, machines, and auxiliary installations meant for or used for:
supplying distribution companies;
supplying final customers, when the yearly volume crosses a certain threshold
or when the distribution company cannot fulfil their demands;
transportation without distribution or delivery of gas on Belgian territory;
connection between installations for gas production and the different
exploitation seats of an identical company;
…
The products referred to are natural gas, oxygen, hydrogen, ethylene, propylene,
liquid or liquefied hydrocarbons, saline solutions, …
The law treats the following subjects:

regulations on transportation licenses and the administrators of transportation
installations;
rights and obligations of the holders of transportation licenses and of the
administrators;
delivery permits;
access to the transportation network;
tariffs, public service obligations, …;
surveillance of the assurance of supplying;
…
In view of the execution of the law, a number of Royal Decrees and ministerial
instructions were drafted and issued.
A number of these establish the minimal safety requirements which holders of

transportation licenses have to fulfil when establishing and exploiting their
transportation installations, without diminishing the obligation to keep the
installations in good operating conditions at all times. Therefore, these set a
number of requirements related to:
materials and accessories (mechanical properties, manufacturing and delivery
requirements, …);
design information (thickness of pipes, …);
activities for installing the pipelines (digging depth, welding, control of the
welds, …);
final tests (strength test, tightness test, …);
protection of the installations (cathodical protection, coating of the pipes,
paint, …);
exploitation conditions;
…
In addition, these Royal Decrees determine that the tests, inspections and trials
that they prescribe for the establishing, altering and repairing of transportation

I.46
installations, have to be executed under the surveillance of an inspection body

that is authorized as such by the minister of energy.
The authorized body thus intervenes mainly in the following stages to make sure
of the structural integrity of equipments and installations:
Supply of materials, accessories and equipments
These are pipes, fittings, flanges, pig traps, meters, filters, pressure vessels,
valves, hot bends, plates, … in short, all materials, accessories, and equipments
that will be exposed to pressure (excluding instrumentation).
Depending on the individual case, the interventions of the authorized body

involve the following:
review of the drawings, of the calculation notes, and of the choice of
materials;
review of the manufacturing procedures (welding, heat treatment) and the
inspection procedures (non-destructive testing, …);
identification of the materials and review of the corresponding certificates;
surveillance of and evaluation of destructive testing, welding activities (during
qualification of the procedures and manufacturing) and non-destructive
testing (during qualification of the procedures and manufacturing);
surveillance of the strength and tightness tests;
visual and dimensional examination;
surveillance during the application of protective coatings;
review of the technical documentation;
marking;
…
Surveillance of the prefabrication, assembly, installing, converting, and repairing

activities on site and in the workshop
review of the manufacturing procedures (welding) and the inspection

procedures (non-destructive testing);
identification of the materials and review of the corresponding certificates;
surveillance of and evaluation of the welding activities (during qualification of
the procedures and montage);
surveillance of and evaluation of non-destructive testing (during qualification
of the procedures and montage);
surveillance of and evaluation of the cold bending;
surveillance of the strength and tightness tests;
visual and dimensional examination;
surveillance during the application of protective coatings (coating of the welds,
paint, metallization, …);
inspection of the digging in;
review of the technical documentation;
…
It is important to stress some elements that indisputably have contributed to the

safety of transportation installations in Belgium:
1. legislation requires that a body independent of the holder of the

transportation license surveys the construction, conversion, and repair
activities to the transportation installations;
2. although this is not explicitly mentioned, the spirit of the legislation indicates
that the holder of the transportation license appoints the body responsible for
surveillance, and not the manufacturer, the contractor, or the engineering
company; because the holder of the transportation license would have as a

I.47
primary goal the exploitation of a safe transportation network, while certain

financial interests for the constructors or contractors could in certain cases
triumph over safety purposes;
3. the number of bodies that are authorized by the minister is relatively limited,
which promotes the competence and experience level of those bodies;
4. the mandate of the authorized body is broad, as described above; however,
we can marvel that it is rather limited concerning inspections during the
operation of transportation installations; but government bodies survey the
exploitation of transportation installations and are also charged with
investigating the files for the request of an extension of the license.

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d) Electrical Installations
Electricity
Our contemporary world is inconceivable without electricity; this power source

has become irreplaceable anywhere, whether in housekeeping or in the industrial
sector. Electricity is so usual and common, that we do not always stop and think
how important it is to handle it with care. Always use safe electrical material for
building a safe electrical installation.
When we are discussing electrical safety, we can thereby mean different aspects,
such as:
- the safety aspects of the conception of the installations: a good selection of
materials and of the installation manners and a correct dimensioning in view
of the safe and efficient operation and safe use of the installations;
- safety when constructing the installation, with on the one hand the execution
of the installation work conforming to the design, and on the other the safety
of the individuals doing the construction work;
- the safe exploitation of the installation: drawing up and applying correct
procedures for safe operation and use, for finding and treating problems that
manifest themselves …;
- safety at maintenance, tracking failures, repairing, controlling, checking small
expansions or adaptations, and similar operations on installations in
operation, outside of the actual use of the installation.
To fulfil all of these demands, the electrical installation in Belgium has to be

constructed and maintained according to the “rules of the game”, the AREI.
Legislation Electricity
The AREI (General Regulation on Electrical Installations) applies since:

- October 1st, 1981 for the domestic (residential) installations of for companies
that do not have an electrical maintenance service (BA4-BA5);
- January 1st, 1983 for all other installations.
Before the AREI, there was the ARAB (General Regulation on Labour Protection –
1947) and the Technical Regulation (published by the power company in 1972).
Every electrical installations, even those powered by a private installation, has to
be subjected to a equivalence investigation according to the prescriptions of AREI
before it can be put into operation.
The electrical installations must be built with safe electrical material,

commensurate with their purpose, and must be maintained in a proper manner in
all their composite parts according to the prescriptions of this regulation and the
rules of good workmanship, in such a way that safety of individuals or goods is
not endangered when the installation is flawlessly maintained and used in
accordance with its purpose.
No electrical installation can be put into operation if violations of this regulation

are established during the equivalence investigation. What needs to be done to
make the violations established during investigation disappear, must be done
without delay and all proper measures must be made to ensure that the
installation in violation, should it remain in service, constitutes no danger for
individuals or goods.

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Figure 1.2.1.4.1
AREI
The AREI applies to all electrical installations for production, conversion,

transport, and use of electrical energy in as far as the normal frequency of the
current does not exceed 10,000 Hz.
The electrical installations must be built with safe electrical material,
commensurate with their purpose, and must be maintained in a proper manner in
all their composite parts according to the prescriptions of this regulation and the
rules of good workmanship, in such a way that safety of individuals or goods is
not endangered when the installation is flawlessly maintained and used in
accordance with its purpose.
By ‘safe electrical material’ we refer to:
- electrical machines of devices: appliance that is used for the production,
conversion, distribution or utilization of electrical energy;
- electrical conductor: a bare or isolated object that can be used for
transporting electrical energy;
- electrical cable: conductors combined with their individual casings and their
possible common casings or common shafts;
which have to conform to the respective European directives and norms.
It is the user’s and/or electro-installer’s duty to provide safe controlling and
power loops in the electrical installation.

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Figure 1.2.1.4.2
Protection Measures
All parts of electrical installations have to be designed and constructed relative to

their nominal tension, and measures need to be taken again hazards such as
electrocution and fire.
A dangerous shocking current can run through the human body if the following
conditions are met:
1. the human body serves as conductor in a closed loop;
2. the active parts of electrical equipments, the masses or the alien conducting
parts are at different potentials;
3. the value of the current is sufficiently large or the duration of the passage of
the current in the human body is sufficiently long relative to the value of the
current to cause grave physiopathological consequences.
The protection measures against electrical shocks attempt to prevent at least on
of these three conditions. Active and passive measures can be distinguished,
whether or not they involve the cutting of the current.
The electrical protection against overcurrents must prevent that the electrical
material is traversed by currents that can harm the material as well as the
environment.
This protection must be provided by one or more devices that cut the current
before an accumulation of heat can take place that endangers the isolation, the
connections, the conductors and their environment.
Overcurrents in conductors can be of a threefold nature, which is:
1. overcurrents caused by an increase in the power contained in the user
equipment, one that rises above the normal capacity of the cable, for
example:
- as a consequence of blocking a appliance due to a mechanical overload;
- as a consequence of connecting additional appliances without enlarging the
diameter of the conductors;
- as a consequence of replacing certain appliances by appliances with more
power, without adjusting the cable accordingly;

I.51
2. impedance short circuit current in electrical material; the faults, that cause a
current with the character of an overcurrent, are caused by isolation gone
deficient;
3. short-circuiting currents.
The overcurrents caused by the non-adjustment of the electrical cable to the
terms of usage, have to be prevented by enlarging the power cables.

I.52
e) Fire Safety of Industrial Installations
a) Introduction
Nearly every governmental level in Belgium issues regulations related to fire

safety. Most texts are published by the federal government and by the regions
and communities.
Furthermore, the mayor has, just like in most countries with a legislation based
on the “Code Napoleon”, an important responsibility for safety of the territory of
his city. Often, local fire safety requirements are imposed via local regulations as
a supplement to regulations on federal, regional or community levels. In addition,
mayors often ask the fire department for advice to impose specific requirements
related to fire safety.
To clarify our relatively complicated state structure, an overview of our regions

and communities can be found below:
Figure 1.2.1.5.1
As an introduction to the situation of fire safety in industry, figure 1.2.1.5.2

gives an overview of a part of the fire regulations in Belgium for some
governmental levels:

I.53
Federal Communities Regions
Internal Affairs NL FR D
Public Health
Economy
Wallonia
Flanders
Brussels
Labour
Hospitals Town and country planning

Codex, ARAB, …
Basic Standards
construction
AREI, RL
materials
Retirement homes Rooms
Hotels Environmental
Overview is an illustration and is incomplete!

Source: Ir. Jan De Saedeleer FOD Internal Affairs
Figure 1.2.1.5.2
As can be deduced from Figure 1.2.1.5.2, regulations on fire safety in industry

are mainly found in the following places:
FOD Employment, Labour, and Social Deliberation

The FOD WASO is responsible for two important parts of the regulation on fire
safety in industry, namely the “Codex Well-Being at Work” and the “ARAB” (cf.
ARBO in the Netherlands) and the conversion of the Seveso-directive in Belgian
law.
In 2.9.2 below, you’ll find more information on fire safety in our labour legislation
(CODEX).
The Seveso directive is treated in chapter 1.1.4
Regions
The regions are responsible for the environmental regulations. In every region
(Flanders, Brussels, Wallonia), important chapters on fire safety have been
included in environmental legislation.
FOD Economy
The FOD Economy also has two regulations important for fire under its
responsibility, namely the Royal Decree of 19 August 1998 concerning products
intended for construction (conversion of European directive 89/106/EEC) and the
AREI (General Regulation of Electrical Installations).
FOD Internal Affairs

Another important reference for fire safety in Belgium is the RD of 7 July 1994
(including amendments 1997, 2003, and 2004) for establishing new basic
standards for prevention of fire and explosion to which new buildings have to
conform. As the title itself indicates, this is limited to buildings. The appendix of
this RD on industrial buildings is at the moment still being drafted. Nevertheless,
the draft is already being frequently used as a basic text for new industrial
buildings by advice of the fire department.

I.54
b) Codex on Well-being at work and General Health and Safety

Regulation
Actual prescriptions on fire safety of industrial installations can hardly be found in

this regulation. Some examples:
4. In title III Workplaces – Chapter IV “Special Workplaces” – Paragraph 9
“Storage spaces for inflammable fluids” (i.e. RD 13/03/1998), some
general prescriptions for these storage spaces can be found.
5. Also in title III Workplaces – Chapter IV “Special Workplaces” – Paragraph
10 “Spaces constituting risks for employees by an explosive atmosphere”,
the conversion of the European “social” ATEX-directive can be found.
Furthermore, this regulation is limited to the general principles of responsibility of
employer, dynamic risk management, etc.
In the ARAB (that is systematically being phased out in favour of the Codex),
Article 52 can be found that in addition to general principles gives an outdated
technical content that is particularly aimed at buildings. In other words, this text
gives little solid ground when dealing with industrial installations.
c) Construction Products
Fire safety is one of the main themes of this European directive in the context of
“free circulation of goods”. In this context, this means in practice that
components for, for example, sprinkler installations and detection systems are
construction materials.
To the degree that there already exist applicable harmonized standards (or
sometimes ETAs (European Technical Approval)), these materials should carry a
CE-marking with all the responsibilities that this implies.
In practice, however, it often happens that the specific equipment necessary for
or used for fire safety of industrial installations is often not available with CE-
marking, but is available with, for example, an approval of the NFPA framework
(National Fire Protection Association).
d) Other Prescriptions
Because of the European tendency to include less and less technical prescriptions
in regulations, and let the fleshing out of technical prescriptions happen more and
more via standards, we will here also have to call on standards to locate specific
prescriptions. In the chapter on European regulations, more information can be
found on this evolution.
As far as fire safety of industrial installations is concerned, the standardized

frame in Europe is rather limited, and NFPA prescriptions are often used.
Some examples of NFPA-prescriptions can be found in the reference list on the

last page of Chapter 2, paragraph 9.

I.55
1.2.2 The Situation in The Netherlands
1.2.2.0 Introduction
In no way is it our intention to describe the complete applicable legislation in the

Netherlands in this paragraph.
Here we limit ourselves to the “Putting into Service Inspection” (KvI); this
inspection is not mandatory in Belgian.
1.2.2.1 Putting into Service Inspection
Before classified pressure equipment can be put into service in The Netherlands, a
so-called “Putting into Service Inspection” (KvI) needs to be conducted. This is
under national regulation.
This is different than with the directive pressure equipment 97/23/EC (PED –
Pressure Equipment Directive) that has a European reach.
The inspection includes an evaluation of the installation of pressure equipment to

ensure a safe use and the possibility of good maintenance. It is important to
understand that this in fact involves the environment of the pressure equipment
and not in the first place the pressure equipment itself. For the latter has been
CE-marked and may come supplied with a Declaration of Conformity (DOC –
Declaration of Conformity) and conforms to legislation. However, it remains
possible to apply such a device in a way that still introduces a safety risk. This is
the reason that the inspection is not only focused on the presence of a CE-
marking and the DOC.
The inspection is performed by an Appointed Inspection Agency (AKI).
An AKI is appointed by the Dutch government and can only perform inspection
activities within the Netherlands, in opposition to a Notified body in the directive
pressure equipment, which can operate anywhere in Europe.
Before the KvI became obligatory on January 1st, 2002, we had the so-called
“closer examination” in the Netherlands, as mentioned in the RToD page G 0301
paragraph 12. This was based on the old steam decree. This examination
consisted of two parts: the first included a schematics evaluation and took place
at the approval of the design, the second was conducted in the field. It is this
latter part that is the closest to the current KvI.
In the pressure equipment directive, the putting into service of pressure

equipment is discussed in article 4, titled “Free Circulation”. Therein is stated,
among other things, that the member states cannot prevent the putting into
operation of pressure equipment that conforms to the directive and has the CE-
marking, on the basis of hazards due to pressure.
There are two important notes to be made here:
1. There are other risks than “pressure”;

2. Conforming to the pressure equipment directive.
Both these topics are the reason why a KvI is very useful and often necessary in
practice to ensure safety. Safety is not only connected to “pressure” here.
On the first point it can be remarked that the hazards based on pressure should
be sufficiently covered by conforming to the pressure equipment directive.

I.56
A Pressure Safety Valve (PSV) provides protection from overpressure in the

pressure equipment, but should it fail to release that pressure in an appropriate
way and on a proper location when opened, individuals and equipment in the
vicinity could be at risk.
A manhole provides in itself possibilities for maintenance and inspection.

However, should this manhole not be freely accessible because of neighbouring
pressure equipment or a construction, this possibly creates labour risks and a not
optimal execution of maintenance and inspection.
To determine whether pressure equipment is classified and has to be inspected,

the Law on Goods enforcement contains both texts and tables. Because herein
risks of very toxic or explosive substances (PED substance group 1) or very
undesirable substances for the environment (PED 2) are treated differently from
what the classification according to the pressure equipment directive implies, it is
possible that though the pressure equipment does not or only in part requires the
participation of a Notified body, the KvI performed by an AKI is nonetheless
obligatory.
The risk of a possible release of such substances on the basis of whatever cause
is considered too high. The result is that, when dealing with these substances, a
KvI is already obligatory for lower amounts and smaller design pressures. The
same goes for the in-service/periodic inspection of such pressure equipment.
Refer to Figure 1.2.2.1 with table 1A of the ‘Warenwetregeling’ (Law on Goods

enforcement) pressure equipment as an example of this.

I.57
Putting into Service

Inspection or periodic
Inspection
Inspection
responsibility for
the User ( ARBO
decree)
Classification limits for the Putting into Service Inspection and Periodic Inspection for
pressure vessels intended for gases as classified in group I in Article 9 of PED as fas as they
are very toxic or explosive
Figure 1.2.2.1
The second point is to be approached with nuances in practice.

At the end of its manufacture, a piece of pressure equipment can conform
perfectly to the PED, but often there is a long road, both in a figural and literal
sense, to the construction yard where it is to be integrated in a large assembly,
for example a petro-chemical installation. Just by transporting and hauling the
pressure device to, for example, twenty meters high and connecting it to other
pressure equipment, damages regularly occur. These can cause a direct risk
because, for example, a nozzle has been damaged. But long-term risks can also
come into being because, for example, grinding and welding activities in the
vicinity of the pressure equipment decreased the latter’s corrosion resistance.
The same goes for a valve, which can be neatly supplied with a CE-marking and a
DOC, but can also simply be inserted in the wrong direction, causing a safety risk
despite the markings, in addition to possible maintenance problems.
The result is that, in such a case, the pressure equipment / assembly does not in
fact meet the requirements of the directive pressure equipment and the safety
level demanded by it.
According to the Wares law on Goods decree Pressure Equipment, the KvI has
four main objectives :
1. Verification using technical documentation and markings;

I.58
2. Inspection of the external condition of pressure equipment, assemblies

and pressure systems;
3. Inspection of the operation of the safety appendages accessories
provisions and pressurized appendages pressure accessories pressure
provisions;
4. Inspection of the arrangement of the pressure equipment, combinations
assemblies and pressure systems.
In The Netherlands, the focus of the inspection has been agreed upon and set
down in cooperation with the parties involved. This resulted in a checklist that,
because of its inclusion in a application guideline for pressure equipment (PRD), is
available to other parties than AKIs. The list has been shaped by practical
experience, and is therefore based on common sense instead of a theoretical
consideration.
Because the list is available for all parties, one would probably expect that on the
moment that the inspector of an AKI pays a visit to conduct the KvI, no remarks
can be made. Experience, however, presents a totally different picture. The
combined action of owner – EPC contractor – mechanical contractors and
subcontractors makes a KvI (still) essential.
Whether we are talking about a KvI at a major multinational or at a small

organisation, is of little importance here.
In the past, systems reported as ready were checked by so-called “punching” by

inspectors; this resulted in punching lists containing imperfections /remarks that
were subsequently corrected by the respective contractor. This action seems to
be conducted less effectively/qualitatively nowadays, probably because of time
pressure and a lack of good inspectors. Often, inspections are also requested and
conducted too early, in view of positive effects this may have on construction
planning.
During inspection, the inspector thus has to look at the installation from a
“helicopter view” and ask himself what, how, when and by whom is work
performed here and which interaction exists between the installation, persons and
installation parts. Does Murphy have a chance?
From its findings, the AKI draws up a Report Putting into Service Inspection
(RIK), and, after possible deficiencies have been remedied, a Declaration of
Putting into Service Inspection. Both documents are put at the disposal of the
owner of the pressure equipment.
Below, you will find a number of typical findings reported after the KvI:
Nbr Inspection point Findings

1 Putting into Service Inspection applies? Yes
10 Verification by technical documents and
markings.
Checks of:
11 Presence of documents that prove that the 1. Declarations missing;
conformity assessment of the individual 2. Declaration drawn up by
pressure devices have been conducted other party than the
according to the directive, such as: the EC- manufacturer;
declarations of conformation, CE-marking, etc. 3. Absence of Notified body
documents.
12 Presence, behind the CE-marking, of the 1. Notified body number not
identification number of the Notified body present.
involved in the manufacturing inspection phase.

I.59
13 Presence of a firmly attached dataplate that 1. Dataplate under isolation;

provides the required data for identification, 2. Wrong process parameters
safe installation, use or utilization, maintenance provided.
and periodical inspections.
14 Acquaintance with the relevant texts for the 1. Correct documentation not
Putting into Service Inspection in the instruction present during KvI;
manual. 2. No safety issues mentioned
in the user manual.
15 Possibly required presence on dataplate of a 1. If applicable, not present;
warning, drawn from experience and risk- 2. Wrongly placed
analysis, of the manner in which the pressure 3. Not durable.
equipment should not be used
Figure 1.2.2.2
20 Inspection of the external condition of

pressure equipment, assemblies and
pressure systems.
Checks of:
21 Deformations and external damaging (dents, 1. Damaged by placement
rust, etc.) (lifting operations);
2. Damaged by installation;
3. Corrosion because of
insufficient protection during
storage;
4. Corrosion by activities in the
vicinity of the installed
device (weldings and
grinding);
5. Unable to perform
inspection, device is
inaccessible.
Figure 1.2.2.3
Nbr Inspection Point Findings

30 Inspection of the working of the safety
accessories and pressure accessories
Checks of:
31 Settings and identification data of the safety 1. Wrong safety in place;
accessories and pressure accessories . 2. Not calibrated by certified
company;
3. Wrong opening pressure..
32 Operation / simulation of the operation of the 1. Pilot-operated valves
safety accessories and pressure accessories. blocked;
This can happen in both cold and hot conditions. 2. Pilot-operated valve not
Focal points can be: completely open in final
• important signal and alarm functions position.
• safeguard of the configured parameters 3. Water level low. Alarm when
• time in which the system responds point L.W. has already been
sufficiently passed.;
• correct functioning of shutter organs closure
devices shutter devices/ valves
35 Of venting system, unblocked venting of vented 1. Venting capacity too small;
medium and provisions such as bird mesh that 2. Vent placed on a location
guarantee venting capacity and unblocked that causes danger for
venting individuals
3. No mesh in place.
Figure 1.2.2.4

I.60
Nbr Inspection Point Findings

50 Inspection of the arrangement of pressure
equipment, assemblies and pressure
systems. Checks of:
51 Placement of the equipment according to user 1. Wrong support used;
manual 2. Leg spring support not
deblocked.
52 Attachment, according to the user manual, of 1. Device not attached to the
the supports to the foundation foundation.
55 Readability and placing of measuring equipment 1. Measuring equipment placed

such as pressure gauges and thermometers. where a person cannot
normally reach without a
ladder;
2. Wrong pressure gauge .
56 Accessibility of the controls for use and 1. insufficient working space
maintenance, examination , inspection, repairs, next to the manholes.
and verification .
Figure 1.2.2.5
On all four main objectives of the KvI, deficiencies are found. Verification using
technical documents is usually the most time-consuming.
Conclusion:
According to the documents/ Declarations of Conformity / DOCs and according to

the CE-marking, pressure equipment may fulfil the demands of law. A well-
executed inspection can establish whether they are still in accordance with the
law in their final situation, and can eliminate safety risks when possible
shortcomings are established.

I.61
Relevant Aspects for the Integrity and Safety of the Installations
CHAPTER 2 : RELEVANT ASPECTS FOR THE INTEGRITY AND SAFETY OF THE

INSTALLATIONS
2.0. Introduction
In this chapter, a number of technical aspects will be examined in more detail and
attention will also be drawn to some shortcomings in surveillance and regulation.
The following topics are treated in this order: risk analyses, design, materials,
construction, and inspection of pressure-bearing parts, concrete and metal
structures and their coatings, electrical installations, control and safety control
circuits and, finally, fire protection. The main focus points, treated in these
paragraphs, are picked up again in table form in Chapter 4.
2.1. Risk Analyses
2.1.0 Introduction
In what follows, commonly known techniques of risk analysis are presented. First
of all, we would like to point out that risk assessment is a general term for risk
analysis and risk evaluation. Risk analysis is in its turn divided into hazard
identification and risk estimation. It is of the highest importance to clearly
distinguish these steps in every process. What we would also like to point out in
this context is that it is advisable to separate the analysis of risks from their
evaluation. Moving through all these steps motional at once leads to a loss of
quality and a waste of means as well. Because identifying hazards required for
the risk analysis requires different competencies than evaluating them, depending
on the context.
Also important to point out is the fact that the purpose of the risk analysis must
be clearly defined. The techniques of risk analysis and the depth of its execution
differ depending on the purpose of the analysis.
Examples of this difference are, among other things, risk assessment in the
context of the economical directives or risk assessment in the context of the
Seveso directives or the social directives involving explosion protection or safety
of individuals. Between process safety, safety of individuals, and external safety,
there are diverse differences and these require sufficient attention.
For danger identification, the DOW F&EI is an important instrument that allows a
possible (preliminary) hazard assessment. In the context of LNG, there is little
differentiation in the intrinsic hazards other then those based on mass,
temperature, and pressure. In other words, the intrinsic hazards of the product
are well known.
Indexes are mostly employed to allow a comparison between the different

installations of the company and to identify those parts of installation that are
potentially the most dangerous. The most dangerous installations will afterwards
be subjected to detailed studies. Therefore, indexes are rather means to define
further actions than methods to identify preventive means.
It is thus of high importance that the risk analysis focuses on the processes and
the gaps inside and around standards.
In this paragraph, we stress risk analysis, which is a part of risk management.

We do not treat the aspect risk management here.

II.1
2.1.1 Technical Risk Analysis Techniques
In what follows, we present some frequently used risk analysis techniques. Note
that some techniques are limited to hazard identification, and that others can
include complete analysis and evaluation. For the sake of completeness, we are
adding a checklist here as well, that, on the basis of past experience, is ideal and
supplementary from the point of view of risk analysis. The importance of well
drafted checklists should not be forgotten in this context.
• What if – method
• HAZOP – method
• FMEA – method
• Fault tree analysis
• Fact tree analysis
• LOPA – analysis
• Standard EN 1050
• Standard EN 954-1
We will not go deeper into the last two standards right now, since these will be
exhaustively and completely treated in the chapter machine safety. The big
difficulty there is defining what a process installation is and what a machine is.
Other important and necessary instruments are bow ties, cause and effect trees.
A useful instrument to document these is the PLANOP method, which was
developed by the FOD WASO, General Direction Surveillance on Well-Being at the
Workplace, Department Surveillance on Chemical Risks. PLANOP stands for
‘Progressive Loss of Containment’ and is a software-based methodology for
executing loss of containment analysis of process installations. More information
on this can be found on the website www.PLANOP.be.
Before treating the methods above in more detail, a classification of hazard and
risk-identification techniques is mentioned below, with their data requirements
and their output.
Tixier et al. (2002) have, by means of an extensive study of the literature,

inventoried a total of 62 different hazard- or risk-identification techniques. The
methods were classified according to the criteria below:
• Qualitative or quantitative risk analysis

• Deterministic or probability method. A deterministic method determines
the eventual damages (evaluation of consequences). A probabilistic
method evaluates the chance of something dangerous happening. The
combination of both renders the risk.
Then, it is investigated which data are required to apply the method. Seven
groups are distinguished:
• Plans and process diagrams, which contain detailed information on the

installation.
• Properties of materials used in the installation.
• Reactions and processes that occur during installation.
• Probability data and frequencies
• The safety management system
• The surroundings of the company (vulnerable areas, neighbours)
• Standards and codes of good practice

II.2
Eventually, the result of the study is classified according to:
• Actions related to management (organisation, procedures, training).

• Lists of hazards, risks, causes and effects, critically important tasks,
causes of accidents, etc….
• Probabilities
• Classification of hazards
• What if method:
To support brainstorming during a What-if analysis, checklists are often used. The
experience of the team is supplemented by the use of checklists. Sometimes, the
term SWIFT is used for this technique (Structured What-IF checklist).
• HAZOP method:
HAZOP is without any doubt the most widely used hazard identification technique
in the process industry. People work in a multidisciplinary team, and brainstorm
to detect dangers by looking for possible deviations of process conditions. The
team leader guides the team systematically through the piping and
instrumentation diagram (P&ID, also known as Process & Instrumentation
Diagram), using so-called ‘guide words’. These guide words are used at specific,
well-defined sections of the diagram to identify potential deviations of the process
parameters.
There are a number of factors that explain HAZOP’s success. First of all, the
method is applied to a well-defined study object, namely the piping and
instrumentation diagram. Furthermore, HAZOP is characterized by a very
systematic approach. The creative process, that risk analysis is after all, is
strongly supported by the actual questions that are generated by the HAZOP
method and this for every part of the installation to which the method is applied.
However, HAZOP is a verification technique, which limits its application
possibilities:
• In a late phase of the design process, there often remain no possibilities to

implement important changes.
• The typical working method of a HAZOP study still considers the proposed
design as set. It is checked to what extent deviations can lead to
problems, not to what extent deviations can lead to possible ameliorations
of safety. HAZOP is a verification technique and not a design technique.
The prevention measures that are the result of a HAZOP are therefore
often limited to specifying additional safety equipment rather than
optimising the design by applying principles of inherent safety.
Yet this verification study has to be preceded by proper risk analyses in the
course of designing. Those preceding analyses should in principle expose most of
the scenarios, and on the basis of these analyses, a major part of the measures
will already have been determined.

II.3
A schematic representation of HAZOP methodology can be found in Figure 2.1.1:
Start
Select a process
or operating step
Select a process variable or task

(e.g. temp., flow, pressure)
Yes
No
Deviation possible
No
Yes
Hazardous?
Yes
Which adaptations to design Deviation known

No
needed to record deviation? to operator?
No
No
Yes
Which adaptations to design

needed to prevent deviation, to
occur less frequently or to
mitigate possible effects?
Yes
Cost adaptation
No Investigate other adaptations
acceptable?
Yes
All parameters
discussed?
Yes
All equipment of
installation discussed
Yes
Stop
Figure 2.1.1 Flow Diagram HAZOP
The method has been included in IEC standard 61882 – “Hazard and Operability
Studies (HAZOP Studies) – Application Guide”.
• FMEA method
Also called FMEA, “Failure Modes and Effects Analysis”. This technique uses a
matrix wherein all separate system elements, their ways of failing, the effect of
each potential defect on the system itself, on the results of the system and on the
environment of the system, are inserted. The failure mode is a description of how
elements become defect. The effect of a defect is the system response or the
resulting accident.

II.4
Thus, FMEA identifies separate modes of failure that directly result in or are
important contributors to an accident. Human and operational errors are not
taken into account in an FMEA. The method is also not fit to detect combinations
of systematic defects that can lead to accidents. It is a qualitative technique,
whereby time and costs of methodologies are directly related to the number and
size of the systems investigated.
A variant is the FMECA – “Failure Modes and Effect Criticality Analysis”, which
estimates the probability of prevention for every malfunction and the graveness
for every effect. Thus, a risk number is acquired for every failure and
malfunctions can be ranked depending on their risk levels.
The method has been included in IEC standard 60812 – “Analysis techniques for
system reliability – Procedure for failure mode and effects analysis (FMEA)”.
• LOPA analysis:
In what follows we give a description of a semi-quantitative technique for Risk-

evaluation: the analysis of protective layers (LOPA – “Layer of Protection
Analysis”).
During the last decennium, the LOPA technique has developed to become a full-
fledged risk evaluation technique, which allows the user to conduct a relatively
simple risk analysis with little effort. The result is a more accurate estimate of the
risk than when a qualitative method is used. Since this is simple technique, more
complex hazard situations will have to be further investigated with a more
extensive quantitative technique.
These methods will be supplemented with a fault tree, event tree and MORT
analysis.
Some important side remarks:
The use of risk analyses is obligatory and/or recommended by the diverse non-
prescriptive regulations, yet one has to realize the correct relationship and
estimate it in relation to existing and proven standards. Additionally, it is of high
importance that one describes its correct goals by risk analysis.
When conducting a risk analysis, it is of high importance that earlier accidents

and incidents are taken into account, insofar they have not already led to an
adaptation of current standards.
The use of internal and external information systems on major accidents are of
the highest importance in the process of risk analysis.

II.5
2.1.2 QRA and Effect Calculations in the Framework of the SEVESO

Regulations
Important in the context of the Seveso regulations is, among other things, the
conducting of a QRA to translate the risks to the external framework, and to
calculate effects to delimit possible hazardous zones in the framework of external
interventions.
Problem areas in this matter are, among other things, the comparability of the
results in function of the included scenarios, the interpretation of risks and zones.
In view of the uncertainty on the models, a validation of the models and a

comparative study related to the QRA and the effect calculations is necessary.
Preferably, a number of models is used whereof the scientific basis can be shown
by international publications. When applied models are not supported by scientific
publications, they can only be considered as indicative.
The same applies to the effect calculations preceding the QRA. In addition, the
usability has to be taken into account in relation to the emergency planning zones
in the context of the regulations referred to above.
From experience, we know that, in practice, deviations of sometimes 200% can

be established on both effect calculations and calculations of individual risk
contours.
2.1.3 Conclusions
The choice of the method to be applied is (often) free, and can be modified in
function of available data and the installations to be studied. However, it is more
than clear that risk analysis and management has become an essential tool in the
context of European Directives in general and the surveillance on safety of
installations in particular.

II.6
2.2. Design of Pressure-Retaining Parts
2.2.0 Introduction
In the lifecycle of a product, in this case pressure equipment, three phases can be
distinguished: design, manufacture, and utilization. To avoid major problems in
the last two phases, it is important to work accurately during the design phase.
By “design”, we hereby not only refer to dimensioning and determination of wall
thicknesses, but more generally to the specification of all parameters and
procedures that are supposed to guarantee a flawless manufacture and an
uncomplicated use in exploitation. More particularly, the design phase consists of:
- risk analysis
- selection of materials
- general dimensioning and wall thickness determination
- specification of important manufacture parameters (shape, connections, heat
treatments, etc.)
- program definition for destructive and non-destructive examinations
- definition of strength and leak tests
A number of considerations that are important for an efficient design process are
given below.
2.2.1 Design Specification
The design specification is the basic document that contains the requirements or
references to requirements that the pressure equipment has to fulfil. The absence
of a complete and clear design specification or an insufficient knowledge of its
contents by some parties (for example subcontractors) are often the fundamental
cause of problems occurring during manufacture or, later, utilization.
For important installations, the user is responsible for drawing up the design
specifications. Should he not have the capacities and/or capabilities to do this, he
has to designate a capable party himself.
A good design specification includes the following points:
scope of the design and construction
legal context
responsibilities of possible intervening parties
QA-requirements
classification of the components
specification of the construction code & standards (including the applicable
edition)
supplementary requirements in addition to the requirements of the
construction code (for example legal requirements and typical requirements
related to the application)
basic information for the dimensioning and wall thickness determination
- general dimensions
- design pressure
- design temperature (maximum and minimum)
- working pressure
- working temperature
- testing pressure
- weight
- weight fluid component
- transients
- number of cycles
- external loadings on the connections
- wind
- earthquakes

II.7
- dynamic loadings
- loading combinations and acceptance criteria to be considered
properties of the fluid
installation limits (assemblies)
supports
possible degradation mechanisms
prescriptions related to safety (such as overpressure protection)
prescriptions related to in-service inspection
To ensure that all parties take the design specification into account, the basic
documents (drawings, calculation note, material list, etc …) produced during a
project should refer to it.
2.2.2 Responsibilities of the Parties Involved
In major projects, a lot of parties are involved, for example:

Owner
Owner’s Agent
contractor responsible for the realization of the complete installation
(assembly)
manufacturers responsible for the design and manufacturing of the individual
pressure equipment
constructors responsible for the assembly of the individual pressure
equipment
subcontractors of the constructors
suppliers of materials
inspection-organisations and third parties
It is important that the responsibilities of the different parties are clearly assigned
and that there is a good flow of information in-between and inside the parties.
It has to be ensured that there is one individual responsible for the final design
and the realization of the complete installation. He has to ensure that all parties
involved in the project know and respect the applicable requirements.
2.2.3 Application of a Construction Code
The construction code chosen must be fit for the application, for example vessel,
pipe, tank, …
Once the construction code is defined, the requirements relating to the following
flow forth from it:
selection of materials
dimensioning & wall thicknesses determination
qualification of manufacturing processes & personnel
qualification of non-destructive examination methods & personnel
program and criteria for destructive and non-destructive examinations
strength and leak tests
QA/QC aspects
In the design phase it has to be verified that the material specifications, the
dimensioning, the determination of wall thickness, and the manufacturing and
inspection program meet the requirements of the construction code. In contrast
with what is often found, all requirements of a code must be respected and there
can be no mixture of requirements of different codes. The requirements of
a code constitute a coherent whole and it is this coherent whole that ensures that
what is constructed has an adequate level of safety. For purposes of illustration:
construction codes with less strict quality criteria for materials use a lower
allowable stress than construction codes with stricter quality criteria for materials;
thus it is not allowed, unless supplementary requirements are made, to apply
lower quality materials in the framework of a construction code with a higher
allowable stress.

II.8
2.2.4 Selection of Materials
The materials for the pressure-retaining parts have to be chosen from the list of
allowable materials included in the construction code. Furthermore, the specificity
of the application has to be taken into account: high/low temperature, sensitivity
to corrosion, capacity for welding, etc.
For many materials, supplementary requirements in addition to the requirements
of the material standard exist. They are specified in the construction code and/or
the design specification. The material certificates have to show that all
requirements are met.
If materials that were not included in the construction code are used, their fitness
should be checked, taking into account all requirements included in the
construction code for comparable materials. Often these are hardly taken into
account.
2.2.5 Design drawing and calculation note.
During the design phase, the dimensions of a pressure device are defined in the
design drawings. These shall take into account the geometrical limitations
prescribed in the construction code, such as:
central curvature radius in dished heads
knuckle radius in torispherical heads
welding details for mounting pipes, flanges, stiffeners, …
transition angles in the case of wall thickness variations
relative position of longitudinal welds in the case of adjacent cylindrical shells.
The calculation note has to show that the wall thicknesses mentioned on the
design drawings are acceptable according to the criteria of the construction code,
taking into account the loads specified in the design specification. To show the
validity of the calculation note for the application, the former needs to refer to the
design specification and the design drawings on which it is based. In addition, it
has to contain sufficient data to allow an independent review by a third party.
2.2.6 As-Built Designs
The as-built drawings take into account the deviations of the final product from
the design drawings. If these deviations are outside the tolerances the individual
responsible for design needs to verify whether the final condition still meets the
design criteria. More particularly, the calculation note needs to be reconciled with
the as-built drawing. This important verification is all too easily ignored.
2.2.7 Specifications
The following specific parameters are to be compared with the requirements of

the code during the design phase:
preheating before welding
heat treatment after welding
material requirements for low-temperature applications
forming with or without heat treatment
program for non-destructive examination
In view of the importance of these parameters, it is advisable to mention
them on the design drawing.

II.9
2.2.8 Conclusion
In order to avoid problems during the fabrication and the utilization of the
equipment, it is important to work accurately during the design phase. The
following points are important for an efficient and correct design process:
availability of a complete and comprehensible design specification
clear assignment of the responsibilities among the different parties
application of the construction code in a coherent way
consistency between the data in the different design documents
agreement between the calculation notes and the as-built drawings

II.10
2.3. Materials for Pressure-Retaining Parts
2.3.0 Introduction
To gain a better understanding of what can go wrong with materials, it is

important to first go over the selection process of a designer or manufacturer,
who chooses his materials from the perspective “fit for purpose”, or, in other
words, selects according to application or according to resistance against stress.
In the context of the design and fabrication of pressure-retaining parts, the basic
materials of the components are of fundamental importance.
Materials are primarily selected relative to the expected function of the pressure
equipment, this often consists of a combination of different parameters, such as:
- sufficiently strong and resistant to external and/or internal pressure;

- resistant to high or low temperatures;
- intended for gases, fluids, granulates…;
- resistant to one or more of the several types of corrosion;
- resistant to erosion
- resistant to radioactive radiation (does not become brittle);
- resistant to ageing
- resistant to creep
- resistant to vibration, fatigue, temperature variations, pressure variations,
water hammer …;
- resistant to chemical attack;
- etc…
Next, the part is dimensioned by performing a calculation conforming to the

applicable standard or code, by executing a bursting test, or (for some parts that
are standardized such as tubes or flanges) by selection from a catalogue.
Finally, the material is ordered with mention of the material specification or

standard, if need be supplemented with specific requirements of the customer.
The availability of materials on the market and the price of these materials may
influence the eventual choice of materials here. Thus, some customers wrongly
choose the application of a construction steel (for example type EN 10210
S355J2H) instead of steel for pressure-retaining parts (for example type EN
10216 P355NL1).
The kind and type of certificate required is also important to mention in the order,
and may depend on different factors.
The different types of material certificates can be best illustrated by use of a
European standard. Other, non-European certificates can often be relatively easily
associated with this.

II.11
2.3.1 Certificates
The European standard EN 10204 distinguishes between four types of material

certificates:
1. A 2.1 certificate
A document wherein the manufacturer declares that the products supplied are
conforming to the requirements of the order without mention of possible
testing results.
A document wherein the manufacturer declares that the products supplied are
conforming to the requirements of the order and wherein he presents testing
results from non-specific tests.
This means that the products supplied are not necessarily those inspected or
tested , and that these inspections and tests are carried out according to the
manufacturer’s procedures and not necessarily those determined in the
product specification.
A document drafted by the manufacturer wherein he declares that the
products supplied are conforming to the requirements of the order and
wherein he presents testing results.
The tests to be carried out are those determined in the product specification,
in official regulation and the associated requirements and/or in the order.
The document is validated by an authorized representative of the inspection
service of the manufacturer, one who is independent from the production.
A document drafted by two parties, on the one hand by an authorized
representative of the inspection service of the manufacturer, one who is
independent from the production, and on the other by an authorized
inspection representative appointed by the customer, or an inspector
appointed by official and applicable regulations. In this document they declare
that the products have been delivered conforming to the requirements of the
order. This document also contains testing results.
Type 2.1 and 2.2 certificates are often used for less important (read: less risky)
applications (for example in the European Directive for Pressure Equipment
97/23/EC for category I equipment or for other than the main pressure-retaining
parts in category II, III and IV equipment).
Type 3.1 and 3.2 certificates are actually identical content-wise, except that in
the case of a 3.2 certificate a third party is involved who has to ensure conformity
of the order together with the material manufacturer.
The involvement of a third party obviously has its implications. On the one hand
these interventions always come at a cost, and on the other a specific reception
and inspection is at stake here, something that can impact the tests to be carried
out and the delivery time.
To partly deal with these issues, sometimes an upgrade of the material delivered
with a 3.1 certificate is carried out. Here, the 3.1 certificate is, by sampling or
not, confirmed in the presence of the third party. In case the results of the
inspections and/or testing are confirmed, an equivalent 3.2 certificate is drafted.
This procedure is convenient for bars, plates, pipes, … but is more problematic
when cast or forged pieces are involved.
Due to the production processes of such materials, more attention needs to be
given to aspects such as the traceability of heat numbers or lots of heat
treatments.

II.12
The 3.2 procedure with intervention of a independent (and neutral) third party
does not only give more guarantees of intrinsic quality (read: conforming to
material specifications), but also gives an additional guarantee as to traceability
and origin of the material.
However, as we will see later on, a 3.2 certification, for different reasons, does
not always offer the guarantees expected of it.
As mentioned above, legislation can be determinating. This is the case, for

example, for the European Pressure Equipment Directive 97/23/EC.
This directive connects the choice of the type of certificate for the main pressure-
retaining parts with the statute of the material manufacturer.
For material manufacturers whose quality system is approved by a competent
body established within the European Community, it suffices that the materials
are delivered with a 3.1 certificate.
In simpler terms this means that the material manufacturer possesses an ISO
9001 certificate covering a quality system for the fabrication processes needed for
this type/grade of material. If these requirements are not met, the material
manufacturer has no choice but to deliver the materials with a 3.2 certificate.
Certain certification institutions have eagerly used this to make money. Thus,
many European, but especially non-European, material manufacturers got an
offer to check and certify their quality system, specifically for use within the
European Pressure Equipment Directive 97/23/EC. When the assessment was
positive, they became holder of a certificate of recognition as a material
manufacturer within the scope of this Directive. From our market experience, it
appears that many, especially non-European material manufacturers were duped
by this. Due to their lack of experience and knowledge of the Directive, especially
in the beginning of its application, they gladly made use of the “help” offered.
Fact is that such a certification is not required at all, and what appears from the
practical examples given later is that many of these certificate holders, especially
those in India and Southeast Asia, even have no idea of the value of such a
certificate.
In other cases the type of certificate is set in the construction standard. Thus,
section III of the ASME code requires that materials for pressure-retaining parts
are delivered with a CMTR. CMTR is an abbreviation for Certified Material Test
Report, and is actually a type of 3.2 certificate where a third party, appointed by
the customer, functions as an “authorized inspector”, a qualified and recognized
third party specifically in the scope of this application.
Materials are not always bought straight from the material manufacturer. Too
small amounts of too many different kinds of materials could cause unacceptable
and unreal times of delivery and prices.
In these cases suppliers that buy and store important stocks of materials to sell
them later to the final users, are called upon. Needless to say that, particularly as
traceability is concerned, it is of exceptional importance that such suppliers are
very careful in handling the identification of materials and with the appended
certificates.

II.13
2.3.2 Our Experience: Deficiencies and Shortcomings
The following are a number of examples of deficiencies and shortcomings that we

have gathered during the last years from different experiences, and that can be
specifically related to materials and material certification.
For deontological reasons and because confidentiality is a criterion on which our
accreditation is founded, the names of our clients, the material manufacturers
and/or suppliers involved in different cases, are kept secret.
- Upgrade of pipes, diameter 3/8”, sch 160 in ASME SA 182 316L for a nuclear
application.
Description of the problem:
Due to the relatively small quantity needed, material with a 3.1 certificate was
purchased. Due to the necessity of guarantees on the quality of the material,
it was decided to run all tests and inspections required by the material
specification and by the order on every pipe length (of 6m).
The pipes were all supposed (and certified) to belong to the same heat
number and the same lot of heat treatment. On review, it was seen that for a
number of pipes the intergranular corrosion test was insufficient. In view of
the homogeneity of the lot this was theoretically impossible.
Cause:
At the degreasing after fabrication (this is accomplished by submerging the
tubes with a basket in a bath) it was shown that, at regular times, tubes were
not entirely flat in the basket, which was why one of their extremities was not
degreased. The carbon in the oils and fats used in the fabrication were left
unneutralized on those loci and diffunded between the granular borders of the
steel during the following heat treatment, which caused a number of tubes
showing an unacceptable structure.
- Flanges in ASTM A105

Description of the problem:
As a result of an incident (brittle rupture of a flange, diameter 24”, class 600
lbs in ASTM A105) in a petrochemical company, the Belgian institute for
welding technique started an investigation of the brittle fracture behaviour of
this material.
Twenty flanges were purchased of different diameters, classes, and of
different origins, with a 3.1 certificate for all flanges.
From the results of the testing program that, among other things, provided for
the confirmation of physical and chemical characteristics as presented in the
appended certificates, it was concluded that:
one flange was not a ASTM A105 material at all, and another’s chemical
analysis was not in compliance with the specification;
for more than 40% of the flanges the minimally required tensile strength
was not achieved
for a major part of the flanges (more than 40%) the announced heat
treatment was not or incorrectly performed, something that results in an
actual larger grain size.
the carbon equivalent of the flanges was systematically higher than the
one presented in the certificates; this results in a lessened weldability of
the flanges (increases of the sensitivity for cold cracks and hardness;
the impact values in the certificates were significantly higher than those
measured on the flanges
Cause:
Mostly uncarefully performed heat treatments. See annex 3.1.
- Audit reports of material manufacturers on request of manufacturers and end

users with the purpose of assessing whether these organisations are capable

II.14
to proceed to 3.2 certification. See annexes 3.2 and 3.3. As is apparent from
the reports and conclusions, it is not evident for these organisations to
demonstrate sufficient competence and trust, despite every possible ISO
9001s and other certifications.
- Upgrades of pipes, fittings and flanges with a 3.1 certificate in the context of
the Belgian gas regulations.
Of the 96 different heat numbers tested, 21 had to finally be declared
unacceptable because the mechanical test results were insufficient, 2 had to
be declared unacceptable because of defects in the material, and 1 had to be
declared unacceptable because of dimensional shortcomings. More than
twenty percent of the materials were thus rejected because the testing results
of the 3.1 certificate were not conforming to reality.
As an illustration the annex 3.5 contains some remarkable results:
• Item 2, heat number 180RZ: both the results of the tensile test as those of
the impact tests were insufficient.
• Item 5, heat number 201RV: the results of the impact tests are insufficient
• Item 71, heat number 106781: anomalies in the chemical analysis
- Inconsistency in testing results.

Results of impact tests on material retaining from the same heat number and
tested under identical conditions vary from excellent to acceptable to
completely unacceptable in relation to which organisation carries them out.
See annex 3.6.
- Edited certificates.
In annex 3.7 a 3.1 certificate is included that dates from May 6, 1996 and yet
refers to the European Pressure Equipment Directive 97/23/EC (only effective
from November 29, 1999 onwards). The composer of the certificate is even
presumptuous enough to mention that his organisation was certified by a well-
known qualified organisation for supplying materials conforming to this
Directive. It is a pity that the certificate also cannot be withheld for other
reasons because this kind of material can only be used for structural purposes
and not for pressure-retaining equipment.
- Copied certificates.
In annex 3.9 two 3.1 certificates are included of different manufacturers for
material with the same heat number. The results are simply copied from one
certificate to the other, yet in this process, the temperature of the impact
tests suddenly changes.
- 3.2 certificates
Annex 3.4 features a 3.2 certificate of a third party, drafted on the basis of a
3.1 certificate distributed by the manufacturer. One notices that the third
party has simply copied the results of the mechanical tests and the chemical
analysis to its own document. Furthermore, there is no mention of the
different heat numbers included in the 3.1 certificate and a mistake occurred
during the copying of the dimensions. (For item 1, a wall thickness of 2.87mm
and a pipe length of 9m is indicated, where the 3.1 certificate indicates a wall
thickness of 3.91mm and a pipe length of maximally 6m.)
Additionally it was established that on the same day, the same inspector
drafted more and different 3.2 certificates for materials produced in different
locations.
From the explanation of this internationally active third party (and Recognized
and notified Body), it seems that, in February 2006, they do not yet apply the
2004 edition of the EN 10204 standard. This explanation is supposed to be
part of a justification why this organisation, in a 3.2 certification, did not

II.15
witness the sampling nor attended any tests, being content to just copy the
information of the 3.1 certificate to a 3.2 certificate.
However, their arguments do not make sense, because the previous 3.1.C (an
outdated name for 3.2) certificate in the previous edition of the standard was
identical.
The 3.2 certification which was supposed to offer additional guarantees
therefore has absolutely no added value in this case, but is on the contrary
misleading, thus producing the opposite of the effect desired.
2.3.3 Conclusions
Despite the importance to be able to have materials that are in compliance with
the specifications while the mechanical characteristics are taken into account in
the design, we have seen here that, in practice, they are sometimes handled
carelessly and irresponsibly.
ISO 9001 certificates or other approvals based on a general evaluation of the
quality system of the manufacturer does not really offer an added value here and
do not provide a final guarantee of the quality and conformity of the materials.
The most important reasons why things go wrong are carelessness and partly
also incompetence or ignorance of the manufacturer. But, we also see that third
parties are not always innocent and sometimes adopt, as a way of profiling
themselves or because of market pressure, methods that certainly not have
positive effects.
In practice, there is no watertight solution, or the whole fabrication process
should, from the preparation of the steel up to delivery, be under supervision of
an independent and reliable third party, something not only utopic, but also
unpractical and unaffordable.
It remains clear, however, that 3.2 certification still offers more guarantees than
3.1 certification. Fact is that in such cases only sufficient supervision and
assistance in key operations has any chance of identifying deficiencies.
Of course, more (external) quality control affects costs and times of delivery,
which both are primordial parameters in the contemporary, liberalized market.
Yet a consensus will have to be reached to ameliorate the current situation. Only
then can situations as those presented in the annexes be avoided.

II.16
2.4. Non-Destructive Testing on Pressure-Retaining Parts
2.4.1 Impact
Often manufacturers consider non-destructive testing as investigations that being

not a part of the production process only cost money.
However they form a relatively important step that has to be appraised with great
knowledge and can offer much added value.
2.4.2 The Method and Techniques
The codes utilized identify and define the deficiencies established for different
kinds of products, mainly for welds.
These are divided in groups and are mentioned, for example, in ISO 5817
(EN 25817).
These deficiencies must be detected, interpreted, and finally evaluated.
Depending on the functionality of the products, a threshold level is defined that
determines acceptance or rejection.
The non-destructive analysis consists of 3 parts:

a) the visual investigation
b) application of surface techniques
c) application of volumetric techniques
a) Visual Investigation
The first investigation with which the department Quality Control (QC) is charged,
is the visual investigation of the equipment and of possible welds.
No measure or analysis equipment is necessary, except possible extra lighting,
instruments allowing a better vision, and/or accessories to determine the
dimensions of the deficiencies.
The conformity with drawings and the dimensions of the welds have to be
checked.
b) Surface Investigation
Then the surface investigations begin: dye penetrant and/or magnetic particle
testing.
The dye penetrant testing works according to the principle of the capillary
attraction in the holes of the surface whereby these are filled with a penetrating
fluid. After removing the superfluous penetrating fluid remaining on the surface, a
second product (the developing product) is applied. This extracts the penetrating
fluid out of the holes and makes it more visible by creating an effect of contrast
(coloured penetrating fluid on a white background) or fluorescence (fluorescent
penetrating fluid activated by UV-rays).
In magnetic particle testing (magnetic current circulating in a ferromagnetic

material), deficiencies on the surface (and depending upon the method of power
generation, also deficiencies just below the surface) can be traced by showing a
magnetic leaking current. The fine magnetic particles (iron filings) make this
leaking current visible by forming a chain of small magnets attracted to this
current and directed by it. Visibility is enhanced, just like in dye penetrant
testing, by creating an effect of contrast (grey particles on a white background)
or fluorescence (fluorescent particles activated by UV-rays).

II.17
c) Volumetric examinations
Finally, there also volumetric examinations.
Here we need to distinguish between radiographic and ultrasonic examination .
Radiographic examination
In radiographic or gammagraphic examinations, roentgen beams (X-ray)

(generated by the electrons of an electric current) or gamma beams (γ-beams)
(broadcast by an ionising source) are used, beams that can penetrate the
materials and make deficiencies visible by a varying absorption of the beams by
the material. Places where there is no material present, do not absorb, whereas a
very compact material such as lead absorbs heavily. The amount of beams that
reach the radiographic carrier (a negative film consisting of silver salt which
becomes black when beams strike it) will thus produce intensity variations of the
black discolouration and presents differences in density of the material. A lack of
welding material, porosity, slag inclusions that are less absorbing (three-
dimensional deficiencies) are therefore readily apparent; lacks of fusion and
cracks (two-dimensional deficiencies) can become visible, when their surface
(almost) coincides with the transmission axis of the beams.
Ultrasonic Pulse Echo Analysis
Ultrasonic examination works according to the principle of the transmission of

high frequency sound waves (0.5 to 15 Megahertz) sent by a piezo-electric
generator and transmitter through the material to be inspected. In opposition to
roentgen beams however, these beams have a faster transmission as the material
gets more dense. An internal or surface deficiency produces a break in the
transmission of the waves and works like a mirror, reflecting the waves.
Depending upon the shape, dimensions, and orientation of the reflector, more or
less waves are reflected to the transmitter that functions as a receptor as well (or
to which a receptor is attached) and the two waves can then be compared on the
oscilloscope.
Using a calibration block with artificial defects well known in position and
dimension, it is possible to compare the detected imperfections and judge their
acceptability or not.
2.4.3 Procedures and Qualifications
An examination must be adapted, reliable, reproducible, and must lead to an

unambiguous conclusion based on the defined criteria.
Adaption.
Method and technique must be selected taking into account the product to be
controlled and the deficiencies to be investigated. A device in rust-free steel
cannot be controlled for surface cracks by means of a magnetic analysis, because
this kind of steel is not ferromagnetic and the investigation will therefore reveal
nothing.
Reliability.
If all steps of the preparation and execution of the examination are executed by
meticulous employees trained for this purpose (adapted training that is regularly
refreshed) and who are experienced (with the product and the method), the
usage of an apt method and technique must lead to reliable results. The vision
and experience of the operator are of decisive importance, because half of the
analyses conducted stand or fall with human interpretation and evaluation.

II.18
Reproducibility.
An examination conducted on a moment M1 by operator O1 and supported by
report R1 must be executed again on a moment M2 by another operator O2 and
must be supportable by a report R2 that must be completely identical to R1. The
qualification of the operators and the procedure for applying the technique are
absolutely necessary for reproducibility. Essential variables are defined and
calibration blocks exist for all available techniques to guarantee and control
reproducibility.
Thus, it is necessary to employ written procedures in conformation with a code

recognized and accepted by the diverse parties and for which the quality level has
been clearly defined.
Only qualified operators are (fully or partially, depending on their level of
qualification) authorized to apply the techniques and interpret the detected
indications.
2.4.4 Advantages and Disadvantages
Since different types of analyses (visual, surface, or volumetric) exist, it is

immediately clear that the selection of the method to be used should not be
random.
If a certain choice is not demanded by the construction code, it should be guided
by the review of a series of factors such as:
- the design (suitability of the equipment, choice of construction code,
safety of individuals and of the installation, …),
- the base materials (quality of the material, generic defects of the product,
…),
- the calculations (loading methods that influence mechanical integrity,
rolling direction of the material, safety factor of welding, …)
- the methods for welding and for heat treatment (generic deficiencies in
materials and in welding processes that can be directly connected to each
other, the necessity or non-necessity of a heat treatment and its
execution, execution of certain non-destructive examinations before
and/or after treatment, …),
- the overpressure coefficient for the hydrostatic tests,
- the necessity to conduct a non-destructive examination or not after a
hydrostatic test.
Examinations must always begin with visual examination before surface and/or
volumetric examination. If no specific surface and/or volumetric examination is
requested, the visual one should be unavoidable.
One does not begin an investigation for a weld when this one is too small or
incomplete, or one of which the welding slag have been insufficiently removed; a
magnetic examination cannot be performed on non-magnetic rust-free material; a
welding too thick for the requirements of the code must be ground off before
radiographic examination is conducted; an ultrasonic examination is impossible
without a review of the drawings to take the geometrical features of the zones to
be investigated into account.
Dye penetrant testing has the advantage that it require not much material and no
external power, but temperatures under 10° centigrade or humid circumstances
can impair the testing or even render it inexecutable. Products packaged with
aerosols and solvents damage health and environment and also create an
explosion hazard.
For the magnetic particle testing an electrical power source is always needed
(permanent magnets excepted: however, this is a rarely used technique about

II.19
which there is a lot of controversy), a somewhat heavier material that guarantees

better traceability of linear deficiencies and/or deficiencies just below the surface
but not open to the surface.
For the two kinds of surface investigations, the use of fluorescent products
improves the visibility of very small deficiencies, but for this a UV-lamp is
obviously necessary. But in this case, natural lightening must be strongly limited
and electric, burn and glare hazards have to be taken into account.
Examinations with roentgen and gamma beams are conducted with material that
weights tens of kilos and involves generation of very intense and strongly
penetrating electromagnetic beams for the industrial application. Its safety aspect
(ionising radiation!) is without doubt its most disadvantageous element, but this
type of examination produces good results in tracking three-dimensional
deficiencies if application limits are respected (materials, thickness of the material
relative to the type of radiation and the type of radioactive isotopes, freezing of
not desirable beams, sharpness of the granule on the film or the resolution of the
digital equipment …).
Flat deficiencies such as lack of fusion on the bevel or between layers are more
often found by coincidence because the detection of them depends on the
deviation angle between the direction of the beam striking the film and the plane
on which the deficiency is located: the closer the angle is to zero, the better the
deficiency’s visibility.
As to documentation and inspection, radiographic examination has the advantage
that an image of the deficiencies can be saved and consulted after the execution
of the analysis and even during the lifetime of the equipment.
However, deficiencies such as lack of fusion become very nicely visible by

ultrasonic examination … in as much as the choice of sensors and the measuring
direction are suitable on the basis of the geometry of the welded whole (as a
reminder: waves reflect on the external walls or on the deficiencies, like our
vision does on a flat or bent mirror or facet mirror).
When considering the ultrasonic method, a number of settings and parameters
have to be taken into account, rendering these examinations technically more
complex and more demanding in knowledge and experience.
For common steel types, it can be assumed that the ultrasonic examination is a
supplement for the radiographic examination, and is even capable of replacing it.
Because the equipment for the ultrasonic examination is becoming lighter and
lighter, and at the same time more and more sophisticated on the level of
electronics, it no longer requires an external energy source for a regular workday
nor constitutes a hazard or risk for the safety and for the environment.
In many cases automatic or semi-automatic ultrasonic examination (AUT) is the

most ideal investigation method. The example of TOFD (Time of Flight Diffraction)
is telling in the sense that in almost every case deficiencies found in the volume
of the weld can be detected and measured in height and length.
For documentation and inspection, AUT examinations have the advantage that an
image of the deficiencies can be saved and consulted after the execution of the
analysis and even during operation of the equipment.
With the development of more recent AUT methods such as Phased Array,
multiple ultrasonic techniques can be combined. TOFD, for example, is an ideal
technique to detect and measure deficiencies in the volume of the weld, but is
relatively weak on the internal and external surfaces. A combined TOFD / Pulse
Echo analysis uses TOFD for volume and Pulse Echo for surface, making it
possible to acquire the best analysis results.

II.20
The operators need to have the required experience on the levels of knowledge of
materials and production methods, welding processes and general and specific
deficiencies caused by this. This experience is required to utilize the most apt
techniques for detecting deficiencies.
The costs tied to the examination cannot influence the price of the inspected
products negatively, but have to be judged on their proper value. Sometimes
they are ridiculously low relative to the possible costs on products that are
damaged by a lack of investigation or tampering with the examination.
One also cannot attempt to reduce training, competence of operators, quality of
products and of used materials to minimize construction costs.
2.4.5 Examples from Experience
Are non-destructive examinations infallible and do they have to be accepted

without any reserve or surveillance?
As was mentioned succinctly earlier in this text, every method has its area of
application and its limits and incompatibilities.
Below are listed some examples of flagrant or more concealed deficiencies that
are often found:
Magnetic particle testing
- A magnetic particle examination is executed on a weld between carbon

steel and rust-free steel (the zone was ground evenly and nothing shows
the difference between the two materials): analysis shows a minor crack
between the carbon steel and the weld, a crack the operator removes,
while this indication was only due to the abrupt difference in magnetical
characteristics of the different metals present in the whole.
The same phenomenon can occur for a welding between non-alloyed
carbon steel and lightly alloyed steel.
- A magnetic particle examination for a certain zone must be conducted in
two directions, more or less perpendicularly, in view of the orientation of
the magnetic field. The intensity of this field must be controlled with a
Berthold cross, a Kastrol indicator, a measuring of the field with a Hall-
effect, or another means of calibration rendering known indications: in this
way, the chain of examination is checked and it is demonstrated whether a
technique is fit for the analysis one wants to conduct. A too low intensity
shows no indications, a too high intensity reveals (structural) parasitical
indications that threaten to hide true indications.
- Some techniques demand the application of magnetic inks during the
period of magnetization and before the end of it, to prevent that the
spectrum generated by the magnetization is washed out. The
interpretation and evaluation must be conducted before every new
magnetization.
Penetrant Testing
- Before a penetrant testing, the whole surface of the part to be controlled

(obviously made from non-porous materials) must be thoroughly cleaned
using a degreaser to remove all fatty products that can prevent
penetration of the “penetrating” product. When the surface is not
degreased, the penetration product will not humidify the full zone and
grease stains will appear on the surface.

II.21
The temperature of the part cannot go higher than a certain level,

otherwise the penetration product will evaporate in the holes and no
indications will become visible; therefore, the part must remain humid
during the entire penetration.
- Removal of the superfluous penetrating fluid has to be meticulous,
allowing no penetrating fluid to remain, because this would lead to a non-
contrasting background (for example: with cast products) that could hide
small and fine deficiencies of the type of microscopic rips.
Cleaning must, however, not be done overzealously, causing the
penetrating product to be washed away in the holes; for penetrating fluids
that can be removed by low-pressured water, the water can be directly in
contact with the surface under scrutiny; but solvents can only be applied
to a cloth or on absorbing paper and cannot be poured directly on the
surface.
- Not too much and not too little developing product should be applied,
otherwise there is the risk that the deficiencies will not become visible and
contrast too little, or are just hidden beneath a too thick layer.
- For every step of the penetrant testing the durations (evaporation of
solvents, application of penetrating fluid, removal of traces of penetrating
fluid by means of solvents, development time) are clearly defined or have
to be defined on the basis of technical knowledge.
- When a step was skipped over, the whole procedure needs to be repeated.
- Products of different brands cannot be mixed: the manufacturers
determine the compatibility of products to optimize performance.
- No concessions on the quality of the products: some development products
can be syrupy or runny, penetrating fluids can evaporate very rapidly, and
others have a very unpleasant smell. The aerosols contained in sprays are
being systematically withdrawn from the market at the moment, just like
the petrol-based carriers that have to give way to those that are water-
based, which, regrettably, are less sensitive.
Radiographic examination
- Roentgen examination has been in many cases replaced by a

gammagraphic examination. Despite the great weight of the material to be
transported (X-ray equipment: 50 kilos; source container: 25 kilos; film
with lead-screens; lead lettering for identification; ejection mechanism for
the source, …), an isotope source is easier to manipulate and less likely to
be damaged by falling. An isotope source can even be used in “tube racks”
or in the field where no electricity is available.
- The primary disadvantages are:
• the necessity to build in a safety zone for all techniques at the
moment of the examination and to coordinate the simultaneous
presence of the employees,
• the radiation danger when the source is injected outside of its
container while the X-rays are stopped during the power
interruption of the station,
• the transport regulations for hazardous products,
• the lower sensitivity of the Rγ-film in contrast to RX-film (sensitivity
for detection of deficiencies is smaller for γ-beams than for X-rays.
- More particularly, the inspector and researcher must devote more
attention to the following elements:
• the correct thickness of the penetrated wall,
• the quality of the film (granular size that determines the lighting
period),
• the correct choice of the image quality indicator and its positioning
with respect to the inspected wall,

II.22
• the geometrical blurriness determining the distance between the

source and the film and the lighting period,
• the unambiguous identification of the element and of the zone of
which a radiography is made
• the quality of the film development
- The inspector is often faced with problems related to:
• the density of the film (image too dark or too light)
• the sensitivity (the required wire or opening of the image quality
indicator is invisible while being determinative for qualification of
the whole chain of the technique)
• differences when interpreting indications,
• …
- The inspector must make sure that the non-conforming deficiencies were
actually repaired and were checked again, and obviously the film
representing the area of reparation must be shot again on the same place
of the same weld (always analyse and compare both films at the same
time).
- The exposure period cannot be shorter than 30 seconds because, although
a more powerful source needs a shorter lighting period, it demands a
longer ejection period, namely the (useless) period between exiting the
container and arriving at the extremity of the ejection canal. During this
ejection period, the source is uselessly striking the film, producing a blur
that lessens the contrast. Therefore, it is recommended to keep this time
as short as possible in relation to the useful exposure period.
- The care expended on manipulating films before and during development
and drying, the purity of the baths and racks, the respect for temperatures
during the soaking in each of the baths, the absence of light bursts before
development, are of crucial importance to obtain a quality film.
Ultrasonic examination
- The preparation of ultrasonic examination requires attention and care, and

the respect for a number of preparatory steps:
• knowledge of the geometry of the piece or of the welded whole
(material, manufacture, blunting, thickness, angle of the sloping
edges, curving, welding process),
• choice of sensors (angle, type transmitter-receptor, type tandem
transmitter + receptor),
• calibration of the basic times,
• calibration of sensitivity,
• use of DAC-curves (diagram of the curve of the amplitude/distance
on the basis of a certain calibration block) or AVG-curves (reflection
technique, using a number of amplitude/distance curves on
normalized reflection plates),
• calculation of the transfer,
• side and direction of the investigation,
• speed of the investigation,
• technique for determining proportions
• reference level, evaluation level, acceptance level.
- Clearly, a written procedure is necessary, describing the crucial variables
and other elements for the correct application of a technique.
- The fitness of a procedure, and obviously also the competence of the
operators, are more and more considered as crucial by specialists. Three
possible axes can be distinguished here:
• the application to a large number of parts (expensive technique
requiring a lot of time),

II.23
• technical justification (very thorough knowledge of the

configuration and of the technique, less errors, fast, not always
simple),
• the model design of the investigation.
- Errors and (non-intentional or intentional) deficiencies are possible during
ultrasonic examination; it is clear that an investigator who carries out
ultrasonic examination has to possess solid experience and knowledge of
materials, practical experience with this method and a training that is
regularly repeated; every analysis can be a reason to remain vigilant over
the knowledge and to question competencies.
2.4.6 Conclusion
It is clear that the execution of examinations has to happen thoughtfully,

meticulous, but also realistically and economically. Furthermore it is required that
examination procedures have to be submitted for approval to specialized
technicians of an independent inspection body and that in the field, surveillance
has to be maintained on the application of these examination procedures, such as
with all other special techniques (welding, heat treatments, …).

II.24
2.5. Electrical Installations
Here we provide an overview of problems based on our experience in the

surveillance of electrical installations belonging to complex industrial installations.
A number of points require our specific attention whereby a distinction is made
between points of interest, shortcomings and problems established at the
workplace and more administrative problems.
2.5.1 Administrative Problems
• The documents not conform to the “as built” situation (for example drawings,
cable calculations, …)
• Absence of or missing ATEX-certificates of the different components
• Zoning file not drafted in advance, but only after construction of the
installation.
The points mentioned above are mostly due to a lack of communication and
absence of pre-existing agreements.
2.5.2 Inspection
• Inspections are required for partial installations. In view of the size of the
installation, it is not always evident to keep track of what has been inspected
and what has not. In addition to this, the inspected installation can be altered,
making the inspection report no longer conform with reality. It is of great
importance that the EDTC (External Service for Technical Inspection) keeps
good track of the work performed and that after the work is done, inspection
can commence immediately. Also important for the inspections is to call upon
a limited amount of people who have been continually present on the
construction site to better keep track of the work done. If the inspector only
comes by afterwards and half of the construction is already invisible, it
becomes very difficult to perform a (good) inspection. Therefore we strongly
advise the constructor to let the EDTC (External Service for Technical
Inspection) follow the construction closely from the beginning.
• The quality of the work performed is so questionable that every component

has to be inspected after being connected. Although the design office of the
contractor is often aware of demands relating to the execution, the trouble is
often caused by a lack of communication between design office and
technicians.
• Erroneous connection of ATEX-components because the technicians are

unfamiliar with working with this kind of material.
• Use of branching boxes with a U-certificate (component-certificate) without

CE-marking.

II.25
2.5.3 Organisation
The EDTC (External Service for Technical Inspection) can be appointed by both
the contractor as the subcontractor.
If the EDTC is appointed by the subcontractor, conflict might occur because in
this case commercial interest may prevail. Because of this, the EDTC (External
Service for Technical Inspection) is better appointed by the contractor to
guarantee an independent surveillance.
2.5.4 Conclusions
From the above, it clearly appears that, for a good tracking of electrical
installations, which have an important contribution to the safety of the complete
installations, a number of preconditions have to be met:
- The EDTC (External Service for Technical Inspection) is best appointed by the
contractor to guarantee its independent surveillance.
- The inspectors involved have to be present on the construction site almost
permanently.
- It is very important to have good agreements in advance and to communicate
these agreements to all people involved.

II.26
2.6. Concrete Structures
2.6.1 General Remarks
Recent experience teaches that hidden deficiencies can occur with major projects
in The Netherlands. From a census taken from bridge experts, for example, it is
clear that these hidden deficiencies often had negative consequences for
structural safety, utility, and durability of the bridge construction.
In Belgium, a so-called insurance contract with ten-year liability is usually
concluded when dealing with major projects. To acquire this insurance, an
independent technical inspection is required and at the delivery of the work a
statement of approval is drafted that allows the work to be insured. But also if no
insurance is concluded after the works, a technical inspection can offer added
value.
A hidden deficiency can be defined as follows:
All deficiencies in the structural parts of the work that are due to errors in design
or competency or materials that were unknown during the statement of approval
and the delivery of the work. This term also refers to deficiencies caused by
defect or malfunctioning water tightness of both structural and non-structural
parts of the work.
The purpose of the inspection is to reduce the chance of hidden deficiencies to an

acceptable level. Usually this service is described in the Netherlands as Technical
Inspection Service (TIS). This service is employed to reduce the chance of hidden
deficiencies after completion of architectural constructions.
The completion of the service requires an inspection of the design, inspection
during the construction and a statement of approval. During these checks and
inspections, hidden deficiencies are searched for that are related to structural
safety (Ultimate Limited State - ULS) and to hidden deficiencies connected to the
usability (Serviceability Limit State) of the construction. In addition, aspects are
considered that may negatively affect the structural safety and usability during
the lifespan of the construction (durability). Finally, contact areas of the
construction with neighbouring objects and contact objects such as neighbouring
buildings and constructions are surveyed, as they might cause hidden
deficiencies. The TIS is employed to conduct risk-focused inspections directed at
the design and execution documentation of the constructions and contact objects
and for conducting risk-focused inspections during execution. The task of the TIS
is more specifically focused on delivering a statement of approval when the work
is complete. One of the activities to achieve this is gathering relevant information.
Additionally, checks and inspections are conducted with the purpose of damage
prevention causing a quality amelioration of the work and reducing the chance of
hidden deficiencies to an acceptable level.
For the construction of an LNG terminal, where the architectural constructions are
important and subject to very different loads such as those described in the EN
1473, a TIS can also be useful.
Beyond the scope of the TIS are the works that have to be performed by or in the
name of the client in the context of design and realisation of the construction
project, such as making the design products, contractual management,
realisation of the work, representation of the client or (other technical)
surveillance within the framework of the execution. These works are performed
by other contractors.

II.27
When performing the TIS, the following basic assumptions are used:
The TIS works objectively and independently
The TIS indicates to the building contractor during the phase of (contract)
execution which drawings and documents are needed for the execution of its
duties and which period is needed for the appraisal or inspection.
The TIS hereby takes into account the planning of the project and the nature and
extent of the work.
The inspections of the execution of the work are conducted in conformation with
the planning of the contractor. For this purpose, the TIS has the planning –
including the execution planning – of the contractor at its disposition;
The TIS gets access to all locations (construction yards, workplaces).
The works the TIS conducts for the delivery of the statement of approval can be
divided into two phases.
2.6.2 Phase 1: Tender Phase
The first part of the works involves the design of tender documents. The tender
phase can be based on a complete design by architects or design offices or on a
design-and-build procedure. On the basis of an analysis of the question
specification and a risk scan on the designs or the initial design, a sufficient
quality level of structural safety, usability and durability of the initial design is
aimed for.
Depending on the way of tendering, the client drafts a number of contractual

pieces during tender preparation, which can be a question specification (a
demand specification) or a complete design.
A question specification is the input in the tendering procedure with which the
work is put on the market. The TIS reviews a number of relevant contract pieces
for possible limitations vis-à-vis the delivery of the statement of approval.
In case of a complete design, the TIS is conducted from the beginning of design
activities. During the different phases of the design, the TIS will judge whether
the design conforms with applicable standards (Dutch, European …) and
directives (CUR-reports …).
More specifically, an assessment is carried out whether the design conforms to

the specifications and load combinations that are set down in the EN 1473 in the
context of the design of an LNG terminal. Also, the review of the design with
specifications in the different eurocodes (concrete, steel, steel-concrete,
foundations …) that are specifically related to the design of a LNG terminal is
conducted.
Especially the covering of certain typical risks related to installations using LNG
are meticulously tracked. The typical attention points for these installations are:
- correct assumptions of load conditions and combinations of loads such as
settings the soil, temperature, wind, earthquakes …,
- the limitation to settings in the soil and freezing of the soil (risk of tension in
the soil),
- the cryogenic condition and the influence of this on material behaviour (risk of
brittle fracture) and this especially when applying pretensioned concrete
elements on possible leaks,
- occurrence of condensation (internal condensation) and subsequent freezing
when dealing with tanks,
- risk of corrosion of concrete in corrosive marine environments.

II.28
In the case of a question specification and the possible consequence of the tender
procedure with a competitive dialogue that is often divided into a number of
phases, the TIS conducts a risk scan and appraisal of submitted designs in every
phase.
After the appraisal of the submitted materials is complete and the economically
most advantageous submission has been found, a clarification round will take
place to establish the “durability” of this submission. Here, the TIS will indicate on
which points it sees a increased risk in relation to the possibility of acquiring a
statement of approval. It will indicate this on the basis of a risk scan of the
submitted design belonging to the economically most advantageous submission.
After every phase of either design or procedure with question specification, the
TIS will draft an analysis report to allow the designers to adapt either the design
or the submission documents. This report usually contains the following
elements:
- short project description or technical description of the part of the work
the report is about
- overview of the documents involved in the analysis
- overview of the checks conducted on the design
- overview of the review of the calculation designs employed by the
designer, basic assumptions, load assumptions and method
- risk of hidden deficiencies
- potential exclusions of the statement of approval
- synthesis and advice on design and execution risks related to the
statement of approval
2.6.3 Phase 2: (Contractual) Execution Phase
The second part of the work is aimed towards the (contractual) execution phase
of the design.
These works are performed to establish whether the statement of approval can be
truly acquired, which means that the work has been designed and built in such a
way that the risk of possible hidden deficiencies related to constructive safety,
usability and durability of the work has been reduced to an acceptable level.
a) Inspection of Design Documents
The appraisal of design risks is often realized by risk-oriented inspection of the

design documents. Because in practice the design documents are drafted in
phases, inspections will usually also be made in phases.
The inspection involves the risk on hidden deficiencies and includes at least:
- checks of the design’s basic assumptions;
- checks of the construction in relation to the applicable standards and
directives, legislations and regulations;
- checks of the calculation models employed by the designer, basic
assumptions and load assumptions (including standards);
- checks of environmental factors that can directly influence the risk of
hidden deficiencies in the work;
- the inspection must take into account the computer programs used and
analyse the applicability of these computer programs
Just like in the design phase, reports are made of the phased risk-oriented
inspection of the design documents.

II.29
b) Inspection execution documents
The appraisal of the risks of execution documents takes place by means of risk-
oriented inspections of the execution documents.
The inspection of the execution documents includes at least checks of:

- execution drawings, execution calculations;
- specifications and quality declarations of the construction materials to be
used;
- quality plans and work plans;
- inspection plans and inspection reports;
- requests for modifications;
- deficiency reports;
- certificates of used basic materials and used materials;
- certificates of required certification processes.
Should a potential deficiency be established, the client will be informed of this as

soon as possible.
After reception and inspection of the received documents as indicated above, a

report is drafted indicating possible deviations from the quality required or
making no remarks at all.
c) Inspecting and Appraising Risks During the Execution of the Work
The purpose of inspecting and appraising risks of the execution of the work is the
timely identification of inadequacies in the work that can lead to possible hidden
deficiencies in the context of the statement of approval.
Activities conducted in the frame of appraisal of the execution of the work:

- Conducting inspections on the construction yard.
- Conducting inspections on other locations where parts of the Work are
produced.
- If necessary, attendance of construction meetings.
- Conducting discussions on applicable technical solutions.
- Conducting discussions on appropriate measures.
- Reporting the results of the inspections.
- Drafting the statement of approval.
Inspections of the work are conducted in conformation with the applicable Arbo
legislations and regulations.
Inspections take place on the construction yard or on other locations where parts
of the work are produced.
Inspections are conducted in such a way that the risk of possible hidden
deficiencies is minimalized.
Inspections are conducted regularly.
The number of inspections, their frequency and time is determined on the basis
of:
- the nature and extent of the work;
- the risk scan
- a self-performed risk analysis of the work
- the research reports, design and execution documents;
- inspections already carried out.

II.30
At certain times, the TIS imposes stops. At these points, the contractor may only
continue working when the inspection is completed on location. This is particularly
important for the inspection of placement of important reinforcement or pre-
tension cables before the pouring of concrete is commenced. The same applies for
placement isolation or vapour-limiting isolations before grouting or the like are
applied for the construction of tank walls or floor plates.
Inspections include all risk-related aspects of the work.
A report that indicates which parts of the work were inspected and whether any
remarks were made related to the execution is drafted after every inspection.
When deficiencies are serious, the client is informed as soon as possible.
d) The Final Report and the Statement of Approval
The final report contains the following items:

- information of the client and all parties involved in design and execution
(client, architect, engineer, contractor);
- description and location of the work;
- risk analysis of the work and appraisal of the risk;
- synthesis of inspected design plans;
- synthesis of inspected stations in the contracting (all elements related to
the contract);
- synthesis of the design process and execution of the work;
- overview of parts of the work not yet approved and possible conditions for
eventual acquisition of this approval.
2.6.4 Examples of Common Problems Established During the Execution

of TIS
a) Foundations
A common problem when calculating foundations is the deduction of allowed

tensions from the results of the soil testing. A first observation here is that often
the reference point taken in the execution of the testing and the one used later
on in the plans do not match. During the execution of the testing, the condition of
the terrain is often different from that in a later phase of the project, since there
are still things to be torn down or ground to be levelled, for example. Since soil
testing is the basis for the design of foundations, it is of high importance that it is
calibrated with the design plans.
A second common error involves the design of pile foundations on limited
information, usually when pile foundations are required and soil tests have not
been conducted deeply enough. Sufficient data has to be available of the soil
below the pile foundations and sometimes a local hard layer is present that is
insufficiently thick to place the piles on but that has nevertheless stopped the
tests. In such a case, some designers wrongly assume that such a test is
sufficient.
When calculating supporting power, it has to be made sure that the method used
is consistent. In the past, and in many cases still today, no safety factor was used
for the loads for calculating the foundation and known safety measures were
assumed to perform the design of the foundation itself. One thus needs to pay
attention not to calculate using non-weighted loads but to use the safety factors
for the design of the foundation conforming to the eurocode method.

II.31
b) Structures
When calculating supporting structures in concrete or steel, extensive computer

programs are often used these days. To judge the results of these programs, it is
always useful to make a simple calculation check manually for a single load case.
This is particularly and primarily important for judging the interpretation of
computer results. It has happened that this is done erroneously and that the
reinforcement in a concrete structure is drawn on the wrong side of the structure
in the reinforcement plans. The calculation check also gives an idea whether the
order of magnitude of the results is correct.
Afterwards, it has to be checked whether the assumed loads and combination
have been inputted correctly. Especially the correct input of the indicated
combinations conforming to the EN 1473 is important. The input of the loads and
combinations is primordial since the complete manual calculation of all possible
combinations is impossible.
2.6.5 Conclusion
From the above the important role of independent technical inspections during
the different phases of the construction of concrete structures becomes clear. The
quality of these inspections can be the determining factor for the reliability and
safety of the installations.

II.32
2.7. Metal Structures
2.7.1 General Remarks
Steel structures are important elements in complex industrial installations and

often imply high investments. This is so because the malfunctioning or collapse of
these structures can cause great damage. Deficiencies that are perceived only
late can also lead to extra high repair costs.
Industrial steel constructions essentially undergo the same risks as concrete
structures. The approach method for controlling these risks is therefore roughly
the same.
During their lifespan, these structures undergo different loads that are also
variable in time. This implies that these structures have to possess a certain
resistance to withstand these loads and to fulfil the functions they have been
designed for during their entire lifespan.
The different loads on a steel structure can be:
- Permanent static loads such as for example dead weight.

- Variable loads such as for example the useful load of floors and supply depots.
These are also considered permanent and static.
- Climatological loads such as wind and snow. These are considered static and
occasional.
- Exceptional loads such as earthquakes or collision of travelling crane bridges.
- Dynamical loads such as loads caused by hoisting equipment.
- Chemical loads such as corrosion.
- Fatigue.
- Ageing.
Coupled with these loads there are the possible ways steel structures can fail:
- Passing the elastic limit with plastic, irreversible deformations as a

consequence.
- Passing the breaking strength.
- Passing the limits of allowable deformations (serviceability limit state)).
- Instability phenomena:
- Buckling of supporting columns or slender elements under pressure.
- Buckling of thin plates.
- Crack propagation due to fatigue.
- Corrosion.
- Ageing.
- Wear and crack.
Therefore, it is of the utmost importance that the designer and constructor of

these steel constructions does everything in his power to provide sufficient safety
against all these ways of failure.

II.33
2.7.2 Frequently Occuring Problems in Steel Constructions: Role of an

Independent Third Party
There is often not one unambiguous cause why steel constructions will fail. Most
of the times, it is a consequence of a piling up of blunders, deficiencies or
coincidents. The most frequently occurring deficiencies judging from our
experience are:
a) Design Errors
- Often changes are made to the concept during the design process and even
during the execution. Frequent changes in the concept lead to a heightened
chance of design- or detailing errors.
- The calculation and drawing of steel constructions has been outsourced to
external design offices for ages. These dispose of sophisticated software
packages that can perform all calculations conform to a certain standard.
These days, we are able to calculate constructions that are made just strong
enough. In the past possibilities were less extensive, and larger safety
margins were employed during calculations. Reducing the safety margins
implies that less room is left for small errors or deficiencies during the
execution or montage phases.
- The software packages mentioned above are in fact a “black box”. A large
number of parameters can be inputted and an abundance of results comes
rolling from the computer mere seconds later. These results are often
considered absolute and are not questioned afterwards. Yet a change in
certain basic hypotheses often leads to totally different results. By using this
software, the calculator loses his “feeling” with the construction. The use of
complex software packages can never replace a solid know-how, common
sense, and experience. The usage of calculation software can thus create
dangerous situations.
By inspection of an independent third party, certain problems can be traced early

on and thus damage and major repair costs can be avoided. A third party often
has a fresh method of approach and will not necessarily make the same mistakes
as someone who has been occupied with a project for some time and does not
see the wood for the trees anymore.
This inspection by a third party includes:
- Review of the calculations according to a certain design standard:
- Basic hypotheses
- Load assumptions
- Load combinations
- Analysis of results
- Review and approval of the drawings
- Review and approval of the construction details (bolt connections, weld
connections, placement of certain stiffeners)
- If necessary, a totally new parallel calculation can be performed.
b) Execution Errors
During execution too, all kinds of errors can happen that afterwards lead to
annoying and dangerous situations. One has to try to trace these errors as
quickly as possible and to correct them to minimalize repair costs. Here also, an
independent party can be useful by conducting inspections in the workplace and
during montage.

II.34
Here we are mainly referring to:
- Reviewing whether the last revision of the design drawings is available in the
workplace
- Inspection of the conformity of the execution with the drawings. (dimensions)
- Inspection of the material certificates
- Inspection of the welding preparations
- Inspection of the weldings (possible NDO for critical weldings)
- Correct execution of the connection details, correct placement of stiffeners.
- Inspection of tightening torque of high-resistance bolts
- Geometrical inspections: inspection of flatness and perpendicularity,
alignment of certain parts
- Are montage tolerances met?
- Inspection of certain ergonomic and safety aspects for later users:
- Height and resistance of guard-rails
- Minimum proportions of manholes
- Safe access to machinery
- Correct placement and montage of anchoring points for safety lines
c) Fatigue
In the long term, fatigue is one of the most important causes of the failure of a
steel structure. Fatigue occurs when an element is exposed to a great number of
variable loads. Structures sensitive to fatigue are for example production
machinery, lifting devices, rolling bridges, masts and chimneys. Fatigue cracks
can happen on those places in a steel structure where there are great tension
concentrations. The propagation of these cracks can lead to a rapid degeneration
of the resistance of the affected element and may possibly lead to breakage with
possibly major consequences. These cracks rarely appear in the basic material
and almost always in the vicinity of weldings or connection elements. Especially
weldings are sensitive to fatigue.
Controlling the risks of fatigue demands a specific type of study and a certain
execution of the connections. The basis is a correct definition of the predicted
loads, their frequency, their amplitude and their variations in time; specialists
refer to the load spectrum. The minimal lifespan of the structure can be defined
by the final user as well. On the basis of all this data, the designer can then select
a certain type of connection, taking into account the technical and economical
feasibility of the whole.
The welders are to execute these connections, carefully taking into account the
correct welding procedures to reach the desired stress concentration class.
There is much information on these problems: results of tests in the lab,
university studies, catalogues supplying specific resistances of certain weldings
and finishing details. More specifically this involves Wöhler curves, stress
concentration factors, classification of weldings according to their type and
finishing.
Strain gages are also available to measure stresses in a steel structure near
weldings.

II.35
A strain gage is really a small electrical resistance that is bonded to the steel
structure. By the appearance of mechanical stresses, the electrical resistance of
the strain gage will be altered. By measuring and registering these resistance
alterations, dynamical loads that are hard to determine can be very exactly
defined.
This technique allows a comparison between the behaviour of the structure and
the design hypothesis and thus to make an accurate judgement on the expected
lifespan of the structure.
d) Corrosion
Corrosion is a phenomenon that often appears in structures placed in an

aggressive environment such as the seaside (salt) or industrial areas (acid
environment because of the nearness of chimneys).
In opposition to the standards related to pressure barrels, the European
standards demand no extra material thickness in corrosive environments. It
suffices to apply a specific conservation technique (galvanisation, paint) that is fit
for such an environment.
However, the designer should attempt to avoid zones where water can be still or
locations that are hard to reach for an eventual anti-corrosion treatment.
For internal transverse diaphragms of box girders, it is sometimes attempted to
hermetically shut off these boxes. A air tightness test can then be performed after
completely welding off the box.

II.36
2.8. Coating and Isolation
2.8.1 Objects Exposed to Atmospherical Corrosion
a) Specifications
A qualitatively executed conservation system starts with a good general technical

specification where attention is devoted to corrosion-friendly design.
How often doesn’t it happen that for example a design office gets the assignment
to draft technical specifications and does not have sufficient know-how to do it?
This results in a mix of different paragraphs of other, already existing documents.
Beyond this, the aid of different paint manufacturers is sometimes requested,
manufacturers that each in their turn will try to sell their formulas.
To protect steel structures efficiently against corrosion however, it is necessary

that all parties, starting with the constructor, the design offices, the paint
manufacturers, and controlling organisations, dispose of unambiguous
information on the anti-corrosion protection through paint systems.
Before 1998 there existed an amalgam of national and international standards

that delineated the different aspects of building a conservation system. Luckily
the standard ISO 12944 exists since 1998, a standard that gives all necessary
information in the form of clear instructions.
This standard consists of 8 parts (see reference list).
This standard treats all aspects related to the conservation of steel objects, such
as:
- determining the three categories of lifespans;
- classifying the different environments in function of their aggressiveness;
- concept and corrosion-friendly designs;
- description of different types of soil and their pre-treatment
- description of different types of paint systems and their layer thickness
structure in function of the expected lifespan and the aggressiveness to
which the object will be exposed;
- the manner in which the different systems should be applied,
climatological circumstances, possible labtests to be carried out, how to
track and inspect the work activities, etc…;
- drafting specifications for new buildings and maintenance systems.
To achieve an efficient protection against corrosion, it is important to draw up

clear specifications for an individual project, taking the following elements into
account:
- analyzing or judging of the aggressiveness of the environment in the area
where the object to be conserved will be located (ISO 12944-2);
- evaluation of all environmental factors and special circumstances that
could influence the choice of the paint system to be applied;
- investigation of the concept and design of the structure with special
attention to avoiding corrosion-sensitive zones, galvanic corrosion by
isolating one of the different metals, etc. (ISO 12944-3);
- evaluation of the condition of the surface to be protected for maintenance
painting (ISO 12944-4);
- identification of painting systems in function of the selected durability in a
certain aggressiveness class (ISO 12944-5) or on the basis of the results
of performance tests in the laboratory when the painting manufacturer
cannot present proof of long-term durability (ISO 12944-6);

II.37
- choice from the selected painting systems, taking the different possible
manners of surface preparation into account (ISO 12944-4);
- minimizing the damage to the environment and all risks connected to
safety and hygiene (ISO 12944-1, ISO 12944-8);
- drawing up a work program and selecting an applicable method (ISO
12944-7);
- drawing up a control program during and after the work activities (ISO
12944-7, ISO 12944-8);
- drafting a maintenance program for the entire lifespan of the conservation
system.
b) Vendors
Once good and workable specifications are available, these are added to the order
to all vendors. They are requested to conserve according to these specifications
and possibly present their own coating procedure with selected painting system
for approval.
It is here that a second problem emerges: rarely do we get a vendor specification
that is completely in conformity.
Not all existing standard (housing) specifications of manufacturers of valves,
tanks, coolers, pipes, prefabs, equipment etc… are already in conformity with the
standard mentioned above. Some keep on working as of old, with non-adapted
standard procedures and using painting products from the manufacturer round
the corner.
The consequence of this is that many vendors ask for variations on the
specification; a time-consuming activity for he/she that has to qualitatively assess
these deviations to the directives of the existing specification.
Luckily, more and more constructors that have their objects conserved are
adapting their methods and systems to the ISO 12944.
2.8.2 Isolated Objects
The standard ISO 12944 is only partially applicable to the conservation of isolated
objects. All specific aspects related to the isolation itself, such as for example the
design and choice of painting system in function to design temperature, are not
described there.
That is why we will go deeper into the matter here.
Corrosion under isolation causes much damage because this degradation is

invisible and the corrosion process can thus continue unnoticed for a long time.
How is this form of corrosion to be combated or, even better obviously, to be
prevented?
To make a beginning with the answer, we will start by looking at prevention.
An important condition for efficient prevention of corrosion is a good cooperation
and attunedness between the different areas in the study and engineering
services.
In fact, combating corrosion, also under isolation, starts on the design desk.

II.38
a) Designing Critically
During the design phase, it is to be taken into account that painting and isolation
have to happen on the spot.
Difficultly accessible locations are therefore to be avoided as much as possible.
Supports to benefit isolation of pipes and devices should, in cooperation with
designers and isolation specialists, be installed beforehand and not during
construction.
Sufficient space has to be provided to allow for a good installation of isolation and
plating.
Valves have to be placed in vertical pipes as much as possible. Then, they can be
isolated by water draining. In case that a valve has to be placed in a horizontal
pipe, the spindle should whenever possible be placed horizontally instead of
vertically. Furthermore, valves should always be controllable from steps or
ladders; this prevents walking on the isolation.
No flat steel rings should be used for an isolation welded directly against a pipe or
device. These rings can then work as collecting places for moisture etc. and thus
cause serious corrosion. It is better to apply clips or loose, circular rings.
Especially for stiffening rings connected to devices working in a vacuum, a good
detailing of the isolation has to be provided because these places are very
sensitive to corrosion.
Cold bridges are to be avoided. It is also wise to have as much equipment as
possible painted and/or isolated by the manufacturer of said equipment, since the
quality obtained will almost always be superior then conservation systems and
isolations applied on location.
All the points mentioned above point in one direction, which is: an isolation or
painting system, too, requires design, either in combination or separately.
Further focal points related to applying the isolation are: apply as many
prefabricated isolation materials as possible; this is faster, cheaper, and the
material lasts longer.
Isolation material for cold application needs to be prefabricated in the workplace
as much as possible and needs to be finished through use of a tape or foil, to limit
vapours. Only montage seams need to be finished on the spot.
It is valid at all times that as much work as possible should be completed in the
workplace, especially in winter!
b) Choice of the Painting System
Conserving under isolation is a “must”. But what is, exactly, a good painting
system under isolation?
All big producers of painting products for industrial applications have their own
specific formulations. Multiple factors have to be taken into account to make a
well-founded selection from the painting products.
Here we mention a couple of those factors:
The isolated environment can become very aggressive (certainly on the seaside),
just consider accumulation of salts, namely chlorides during the becoming wet
and drying of the isolation. Furthermore, salt traces are hygroscopic and thus
retain humidity longer, therefore exacerbating the corrosion.
When dealing with rust-free steel from the AISI 300 series, for example, the risk
of stress corrosion, a crack-forming corrosion influenced by mechanical pulling
stresses, needs to be taken into account. Two things can be done here: painting
or aluminium foil wrapping; Aluminium has the advantage vis-à-vis rust-free steel

II.39
in that it has a cathodic operation, just like zinc with steel. If one chooses to
paint, this is to be done with a “zinc-free” product.
For example, for highly alloyed steel objects with carbon steel parts (supports or
flanges), use one system both for carbon steel and for highly alloyed steel, this to
prevent mistakes. For this purpose, select a painting system that is chosen for
the highly alloyed steel.
“A painting system, too, requires designing!”
c) Paint under Isolation: General Remarks
Despite all well-selected materials for isolation and paint, things can go wrong in
practice. What is the cause of this? The durability of a painting system in the
construction phase is completely dependent on a good surface preparation.
External circumstances such as the weather, time pressure, etc. should be
prevented from affecting the execution of the work. When the whole system is
applied as prescribed in a single time, this prevents many problems.
One painting system will almost never fail because of the paint itself, but almost
always because of other circumstances such as insufficient surface preparation,
environmental temperature, relative humidity and product selection in relation to
(natural) environment, object temperature, nature of the object material, and
method of application.
d) Selecting the Isolation System
Experience teaches that isolation systems, when inexpertly applied, can cause
corrosion damage. All isolation materials for industrial applications available on
the market have their specific good features. Use these during the application of
the materials.
For example, for warmth isolation a soft material needs to be used, such as wool
types. For cold isolation, hard materials such as extruded or foamed construction
elements are preferable.
So when is hard isolation to be applied, and when soft?
As soon as the operating temperature of a system is constantly lower than the
environmental temperature on the location, a hard isolation material with a
vapour-limiting finish, is to be applied.
Should the operating temperature of a system be constantly higher than the
environmental temperature and require isolation, then a soft isolation material is
to be selected. This must then be finished using (non-vapour-limiting) plating, to
prevent water percolation.
Again, an isolation system requires designing too!
When dealing with varying temperatures, the best option is a hard isolation
material that can also handle high temperatures; the lowest temperature is the
most determining in this case.
e) Isolating: General Remarks
The system or object to be isolated must be dry, free of dirt, rust etc. and it has
to be painted. The isolation to be applied must also be clean and dry. When
dealing with multiple layers, the isolation must be executed in half-brick skin and
should be applied tightly using a wire or hand (of rust-free steel).
Instead of using kit to render the plating watertight, the preference should
strongly be to design water-draining structures.

II.40
Heat isolation, as mentioned earlier, should not be finished vapour-limiting with

kit or tape. The isolation should be allowed to breathe, the moisture in it should
be able to get out, if not this will cause major problems.
When applying the plating, finishing the isolation with plating material,
precautions can be made to avoid corrosion problems. Here, a so-called roof tile
construction can be achieved by making the plates overlap in a correct manner,
an effective aid. Furthermore, much attention needs to be devoted to tops of high
towers and vessels; a segment top might be pretty, but a pointed top is simpler
and has less seams.
When finishing tank roofs or tops of high towers and vessels, synthetic fibre, such
as a laminated fibreglass-reinforced synthetic fibre that renders a completely
seamless finish, can also be used instead of metal plating.
On places where the isolation still has to be stepped upon, an isolation material
with a higher load density can be applied, finished with, for example, aluminized
steel plates.
Before repairing plating, the paint system has to be checked for corrosion.
Possible corrosion needs to be treated. Not repairing established rust damage
under plating is obviously not an option.
f) Determining the Degree of rust
The determination of the rust degree is a visual determination of the quantity of

rust on a painted surface.
The German standard (DIN) and the corresponding international standard ISO
and the “European Rust Scale For Determining the Rust Degree of Steel Surfaces
Covered With Rust-Protecting Paint” can help us with determining this rust
degree. These standards utilize photographic material. By comparing the photo
and the object, we obtain a rust degree that is expressed in Ri-values of 0 to 5 for
the DIN 53210/ISO 4628 or an Re-value of 0 to 9 for the European rust scale.
The European rust scale uses 10 and the DIN/ISO uses 6 divisions.
For evaluating an object, a rust degree of maximum Re2 is normally allowed.

II.41
The table below compares both standards.
Rust Degree According to

European Rust Scale DIN 53210/ISO 4628- Evaluation
3
Re 0 Ri 0 Rust free
Re 1 Ri 1 0.05 %
Re 2 Ri 2 0.5 %
Re 3 Ri 3 1%
Re 4 - 3%
Re 5 Ri 4 8%
Re 6 - 15/20 %
Re 7 Ri 5 40/50 %
Re 8 - 75/85 %
Re 9 - 95 %
Figure 2.8.1 shows two rust degrees, namely Re 0 en Re5
Figure 2.8.1
Comparison of two rust degrees

II.42
2.8.3 Painting on-site – Focuses
a) Start-up on-site of the Painting Activities
The location of the blasting and painting halls on-site has to be as strategically
possible to avoid unnecessary displacements during the conservation process. But
oftentimes these halls are makeshift “cabins” that in no way contribute to the
quality of the blasting and painting work.
A decently conditioned hall is certainly no luxury.
b) Climatological Circumstances
The period for conducting painting work is fixed in principle. A painting season
starts in March and ends in September. The ideal is that the construction is
planned in such a way that the finishing can be done in summer. But experience
teaches that this is not always possible because of several factors. Once
September comes closer, we find that the “paintable hours” are reduced
drastically due to condensation, rain, etc.
Should one still desire to conserve in this period, this is only possible by
sufficiently protecting zones to be painted. Every professional, self-respecting
team thus has to dispose of the necessary measurement and registration
equipment to anticipate climatological circumstances.
c) Blasting Work
According to the paint specification, a certain roughness profile should be

achieved. Not all types of blasting means fulfil prescribed criteria.
For work activities executed in a blasting hall, a type of blasting means such as
steel grit or grain is often used. These types can be recycled. The danger is that
blasting means’ integrity is compromised, something that can cause serious
adhesion problems in the coating process. A regular check of the blasting means
is certainly appropriate here.
When one is blasting on location, meaning the construction yard, one uses a one-
time blasting means. These are limited by law, and often the type olivine is
selected. Before the blasting work can commence, a good protection should be
provided. Not only for safety concerns but also for gathering remains to conform
to the applicable environmental standards.
Before application, a decent de-dusting has to take place. In the workshop this is
normally not a problem. On the yard and certainly if there is to be blasted
between the installation, it is often found that dust and impurities are painted in.
d) Application of the Coating
Oftentimes the coating is applied with airless equipment. On the construction

yard, this is not always feasible. That is why it needs to be clear that the number
of layers to be applied manually can be different from airless application.
Most painting systems will be presented by the manufacturer as airlessly
applicable. By employing this painting system with roll and brush, the desired
layer thickness cannot always be achieved, thus necessitating the application of
extra layers.

II.43
e) Tracking and Coordinating the Work
Inspection is seen by many as an extra cost that is often forgotten during

meetings on the contract. Correct agreements must be made about the beginning
of the work. But all too often we see that a part has already been done that is
very difficult to evaluate afterwards. Certainly with the assemblage of
construction parts, the painting system is often abused. That is why it is certainly
recommendable that only qualified staff perform the work activities.
f) Working Heights
It is not to be excluded that several work tasks have to be conducted on high

locations. Scaffolds designed for different tasks are not always useable for
painting work. Scaffolds for blasting and painting jobs need to be further away
from the objects than, for example, they have to be for some mechanical tasks.
Should there be no adapted scaffold platforms present, then one often finds a
self-modified scaffold that can endanger security. For some tasks, tower wagons
bring relief.
g) Choice of Painting Manufacturers
During the preparatory phase, certain painting systems have been set by the
constructor. Often, the type of paint is named after the binding means such as,
for example, a two component high build micaceous iron oxide. Since there are
different paint manufacturers offering these products or their alternatives on the
marketplace, it is recommended to choose only one of them. If not, a mix of
systems is acquired that cannot guarantee compatibility among each other. Some
form of guarantee and responsibility is impossible in this case. If this is not
feasible for the entire project, one can choose to divide the construction yard into
zones with each its own paint manufacturer.
Conservation and isolation are often the last to be discussed, sometimes a few
days before the completion date.
These two techniques are often treated negligently.

II.44
2.8.4 Practical Illustrations How Not To Do It
Coating under isolation.
It is necessary to choose an
adapted painting system.
Corrosion beneath isolation is

often discovered too late.
Detail of corrosion beneath

isolation.

II.45
Mill scale.
Pipes and fitting parts should be

treated in an identical way as
described in the specification.
Stagnation of water.
Design has to make sure that

stagnation of water is
impossible.
Use of different materials.
Different materials can be used

underneath each other if they
are isolated from each other.
Uncoated materials are certainly
not an option.

II.46
Sendzimir treated steel.
This method of galvanization

is not fit for a marine
climate.
The galvanizing layer is
about 15 to 20 microns.
Hot dip galvanized pipes.
Pipes that are hot dip

galvanized can only be
attached to each other by
flanges.
Thermically galvanized pipes.
After welding thermically

galvanized pipes, these have
to return to the galvanisation
factory.

II.47
Thermically galvanized “baskets”.
These “baskets” cannot be

welded without burning the hot
dip galvanization.
Painted hot dip galvanized steel.
Is also called a duplex system.

If attached well, this system can
double the lifespan.
Zinc slag and impurities often

cause a non-closed painting
film.
Chain intermittent welds.
To prevent corrosion, all weldings

have to be fully executed.

II.48
Reference List
ISO 12944-1 : Paints and varnishes - Corrosion protection of steel structures by

protective paint systems - Part 1: General introduction.
protective paint systems - Part 2: Classification of environments.
protective paint systems - Part 3: Design considerations.
protective paint systems - Part 4: Types of surface and surface preparation
protective paint systems - Part 5: Protective paint systems.
protective paint systems - Part 6: Laboratory performance test methods.
protective paint systems - Part 7: Execution and supervision of paint work
protective paint systems - Part 8: Development of specifications for new work and
maintenance.

II.49
2.9. Fire Safety Industrial Installations
2.9.1 Fire Safety – Overview by Aspect
This chapter offers an overview of the focus points and inspection approach
concerning the most important aspects of fire safety.
The structure of this paragraph is standard for fire safety:

- passive fire protection
- active fire protection
- organisation
- integration of the three previous topics
Preventive and repressive measures are tied to each one of these sections.
When designing a new industrial installation, the accent is often on controlling

risks by use of technical means and it is sometimes forgotten that the choice of
these technical means implies a certain organisation. To render this clear, an
extreme example: it is conceivable to design and build a safe industrial
installation that only has manual detection and extinguishers, yet this will make
heavy demands on the organisation that supplies the required manpower.
An illustration from practice:
- At some industrial sites, only some installations are protected by sprinklers.
For fire extinguishing, the stress is mainly on manual extinguishing
installations that are available everywhere on the location, such as
permanently placed monitors in combination with an extensive and well-
trained and equipped company fire department.
- At other sites, the choice for (foam or not) sprinkler installations is
systematic, and the company fire department relatively more limited than at
BASF.
Another common mistake is the utilization of a series of technical safety

measures that are not reasonably attuned to each other. A classic example from
fire safety of buildings is the “smoke and heat exhaust ventilation system”
(SHEVS) not being attuned with the sprinkler system. The SHEVS can cause the
sprinklers to reach their operational temperature too late or not at all because of
the venting of heat.
In short: the guidelines for the planned organisation have to be set during the
design phase together with the technical guidelines.
a) Prevention and Repression
As applies to safety in general, the approach to fire safety consists of

prevention and repression.
A1) Prevention
The purpose of prevention is to avoid and control as many risks as possible.

In Belgium the ‘Well-being at Work act’ (cf. ARBO law in The Netherlands)
prescribes the following basics of prevention:
--- beginning of quotation from the “Law of August 4, 1996 Concerning The
Well-Being at Work” ---
Art. 5.- § 1. The employer takes the necessary steps for the promotion of the
well-being of employees in the execution of their work.

II.50
To achieve this, he does the following

a) prevention of risks;
b) evaluation of risks that cannot be prevented;
c) combating risks at their source;
d) the replacement of what is dangerous by what is not or less dangerous;
e) higher priority to collective protection than to individual protection;
f) the adaptation of the work to human capacities, namely as concerns the
organisation of the workplaces and the choice of the work equipment and
the work and production methods, to make monotonous labour and
production quantity-bound labour more bearable and to limit their effects
on health;
g) limit risks as much as possible, taking into account technical developments
and state-of-art;
h) limit the risk of serious injury by taking material measures prior to any
other measures;
i) the planning of prevention and execution of the policy connected to the
wellbeing of employees executing their work in view of a systematic
approach wherein the following elements are integrated: technique,
organisation of work, labour circumstances, social positions and
environmental factors on the workplace;
j) Inform the employee about the nature of his work, the remaining risks
connected with it and the measures aimed at preventing or limiting these
dangers.
1° when he/she is hired
2° every time when this is necessary for the protection of the well-being;
k) providing appropriate instructions to the employees and determining
accompanying measures for a reasonable guarantee of the compliance
with these instructions;
l) providing or ensuring the existence of the proper safety and health signals
on the workplace, when risks cannot be prevented or cannot be sufficiently
limited by the collective technical protection measures or by measures,
methods, or procedures related to the work organisation.
--- end of quotation ---

(free translation from Dutch)
These prevention principles obviously also apply to fire safety.
Safe design of installations related to fire prevention and explosion is treated

in chapters 1.3 and 3.1. This includes, for example, the prevention of
situations in which fires or explosions can happen, such as the prevention of
leaks of combustible fluids, avoiding ignition sources, etc.
In short: the purpose of prevention is to limit as much as possible the chance

of an undesired event occurring.
A2) Repression
Repression implies limiting the damaging consequences of an undesired event

to the lowest level possible.
For LNG this can be achieved by, for example:
- automatically covering an LNG puddle with foam when a leak occurs
- cooling of installations (deluge systems, water curtains) to protect these
from radiation of a fire in a nearby installation

II.51
b) Passive Fire Protection
Passive fire safety of industrial installations is mostly a combination of

compartmentalization and stability during fire and explosion.
Examples:
- “sufficient” distance between different installations on a single industrial
terrain to limit the spreading of a fire and explosion from one installation
to the other, cf. the division in “companies”: every “company” is far
removed from other “companies”, and in that way not only is possible
spreading limited but the spacious intervention paths between the
companies remain available;
- distance in itself is not always enough or feasible, and additional “passive”
measures can be: designing constructions in a way that they can resist a
certain external explosion pressure, building of walls or the construction of
embankments to protect certain parts of the installations, etc.;
- offices, social premises (coat room, showers, dining room,…), and control
rooms are built at a safe distance from the industrial installations and are
where required combined with a design that allows sufficient resistance to
a fire or explosion to render a safe evacuation possible (the catastrophe at
BP in Houston, for example, caused a number of victims by the presence
of contractor-offices between the industrial installations);
- banks around the storage tanks is a form of compartmentalization as well.
c) Active Fire Protection
Detection
Important aspects:
- In industrial installations the detection of the release of inflammable
products is highly important. It allows for action to be taken before a fire
or explosion occurs.
- The fire detection technology has to be adapted to the operating
circumstances (resistant to weather and wind and the influence of the
installations and used products) and to the phenomenon to be detected
(smoke, heat, …). The EN-54–series is at this point in time especially
aimed at detection in buildings and is less fit for open-air detection, in
other words in industrial installations (see list of EN-54 standards in
appendix).
- Especially for detection technology for which no standards exist yet, such
as fire detection through video cameras, it is important to have practical
agreements in advance on the inspection method and criteria.
- Detection systems are used as a trigger for a series of signals and controls
that should render a fast and efficient intervention possible. In addition to
testing the detection itself, the testing of these signals and controls is thus
crucial (cf. below, integration and scenarios).
Automatic Extinguishers
As far as sprinkler systems (foam or not) for industrial installations are
concerned, European standards fall short as well. The NFPA-directives (or the
FM global directives grafted upon it) describe more concretely how industrial
risks can be limited with automatic extinguisher systems. In addition to design
and execution guidelines, the NFPA directives also provide clear maintenance
and testing procedures.
d) Organisation of Fire Safety

II.52
As indicated earlier, during the design phase attention should already be

devoted to the organisation that will be set up around the installation. Should
the organisation not be attuned to the technical means, mistakes are bound to
happen.
Focus points:
- Individuals present in the installation. Permanent / occasional, place,
number, day and/or night regime, …
- Evacuation procedures, emergency exits, means of exiting, entry and exit
controls (cf. has everybody been evacuated?), evacuation team, …
- Organisation of the intervention: internal fire department or first
intervention team, means of intervention, level of training, …
- Fire prevention such as working permits, …
e) Integration of Fire Safety
Integration is often the point where things go wrong.
The scenarios needed to intervene as efficiently as possible in case of fire

must be designed and tested in advance. Both the scenarios for individual
production installations or production units and the scenarios that describe the
mutual influence of production installations on an industrial terrain are
important.
These scenarios include both the passive, active, and organizational

measures, and this for different possible incidents identified by risk analysis.
Another focus point are those parts of the scenarios that are embedded in the
installations via hard- and software.
Important here are the protocols between the different systems (are they
compatible?) and the reliability of their operation.
f) Inspection
A good inspection starts with the design of an installation. At this point, it is

best to already establish how the compliance between the installation and the
directives will be investigated. This should not only allow some practical
organisation, but also to account for the costs of the practical tests.
Some examples:
- Points in the directives that are open to interpretation, are better cleared
out in advance. Last-minute changes because of different interpretations
of inspector and designer can cause huge problems: extra costs,
slowdowns, changes impacting other parts of the installation, etc.
- Practical tests on location: agree in advance when these will take place, by
what means, what criteria, etc. Keep these things in mind, for example:
o testing detection systems with “a test fire” without any preparation or
planning and safety measures before testing are often not executable
o the same goes for testing extinguisher systems, for example deluge
systems, foam extinguisher installations, etc.
o it often happens that fire safety systems are only inspected in the last
phase or are tested in conditions that disallow certain practical tests
(for example because certain parts of the installation are already
operational), rendering a possible modification of the installation
problematic
o testing of inbuilt scenarios such as disabling certain parts of the
installation after detection can no longer take place, for example, when
production is ongoing while it is clear that testing these scenarios is of

II.53
crucial importance; it often occurs that individual safety systems

function correctly but that the interaction between the systems has
been incorrectly conducted
2.9.2 Approach Inspection of complex industrial installations
The given examples are not based on our practical experiences during the
construction of LNG terminals but are based on the construction of other similar
complex industrial installations and discussions with safety engineers and
managers of e.g. LNG terminals.
Some of the most relevant examples:
- Distances between the storage tanks differ to a high degree if one compares
different LNG terminals. On the basis of NFPA directives, the mutual distance
is at least half a tank diameter. The EN standards (see EN 1473 – Annex A)
describe the mutual distances by calculating the radiation heat, for example.
From shared experience it is clear that multiple calculation methods are used
that render strongly differing results.
From the outset of the project, it is thus necessary not only to enforce respect
for a certain standard, but also to describe more narrowly how it will be
applied. For example, which mathematical model to use, which design
parameters, etc. This prevents discussion afterwards and simplifies inspection
on the correct observation of the distance requirements.
- At some terminals, not only is there a bank around the storage tanks, but also
below the pipes and certainly below critical points such as the flanges. In
addition, these areas have been equipped with an automatic fire extinguishing
system using foam. The automatic foaming system is controlled by fire
detection, namely IR-detection. Through a “voting system” between multiple
detectors, the fire extinguish system is rendered operational.
With execution, multiple problems come to the surface, namely:
o In some cases the general contractor that was familiar with things such as
piping and controls of industrial installations, designed and built large
parts of the active fire security himself. Apparently the tender allowed for
this, with as a consequence the application of components and calculation
methods unusual (read: not compliant) for fire safety.
o A number of additional remarks were recorded on various sites:
A normal PLC (later replaced by a safety-PLC) for the detection system
and the control of the extinguishers, while approved systems for this
application exist.
A foaming extinguisher installation that was unsatisfactory in practice,
for example because of self-designed foam spray muzzles and a
wrongly proportioned pipe network.
NFPA 11 (foam extinguisher systems) requires, for example, that the
number of minutes for the completion of the foam coverage, has to be
set in advance. If the NFPA 11 is just imposed without further
clarification of which design parameters are desirable, then the
contractor is left at great liberty in building his installation.
In other words, the inspection of an installation by a third party
produces in that case a number of founded remarks with consequently
important (expensive) adaptations.

II.54
o Conclusion: because of the confusion that existed before on the applicable

directives, fire safety installations were not designed nor installed by a
specialized entrepreneur, according to rules of good conduct for this type
of installations.
- Similar stories surfaced in connection with:

o The deluge-system on the tanks itself.
o The water curtains between the different buildings.
o Powder extinguishing systems
o The waterfogsystem in the generator room.
- Changes in the project design were not converted into necessary adaptations
of the fire safety installations. For example, LNG pipes were moved during the
design phase without adapting the position of the fire extinguishers
accordingly.
To sum up, the following recommendations can be derived from the above:
- Compile the technical directives with care and attention to detail.

- Make sure that specialized companies install the fire safety installations,
conforming to agreed directives, as concerns both possible calculations as the
components and execution on location.
- Provide a good management of design adaptations during the project
(management of change)
2.9.3 Conclusions – Practical Advice
- When drafting guidelines it’s advisable to take into account the following
remarks :
o Compile the technical guidelines with care and attention to detail.
o Make sure that specialized companies install fire safety installations,
according to agreed-upon guidelines and this both for possible calculations
and for components and execution on location.
o Provide a good management of design modifications during the project.
(management of change)
- For the inspections:
o Involve the Controlling Bodies as much as possible in the project.
o For example, let the guidelines be validated by qualified controlling bodies
for the aspects that are relevant to them. Ask what the inspection
procedure will be, so that it can be taken into account.
o Let the design (and its possible modification) of actual installations be
approved by the qualified Controlling Bodies (in other words, don’t wait for
an inspection of a completed installation).

II.55
Reference List
NFPA 1 Fire Code

NFPA 11 Standard for Low-, Medium-, and High-Expansion Foam
NFPA 12 Standard on Carbon Dioxide Extinguishing Systems
NFPA 13 Standard for the Installation of Sprinkler Systems
NFPA 14 Standard for the Installation of Standpipes and Hose Systems
NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection
NFPA 16 Standard for the Installation of Foam-Water Sprinkler and Foam-Water
Spray Systems
NFPA 20 Standard for the Installation of Stationary Pumps for Fire Protection
NFPA 25 Standard for the Inspection, Testing, and Maintenance of Water-Based Fire
Protection Systems
NFPA 30 Flammable and Combustible Liquids Code
NFPA 51B Standard for Fire Prevention During Welding, Cutting, and Other Hot Work
NFPA 54 National Fuel Gas Code
NFPA 55 Standard for the Storage, Use, and Handling of Compressed Gases and
Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and
Tanks
NFPA 58 Liquefied Petroleum Gas Code
NFPA 59 Utility LP-Gas Plant Code
NFPA 59A Standard for the Production, Storage, and Handling of Liquefied Natural
Gas (LNG)
NFPA 68 Standard on Explosion Protection by Deflagration Venting
NFPA 69 Standard on Explosion Prevention Systems
NFPA 101 Life Safety Code®
NFPA 110 Standard for Emergency and Standby Power Systems
NFPA 329 Recommended Practice for Handling Releases of Flammable and
Combustible Liquids and Gases
NFPA 550 Guide to the Fire Safety Concepts Tree
NFPA 551 Guide for the Evaluation of Fire Risk Assessments
NFPA 750 Standard on Water Mist Fire Protection Systems
NFPA 1250 Recommended Practice in Emergency Service Organization Risk
Management
NFPA 1452 Guide for Training Fire Service Personnel to Conduct Dwelling Fire Safety
Surveys
NFPA 1561 Standard on Emergency Services Incident Management System
NFPA 1600 Standard on Disaster/Emergency Management and Business Continuity
Programs
NFPA 1620 Recommended Practice for Pre-Incident Planning
NFPA 5000 Building Construction and Safety Code®

II.56
2.10. Control and Safety Control Circuits
2.10.0 Introduction
Control and safety control circuits are an essential part of the functioning and
security of complex industrial installations. In what follows, we are first going to
situate control circuits and then explore safety control circuits to a larger extent.
These will be illustrated by means of the onion model (Figure 2.10.1) that was
already presented earlier on in Chapter 2.1
Figure 2.10.1 Onion Model
2.10.1 Control Circuits
A control circuit is a control of the normal process conditions concerning process

parameters such as temperature, pressure, flow, …
2.10.2 Safety Control Circuits
In process safety, safety control circuits are located in layers four and seven (see
the onion model in Figure 2.10.1). The purpose of a safety control circuit is to
detect a deviation in the process in relation to normal process conditions on the
one hand and steer the process towards a safe condition on the other. Exceptions
are, among others, manual emergency shut downs (ESD’s).
2.10.3 The Evaluation of an Intermediary Risk
By an intermediary risk we are referring to a risk that is described without taking

the whole installation into account. A distinction is made between control circuits
and safety control circuits. In practice, the risk will be determined including the
control circuits but without safety control circuits. On the basis of the
intermediary risk, a decision is taken on the quality and quantity of
supplementary measures with the purpose of reducing the risk.

II.57
There are different standards that can be utilized for this:
• DIN V 19250 => AK classes (Anforderungs class)

• IEC 61508 => SIL classes (safety-integrity-levels, component level)
• IEC 61511 => SIL classes (safety-integrity-levels, system level)
• EN 954 => BC (steering category)
Experience teaches that supplementary evaluation of intermediary risk is the only

practically feasible method to evaluate and assess all risks.
In the process industry, active measures are divided into control circuits and
safety control circuits.
• Control systems (steering cycles) ensure that the processing proceeds in a

normal, desired manner; (basic process control system = BPCS)
• Safety systems (safety steering cycles) only become operational under
deviant conditions. This ESD can include:
o that further steps in the process are prevented (lockdown);

o that the process can be safely stopped (shutdown);
o that the deviation is undone and that the processing returns to normal,
safe operating conditions,…
Here, the following remarks can be made on the development of ESD systems:
• Passive measures have a higher availability than active measures.

• Autonomous systems have a higher availability than systems that require an
external energy source.
• Material measures allow for a higher availability than procedural measures.
• The availability of systems can be ameliorated by building in redundancies.
• Instrumentation circles or parts of these can be upgraded with a auto-
diagnostic system, allowing immediate detection and fast repair of certain
types of failures.
• When measuring continuously, a change of measuring values gives an
indication of the functioning of the measurement system. With switched
measurements this is not the case. This allows a board operator to make a
permanent diagnose.
Determining the SIL-levels, whether or not together with verifying them, is an

important aspect within the domain of process safety of complex industrial
installations.
SIL Determination:
The determination of SIL levels has everything to do with the establishment of

risk reduction factor. The higher the SIL level, the better the risk reducing
properties. Methods exist to determining the required SIL level of an installation
on the basis of a risk analysis (HAZOP, FMEA…).
IEC 61508/5, annexes C and D, allow us to determine a SIL-level, by using a risk
graph or risk matrix.
It is, however, important to mention that it regards a qualitative approach that
has to be performed by a competent and dedicated team.
Moreover, the possibility exists to carry out the determination of the SIL levels,
based on IEC 61511, annex F, in which is referred to the so-called LOPA study
(Layers Of Protection Analysis). In this case, one person can apply the
determination method on the basis of a quantitative approach.

II.58
SIL Verification:
SIL verification will focus on two fields:
Architectural and functional requirements (1oo1, 1oo2,…).

Probabilistic requirements (probable failure on demand).
On the basis of standards, a device has been developed, explicitly for electrical,
electronic and programmable electronic applications, that allows us, in a relatively
simple manner, to assess and subsequently test, the architecture and failure
probability of a safety control circuit and whether or not it complies to the
assumed expectations (SIL determination).

II.59
Approach and inspection philosophy in the context of the first extension of the LNG Terminal in Zeebrugge
CHAPTER 3 : APPROACH AND INSPECTION PHILOSOPHY IN THE CONTEXT OF THE FIRST

EXTENSION OF THELNG TERMINAL IN ZEEBRUGGE
3.0. Introduction
At the end of the seventies, the interministerial task group “Safety Aspects LNG
Terminal” was founded in view of the construction of the LNG Terminal in Zeebrugge
(Figure 3.1). The purpose of this task group was not only to take care of the license
modalities, but also to establish the safety standards against which the LNG Terminal
would be measured.
Figure 3.1 LNG Terminal Zeebrugge
Thus, the advice of the interministerial task force was included in the final license,
granted by the Royal Decree of August 7, 1981.
In addition to the advice of the interministerial task group, said license also referred
to the Belgian regulation for the transport of dangerous products by means of
pipelines (in short: the Gaslaw) and required the involvement of an Authorised
Inspection Organization to survey the tests, inspections and trials.
For the extension of the LNG Terminal (2004–2008), the advice of the
interministerial task group was asked again. In their report it was stressed that for
the extension the same security principles were to be applied, unless a more
optimalized solution guaranteeing an equivalent level of safety were to be possible.
This time, the advice of the interministerial task group was included in the Ministerial
Decree of September 29, 2004, to supplement and amend the existing transport
license.

III.1
Apart from the safety standards on a local level, different European directives were
also taken into account for the extension of the LNG Terminal, such as the Pressure
Equipment Directive 97/23/EC.
3.1. EPC-contract
No longer is an installation for the storage and/or transportation of natural gas solely
an affair of public utility. Indeed, because of purely economic motivations, oftentimes
a group of investors decides to build an installation collectively.
Since the partners in such a project do not always possess the necessary technical
know-how and experience and/or in view of the fact that financial costs and planning
related to the investment are primordial parameters, such projects are often
outsourced via an EPC-contract.
The abbreviation EPC here stands for Engineering, Procurement, and
Construction.
Within the frame of an EPC-contract, it is the EPC-contractor who is responsible for

the complete realization, from the study phase to the purchase of materials and the
final cooperative construction on the construction yard.
For this reason it is often compared to a “turn key construction”.
For the extension of the LNG Terminal in Zeebrugge too, an EPC-contractor was hired.
Yet it is to be noted that Fluxys LNG, because of their technical know-how and
experience as owner and exploiter of the existing installation, did not give the EPC
contractor total independence. Thus, a whole series of project specifications were
construed above all the legal requirements and obligations, sometimes leading to
far-reaching additional safety requirements. In addition, Fluxys LNG, together with
their engineering service have conducted a great number of additional quality and
conformity checks.
3.2. Quality Control
Quality and quality control are two concepts that are inconceivable to do without in
our contemporary world.
Most companies now have a quality system within which their own quality and
inspection services function. Furthermore, the intervention of an independent
company or third party is possible for the carrying out of certain inspections.
To clarify who exactly fulfills which task, the following will for simplicity’s sake talk
about “internal” and “external” quality control.
3.2.1 Internal Quality Control
a) Actors
Primarily, this is the quality service of the manufacturer or the contractor that
surveys the quality of the work done. In addition, the customer can, if he should
wish so, conduct additional inspections and check the quality delivered.
Within an EPC-contract, the role of customer is fulfilled by the EPC-contractor himself.

For it is he who is responsible for e.g. the purchase of the materials and for whom it

III.2
is, in theory, in his best interest to ensure that these materials fulfill the
requirements made.
Apart from this, the owner or exploiter of the installation can obviously conduct
additional inspections as final customer. All this is schematically represented by the
schematic below. (Figure 3.2).
Engineering
General Design
Specifications Procurement
Design
Fabrication
QC Owner Final Inspection
QC EPC-contractor
Construction
QC Manufacturer
Reception Materials
QC Contractor
Construction
Testing
Figure 3.2
Both for the quality services of the manufacturer or the contractor, as for the
inspection service of the EPC-contractor or the owner, there is a risk that other
elements beside quality and safety influence the final appraisal.
b) Remarks
Indeed, is it even possible for a so-called independent quality or inspection service to

always make objective decisions?
Is it not so that, in the case of non-conformities, an easy solution to accept the
materials as they are is too rapidly adopted without any founded technical reason?
And in what degree do routine, company culture, or the direction committee
influence this decision?
In practice, the amount and contents of inspections performed by the EPC-contractor

are often determined on the basis of the importance of the materials or pressure
equipment involved.
A noble thought, were it not that this importance is sometimes determined by budget
and planning and not by quality and safety. Thus, the question could be posed
whether the planned inspection visits are not more a means of controlling the
contractual obligations of the manufacturer (such as the time of delivery) rather than
a check of quality.

III.3
To what degree, furthermore, do personal preferences such as the attractiveness of

the location where the inspections are to be performed influence the decision
whether or not to perform an inspection visit? Is it not so that in the case of distant
or less attractive locations, a local inspector is all too rapidly hired, of whom it is not
known whether he possesses the required competence and who may be insufficiently
informed of the applicable requirements?
3.2.2 External Quality Control
In contrast with the internal quality control, the external quality control is provided
by an independent institution or third party, both of whom are supposed to have
neither a direct nor an indirect interest in the final results.
When the specific case of quality control of mechanical and pressure-retaining parts
is analyzed, three groups can, in the context of the extension of the LNG Terminal in
Zeebrugge, be distinguished (Figure 3.3):
• The Third Party for the EN 10204 3.2 certification of materials

• The Notified Body in the context of the Pressure Equipment Directive
• The Authorised Inspection Organization (AIO) in the context of the license and
the Gaslaw
Engineering Third Party
General Design
Specifications Procurement
Design
Manufacture
Notified Body
Final inspection
AIO Construction Notified Body
Reception materials
Construction Third Party

Notified Body
Testing
Possible intervention
Required intervention
Figure 3.3

III.4
a) The Third Party
According to EN 10204, a 3.2 certificate is validated in cooperation with the

purchaser’s authorised inspection representative or the inspector designated by the
official regulations.
Thus, without specific requirements, the buyer might designate someone of his own
inspection service or even someone who has not necessarily the required skills as
authorised inspector. But, since the added value of this could be questioned, the
project required the services of a Third Party, accredited according to EN 45004 or
ISO 17020 for the inspections of pressure-retaining parts.
b) The Notified Body
The intervention of a Notified Body in the context of the Pressure Equipment

Directive is determined by the risk category and the conformity assessment
procedure chosen by the manufacturer.
This procedure can be directed at the product, in the case of which the Notified Body
needs to be actually involved in design, fabrication, and final inspection. But this
procedure can also be based upon a quality system, in case of which the role of the
Notified Body is limited to the appraisal of said quality system, which does not make
it necessary for it to physically inspect the pressure equipment ordered.
The Notified Body is designated by the manufacturer of the pressure equipment

involved. Not only is this Body needed to assess the individual pressure devices, but
also to evaluate the assembly during construction on the construction yard.
It is to be noted here that an LNG storage tank, because of its design characteristics,
is not subject to the Pressure Equipment Directive, which is the reason why there is
no intervention of a Notified Body in this case.
c) The Authorised Inspection Organization
The Authorised Inspection Organization is charged with the surveillance of tests,

inspections and trials and intervenes in design, fabrication of materials and
construction on the yard.
In contrast to the Notified Body, which is designated by the manufacturer, the
Authorised Inspection Organization is designated by the license holder. Because of
this, the Inspection Organization can operate completely independently and
unprejudiced vis-à-vis the EPC-contractor, his subcontractors and suppliers.
3.2.3 Extent of the Task
The intervention of the Authorised Inspection Organization involved both the storage
tank and the piping.
For the mechanical and pressure-retaining parts, the following elements were
considered:
Storage tank:
• 9% nickel steel inner tank

• 9% nickel steel corner protection
• Aluminum suspended deck
• Carbon steel liner

III.5
• Roof penetrations
• Filling lines
• Pump columns
• Overpressure relieving devices
Piping:
• Non-cryogenic process piping and accessories (such as valves, pressure

vessels, pumps, etc.) with a maximum operating pressure higher than 14.7
bar
• Cryogenic process piping and accessories with a maximum operating pressure
lower and higher than 14.7 bar
3.2.4 Contents of the Inspections
As indicated earlier, the task of the Authorised Inspection Organization is described

somewhat generally by reference to the surveillance of tests, inspections and trials.
A practical enumeration of the most important inspection activities performed in this
context is provided below:
a) Design
General design:
• Review of the piping classes

• Review of construction drawings
• Review of (flexibility) calculations
Procurement specifications:
• Review of procurement specifications

• Review of datasheets
b) Materials and pressure equipment
Design:
• Review of the design

• Review of manufacturing and controlling procedures
Manufacture:
• Review of the EN 10204 3.2 certificates

• Spot witnessing of non-destructive tests
Final inspection:
• Visual and (through sampling) dimensional examination

• Witnessing of resistance and tightness tests
• Spot witnessing of cryogenic tests
• Review of technical files
c) Construction

III.6
Reception of materials:
• Identification of materials
• Spot visual examination
Construction:
• Review of the welding performance qualification records and the procedure

qualification records
• Spot check of welding parameters
• Spot visual examination of the welds
• Spot witnessing of non-destructive tests
• Review of the welding logbook and the construction file
Testing:
• Witnessing of resistance and tightness tests
3.2.5 In Practice
a) Quality Control
In the context of the extension of the LNG Terminal in Zeebrugge, it was attempted
to perform the task of the Authorised Inspection Organization not only as primary
inspector (by directly attending and controlling certain activities) but, due to the
intervention of different Third Parties and Notified Bodies, also as a general surveyor
with the purpose of increasing the effectiveness of the intervention as Authorised
Inspection Organization and lowering the number of double checks and reinspections.
Practically, this amounted to the fact that the intervention points of the Authorised
Inspection Organization were not merely defined on the basis of legal requirements
and/or the possible additional requirements of the customer, but that the
intervention points of the Third Parties and/or the Notified Bodies were also taken
into account.
Initially, it was, for example, prescribed that the design of the piping would only be
checked after the approval of the Notified Body. For the review of the documentation
of the different manufacturers too, it was predetermined that these would already
have been checked and approved by the EPC-contractor, the Third Party and/or the
Notified Body before these would be presented to the owner and the Authorised
Inspection Organization.
The idea behind this method was to make the parties involved (specifically the EPC-
contractor) take their responsibility.
Practice, however, has shown that different documents that were presented were not
(first) checked by the EPC-contractor, the Third Party and/or the Notified Body, or
that remarks only reached the final manufacturer when it was sometimes already too
late.
The initial intent of basing a number of controls on the intervention points marked by
the Third Parties and/or the Notified Body also proved too optimistic very soon.
Indeed, at the moment when these intervention points were clearly perceived, again
fabrication had often already begun or been completed.

III.7
In general, several reasons for this can be pointed out:
Not only in the extension project of the LNG Terminal in Zeebrugge, but also in
several other projects, a very strict planning is maintained these days, something
that naturally influences the time of delivery of materials. In this case therefore,
insufficient or no room was sometimes allotted for the quality control of these
materials.
Not only time pressure, but also the inexperience and egotism of some persons or
institutions responsible for quality control, are reasons for the fact that these cases
are sometimes approached from a theoretical viewpoint.
On the level of organization, for example, it was asked on multiple occasions to
check calculation notes without the corresponding construction drawings being
available, to check welding procedure specifications without the supporting procedure
qualification records being available, etc.
On a technical level, one easily hides behind clauses that may or may not be literally
included in the applicable directive, standard or specification. The most striking
example of this is perhaps EN 10204, which in the context of the 3.2 certification
does not literally specify that the tests (be they through sampling or not) should be
attended by the Third Party.
All this, combined with the eventual establishing of different lacks and shortcomings,
necessitated a correction of the prescribed inspection approach and an eventual need
for more inspection visits than was initially provided for.
b) Quality Assurance
External quality control is of course not infallible. As was indicated earlier, it is

primarily the manufacturer or constructor who has to provide the necessary quality.
In the context of the extension of the LNG Terminal in Zeebrugge, this is the reason
why the Authorised Inspection Organization was also charged, in addition to their
legal task, with doing quality audits of the EPC-contractor and his most important
suppliers with the intention to be able to react proactively and to perform the actual
inspection with more focus.
3.2.6 General Methodology
The Authorised Inspection Organization is involved in the different steps of the

project, from design to the manufacture of materials to the construction itself on the
construction yard.
A Third Party or Notified Body, however, only sees some pieces of the puzzle,
without being necessarily informed of final application purposes nor possible specific
technical safety requirements. But, in the end it are these pieces that make the
puzzle and contribute to the whole.
In all this, it is important not to be blinded by some flashy single certificates and
labels, but to look at the general idea and effectively check whether the puzzle fits.

III.8
Concerns and start of an inspection plan
CHAPTER 4 : CONCERNS AND START OF AN INSPECTION PLAN
4.0. Introduction
This chapter contains a number of points meriting attention for the most
important topics, which were extensively discussed in the previous chapters
(mainly chapters 2 and 3). These are found in the first part, and can have an
impact on the safety and quality of industrial installations during the construction
phase. In the second part, a start is made with drafting an inspection plan.
4.1. Concerns
The points meriting attention found below are not based on coincidences. They
are a representation of the most important shortcoming regularly found during
inspections in the context of the construction of industrial installations. The
attention points mentioned most often have already been discussed in more
detail, mainly in Chapter 2 and 3 of this status report.
The attention of the reader is directed to the fact that it was never the intention
to draft a complete list, and that this list is not an inspection program. The
purpose of it is to direct attention to a number of critical points that regularly
cause trouble.
In the tables that follow, you will find the relevant attention points arranged per
topic (equipment and installations under pressure, concrete structures, coating
and isolation and fire safety) and per phase (generalities, design, materials,
manufacturing, inspection and quality assurance). In a number of case, certain
chapters and paragraphs are referred to for more explanation.

IV.1
4.1.1 Equipment and Installations under pressure
ATTENTION POINTS REMARKS

0. General Remarks
0.1. Despite the present safety risk, some pressure equipment are When extending the LNG terminal in
not subject to the European directive for pressure equipment Zeebrugge, the tank (and accessories) were
due to their nature, pressure and/or volume. built under the surveillance of an authorized
inspection organization (Belgian Gaslaw).
Example: an LNG storage tank due to the limited design This was an additional demand in the license.
pressure (< 0.5 bars).
If the European directive for pressure
equipment does not apply and the
intervention of an authorized inspection
organization, notified body and/ or third party
is desired anyway, their mission should be
defined unambiguously.
0.2. The evaluation programs and the task of the notified body In the context of the Belgian Gaslaw, the
are not always unambiguously defined in the European authorized inspection organization is
pressure equipment directive. Because of this, notified bodies appointed by the holder of the license.
will not only compete on the level of prices, but also on the Therefore, in the execution of their mission, a
extent and contents of their inspections. higher independence from the manufacturer
Since the notified body is appointed by the manufacturer, in is guaranteed than when the manufacturer
many cases the path of least resistance (and lowest costs) itself concludes a contractual arrangement
will be chosen, which will hollow out the foundation of the with an authorized inspection organization,
directive at times. notified body and/or third party of its own
choice.
This voids the often-heard threat of some

manufacturers to give future assignments to
others if the designated body is not lenient in
its application of the directive.

IV.2
1. Design
1.1. Cf Chapter 2.2. In many cases, it is unclear for which medium or The drafting of a design specification should
temperature an equipment or installation under pressure has happen in a very early stage. Its
to be designed, or whether fatigue or external influences prescriptions have to be made known to the
such as wind loads should be taken into account. authorized inspection organization, the
notified body and/or third party.
Therefore, a design specification should be compiled that
contains the prescriptions, or references to these, to which
the pressure equipment and/or installation have to conform.
The lack of a complete and clear design specification, or the
insufficient familiarity with its contents by some parties (for
example subcontractors) are often the fundamental cause of
problems surfacing during manufacture or during later
exploitation.
1.2. Cf Chapter 2.2. Independent of the requirements of the applicable regulation, With the extension of the LNG Terminal in
it is necessary that a construction code be selected. All Zeebrugge, the construction code for the
prescription of this construction code have to be respected tank, piping, and pressure equipment was
(this applies to design aspects as well as materials, imposed in the license.
construction, inspection, …) and there should be no mingling This is not the case, however, in for example
of prescriptions from different codes. the European pressure equipment directive,
Indeed, the prescription of a code constitute a coherent where only a series of essential safety
whole, and it is this coherent whole that ensures that the requirements are imposed.
construction is sufficiently safe.
The notified body is responsible to check
whether or not the essential requirements of
the directive have been met. The verification
of the coherent application of a construction
code is not necessarily part of its mission.
1.3. Cf Chapter 2.2. The pressure equipment or the installation regularly deviates This important exercise is often forgotten, as
in the final condition from the design drawings. If the is the formal confirmation of compatibility
deviations should be outside the prescribed tolerances, or if, between the calculation note and the as-built

IV.3
for example, other materials were applied, the design officer drawings.
should verify whether or not the final condition is in
conformity with the design criteria. In particular, the This review should be conducted by the
calculation note should be brought into conformity again with contractor, the design office, and the notified
the as-built drawings (checks of compatibility). body.
2. Materials
2.1. Cf Chapter 2.3. The selected material should be included in the construction In the context of the European directive for
code. Some manufacturers sometimes erroneously select the pressure equipment, a separate material
application of a (cheaper) construction steel (for example EN evaluation should be drafted for materials not
10210 S355J2H) instead of a steel fit for pressure-bearing included in a harmonized standard.
parts (for example EN 10216 P355NL1).
Experience teaches that the manufacturers
and/or notified bodies do not always take into
account intrinsic qualities and application
areas of the materials and often limit
themselves to a review of the mechanical
characteristics (strength and tenacity).
2.2. Cf Chapter 2.3. From experience it can be said that, for more than 20% of The European pressure equipment directive
the materials delivered with a EN 10204 3.1 certificate puts the choice of the type of certificate in
(pipes, plates, castings, forgings, …), deviations exist function of the statute of the material
between the values included in the certificate and the manufacturer.
veritable characteristics of the materials involved. For material manufacturers whose quality
A EN 10204 3.2 certificate offers more guarantees system has been approved by a body
(conformity with materials specifications & traceability) than competent for this and established in the
a EN 10204 3.1 certificate, on condition that there has been European Community, it suffices that
sufficient surveillance and assistance during key operations materials are delivered with a EN 10204 3.1
to identify deficiencies. certificate.
Those deficiencies can be of very different natures:
- erroneous chemical composition In the context of the extension of the LNG
- erroneous mechanical characteristics (strength, Terminal in Zeebrugge, all cryogenic
tenacity, …) materials and all materials intended for the
- copied certificates transportation of gas under high pressure (>
- falsified certificates 14,7 bars – see Belgian Gaslaw) were

IV.4
- … delivered with EN 10204 3.2 certificates.
3. Manufacture
3.1. All ‘special processes’ (welding, soldering, bending,…) should Where the European pressure equipment
be executed in conformity with qualified procedures and by directive applies, the welding activities should
qualified staff. Nevertheless, deviations are regularly be checked in a sampling manner by the
established that can have implications on the structural notified body, if the manufacturer has
integrity of materials, pressure equipment, or installations. selected a module with actual inspections
(modules C1, F, G).
This in particular for welding activities: However, because of market pressures, it is
- insufficient preheating so that even in those cases, the notified
- wrong intermediate temperature bodies have to limit their surveillance on the
- wrong application of postheating or cooldown welding activities to a minimum.
- wrong filler metal or problem of traceability of the
filler metal In the context of the extension of the LNG
- unqualified welders Terminal in Zeebrugge, the welding activities
- … on the process piping and the tank (both in
prefab and on the yard) were conducted
under permanent surveillance of the
authorized inspection organization.
4. Inspection
4.1. Cf Chapter 2.4. The methods and techniques for the non-destructive testing Only for module G, it is required in the
of materials and welds have to be selected by the framework of the European pressure
manufacturer in function of the product to be controlled and equipment directive to approve the NDT
of the deficiencies that should be detected. It is also procedures formally by the notified body. In
important to check that the applied method and technique practice, no or little attention is again
are able to detect the expected indications, that all NDT devoted to this.
procedures are formally approved by a level 3 operator and
that, where needed, the procedures are qualified In the context of the extension of the LNG
(demonstration of detection degree). Terminal in Zeebrugge, the NDT procedures
were checked by a specialist of the
authorized inspection organization.
4.2. Cf Chapter 2.4. When performing non-destructive testing, even when Where the European pressure equipment

IV.5
qualified procedures were used, deviations can regularly be directive applies, the non destructive testing
detected that can compromise the structural integrity of the activities should be checked in a sampling
construction: manner by the notified body, if the
- when only a percentage of the welds is to be checked, manufacturer has selected a module with
the manufacturer often chooses to have the most actual inspections (modules C1, F, G).
accessible or most ‘favourable’ welds inspected; it is In this case however, surveillance is often
sometimes even asked to mention the faulty welds in limited to reviewing the films (even this does
a separate report (which is not included in the official not always happen) and reviewing the NDT
file) to limit the number of faulty welds and thus to reports.
prevent an augmentation in the number of welds to be
inspected In the context of the extension of the LNG
- the approved procedures are not applied correctly Terminal in Zeebrugge, non-destructive
(radiation time, type of probe, …) testing (in prefab, on the yard, and when
- inspections of repairs not being conducted in the inspecting the materials) was conducted
correct location under surveillance of the authorized
- wrong interpretation of results inspection organization. For the most critical
- wrong criteria applied when interpreting results inspections, the expertise of a level 3
- … operator was called upon.
5. Quality
Assurance
5.1. Cf Chapter 1.1.1 Lack of sufficient experience and knowledge of the auditor,
and lack of coherence between the quality system of an
organisation and the activities that were supposed to be
controlled by this system, lead to an inefficient use of this
tool.

IV.6
4.1.2 Concrete Structures

0. General
Remarks
0.1. Cf Chapter 2.6. In Belgium it is very usual when dealing with major projects (for In the Netherlands, ten-yearly
example, construction of an LNG-terminal) to conclude an accountability is not included in legislation.
insurance that covers an accountability of a ten-year duration. This has the result that the technical
This ten-year accountability is imposed in civil law (art. 1792 and inspections of execution of construction
art 2270). To obtain this insurance, an independent technical activities connected to it are not obligatory,
inspection is required. The coverage of the ten-yearly and that there is no body present at the
accountability is given under the supervision of a specialist civil construction yard that conducts a full
works, who actually conducts the technical inspection. The inspection (inspection during design and
purpose of such an inspection is to decrease the risk of during execution).
deficiencies and to exclude, decrease or at least bring to an The inspection of the construction activities
acceptable level the chance of hidden deficiencies. The nature of is then left to, for example, the designer (or
such a technical inspection is that it includes checks of the design the constructor itself) involved, a party that
as inspections during execution. is therefore not independent.
During these checks and inspections, possible deficiencies and

hidden deficiencies are looked for related to the use threshold
condition (G.G.T.) and on the extreme threshold condition
(U.G.T.) In addition, aspects are considered that can negatively
influence the durability, the constructive safety and usability, or
in other words the “endurance” of the construction.
1. Design
1.1. Cf chapter 2.6. Often many changes are made to the concept during the design It is the task of the technical inspection
phase without taking into account the implications these bureau to conduct risk-oriented checks in
alterations have on the final stability and durability of the every phase of the construction project with
construction. particular attention for the final durability of
the construction.

IV.7
1.2. Cf chapter 2.6. The calculations and the drawing of constructions have been The software package mentioned on the left
done by the designer or an external design office for a very long are very much like ‘black boxes’: a great
time. These parties dispose of sophisticated software packages number of parameters is inputted and an
that can do all calculation conforming to particular standard. abundance of results comes rolling out of
Before, possibilities were less ample, and higher safety margins the computer. These results are all too
were used in calculations. Decreasing safety margins allows less often considered absolutely true, and are
space for mistakes or deviations. not questioned anymore. We see that
through the use of software, a designer
looses his feel with the construction and
with reality. A technical controlling bureau
often provides a new way of approach or
questions things that are no longer noticed
by someone involved in the project for a
very long time (and cannot see the wood
because of the trees).
2. Execution
2.1. Cf chapter 2.6. Also during the execution of construction activities, all kinds of If no independent body should be present
(unpredictable) things can happen that can endanger the quality on the construction yard that conducts an
of execution: umbrella inspection (inspection during
- unfavourable weather circumstances that endanger design and execution), then who will point
planning: since planning has to be met at all costs (by out the effect of some decisions on quality?
designers, constructor), often it is quickly conceded to
alter agreed-upon execution methods (for example:
imposed phases, length pouring phases, …) to make the
deadline anyway.
- Being behind on planning due to too late delivery of
execution plans, too many changes in the project in a too
late stage, decisions not being made,…

IV.8
4.1.3 Coating & Isolation

1. Design
1.1. Cf chapter 2.8. A specification should exist that contains the prescriptions, or Coating and/or isolation specifications are
references to these, to which coating and/or isolation activities often treated badly, and are often drafted
have to conform. The lack of a complete, clear and coherent without too much know-how. All too often,
specification or the insufficient familiarity with their contents by we have to establish that objects are
some parties (for example, paint companies, suppliers,…) are often covered with systems that are not or are
the fundamental cause of problems surfacing during the execution hardly sufficient for their applications.
or during the later exploitation.
In a subsequent phase, the coating and/or isolation procedures of Often it has also been seen that, for
the different suppliers and of the executors (for example paint example, the application procedure did not
companies) should be reviewed for their conformity with coating correspond with the design specification. A
and/or isolation specifications. repainting job is then the consequence.
1.2. Cf chapter 2.8. In many cases, objects are designed without taking the This is to be taken into account in an early
possibilities of good conservation and maintenance friendliness into stage, namely when drafting the plans.
account (for example, stagnation of water, inaccessibility to paint
after montage, combination of different metals,…)
1.3. Cf chapter 2.8. Although different paint manufacturers and systems exist on the Using paint systems of different
market, it is advisable to choose one manufacturer and one manufacturers interchangeably often results
painting system. If not, a mix of systems is created that cannot in loss of accountability when a painting
guarantee compatibility among each other. problem surfaces.
2. Execution
2.1. Cf chapter 2.8. An evaluation of the painting companies before the start of
activities is advisable to test a number of aspects, such as, for
example, the application procedure, the competence of the
painters,…

IV.9
2.2. Cf chapter 2.8. The materials delivered should be inspected. Often non-
conformities are found in the nature and quality of the systems
applied.
2.3. Cf chapter 2.8. All activities should be executed conforming to the approved Because of unadapted scaffolds, often
procedures. Nevertheless, very often deviations are found that can certain zones remain unreachable or hard to
have an implication on the quality: reach, with the consequence that these
- climatological circumstances are to be followed from close zones are incorrectly coated or isolated.
by; all too often painting happens at, for example, a too
high air humidity
- during application of the first layer, often ‘mistakes’ happen
with the type of primer
- if the different painting layers are not different in colour, it
is impossible to check the number of applied layers
- the roughness profile should be checked; this is necessary
to guarantee a good stickiness (critical when dealing with
stainless steel)
- insufficient protection of stainless steel, with welding sparks
or dust as a consequence; extra manipulation is then
necessary before passivation.
- when painting flanges, all bolt connections should remain
free of paint
- …

IV.10
4.1.4 Fire Safety

1. Design
1.1. Cf chapter 2.9. A specification should exist that contains the prescriptions, or From the start of the project it is necessary
references to these, to which the fire safety system should not only to impose respect for a certain
conform. The lack of a complete, clear, and coherent specification norm, but also to determine to a higher
or the insufficient familiarity with its contents by some parties are degree how it will be applied. For example,
often the fundamental cause of problems that surface during the which calculation model, which design
execution or during the later exploitation. parameters, etc. This prevents discussions
after the fact and simplifies control over the
correct compliance with requirements.
1.2. Cf chapter 2.9. During the projects, deviations will come to exist from the
originally determined prescriptions or choices. These are to be
managed well in the course of the project to guarantee coherence
and efficiency of the system.
1.3. Cf chapter 2.9. Integration of the fire safety measures (active, passive, The scenarios required to intervene as
organisation), is often the point where things go wrong. efficiently possible in the case of fire, have
to be fleshed out and tested in advance.
Another attention point are those parts of the scenarios that are Both the scenarios per production-
embedded via hard and software in the installations. Important installation or production-unit and the
here are: the communication protocols between the different scenarios that describe the mutual influence
systems (are these compatible?) and the certainty of their of production installation on a company
operation. terrain are important.
These scenarios include both passive, active,

as organisational measures and this for
different possible incidents identified by risk
analysis.

IV.11
2. Execution &
Inspection
2.1. Cf chapter 2.9. Practical tests on the terrain: agree in advance when these are For example, think of:
planned, with which means, criteria, etc. It often occurs that fire • testing detection systems with “fire
safety systems are only inspected or tested in the very last phase, types” without preparation in
which prevents certain practical tests from being conducted planning and safety measures before
anymore (for example, because parts of the installation are the test itself, often do not happen
already in service) and because of which a possible adaptation of • the same goes for testing
the installation in response to the inspection becomes extinguishing systems, for example,
problematical; testing the built-in scenarios such as the shutdown deluge-systems, foam extinguishing
of certain parts of the installation after detection cannot, for installations, etc.
example, be conducted when the production is already operational,
while it is clear that testing these scenarios is of crucial
importance; it often happens that individual safety systems
operate correctly but that the interaction between systems has
been incorrectly configured.

IV.12
4.2. Start of an Inspection Program for Industrial Installations
4.2.0 Preliminary Remarks
• The intention of these inspections is the concern for safety, health and
environment, but they can also be expanded toward company security.
• The approach is the safety analysis has been conducted and has led to
determining design, construction, and inspection rules, and that these are
set in the design specification. As concerns the safety analysis, it is
important that the seriousness of a danger and the probability of it are
taken into account.
• The origins of this approach are twofold, on the one hand the result of
safety analysis of the installation and of the combined individual
components, on the other the result of our practical field experience.
• It is the intention that the future user of this tool makes his/her own
selection from the series of attention points that are identified in function
of the SRC (safety related category), depending upon the gradation in
categories that applies to him/her.
4.2.1 Approach
• We would like to consider these inspection activities as supplementary to

those provided in the design and construction standards, or in the
applicable regulation. What we are talking about is thus really a kind of
fourth party inspection by the government or the future owner/exploiter,
or by a body designated by them.
4.2.2 Remarks
• All suggestions have to be considered in their proper context. For

example, a pump can be perfectly safe considered from the viewpoint of
structural integrity as a consequence of internal pressure, but it can be
important to check other (safety) aspects such as: the vibration behaviour
(for example fatigue of the operational pipelines or measuring equipment),
the impact of forces or moments on the intake and exhaust pipes as a
consequence of incorrect anchoring or alignment, not fulfilling the
prescribed pumping characteristics, …
• The approach can be inputted into a database for use in other
situations/installations, and this has to allow a number of rankings or even
the generation of modified inspection programs, now or in the future for
other installations. For future use, supplementary requirements can also
be added that, when the time is right, can be added in the order, buyer
specification or design specification, as is desired. For example applying a
quality system with or without third party supervision.

IV.13
PRESSURE
Aspect and Subaspects SRC Check Inspection Activity Time of
by x inspection
Preliminary
Safety Analysis Verifies availability During design
Test the completeness and clarity
Design Specification Verifies availability During design
Test completeness
Evaluate the conformity with the safety analysis
Buyer specification Verifies availability for all materials and components At the
Evaluate conformity with the design specification beginning of
Evaluate conformity with technical purchase phase
standards/specifications
Test completeness
Manufacturing specification Verifies availability for all relevant manufacturing During
processes (welding, forming, heat treatment,…) purchase phase
Evaluate conformity with the design specification (for individual
Evaluate conformity with technical components) or
standards/specifications during
Test completeness montage
Inspection specification Verifies availability for all components to be inspected During the
Evaluate conformity with design specifications purchase phase
Evaluate conformity with technical (for individual
standards/specifications components) or
Evaluate competence to identify sought-for indications during
Verifies the qualification of the technique/procedure montage
Test specification Evaluate conformity with design specifications During the
Evaluate conformity with technical purchase phase
standards/specifications (for individual
components) or
during
montage

IV.14
Design
Design calculations Evaluate conformity of input data with design During design
specifications
Evaluate whether the correct calculation parameters such
as allowable stress, 0.2% or 1% strain,…, were used, or
correct hypotheses were made and whether all load cases
were accounted for
Evaluate whether the design takes all design data into
account, such as fluids to be pumped away, erosion,
ageing, fatigue, transients, number of cycli, wind, earth
quakes, dynamical loads, supports,…
Check whether only one design code was used
Evaluate whether the calculation note contains sufficient
information for an independent review
Drawings Evaluate whether welding configurations and other During design
fabrications details are in conformity with what the
design code provides for and allows for
Evaluate whether the construction/design allows for the
required non-destructive investigations in the different
phases (manufacture, exploitation)
Evaluate whether the impact on calculation notes of the Before putting
differences between the ‘as designed’ and the ‘as built’ into operation
situation were checked
Materials Verifies the AQ status of the material manufacturer or

supplier
Investigate the certificates for completeness as to form,
contents, conformity with specifications and with the
order
Evaluate conformity and completeness of the
identifications on the material with those of the
specification and of the certificate
Confirm the certificates, wholly or partially for X % of the
totality (of the order/ casting number / batch number /
type of material /…) by conducting tests

IV.15
Manufacture Identifies all “special” processes that require a

qualification or different precautions (welding, solding,
forming, rolling,…)
Evaluate the qualifications of one or more procedures
Evaluate whether all WPS’s are covered by a correct PQR
(welding)
Evaluate the heat treatments (if applicable) –
temperature course, time period and heating and cooling
periods, calibration of thermocouples, localisation of
thermocouples
Evaluate whether preheating, intermediate temperature,
postheating and a slow cooldown are correctly applied
Evaluate whether the WPS parameters are respected
Inspection (non-destructive and Verify that all NDT procedures are formally approved by a
destructive) level III operator
Check whether for certain non-destructive investigations,
the procedure should be qualified (demonstration of the
doability of the procedure) …
Evaluate whether the applied method is able to detect
the expected indications
Check whether the operators are formally qualified for
the specific technique and possible subtechnique (for
example, US on austenitic casting parts)
Check the NDT reports for completeness and correctness
Confirm the results of the investigation for X % (of the
component, of the number of components, of the length
of the welds, of the number of welds …)
Evaluate whether the program of production test coupons
was realized
Evaluate whether the results of the tests on the
production test coupons are acceptable

IV.16
Testing – Strength and Tightness Evaluate whether the correct testing pressure is applied
Tests (taking into account the different design pressures,
heigth differences, …)
Evaluate the correctness of the pressure test procedure
(sequence of pressurizing and depressurizing, venting,
draining, position of valves and other appendages,
durations, …)
Evaluate whether a correct testing medium is used
Evaluate the instrumentation (manometers) that are
being used, for example, scale, capacity, calibration, …
Evaluate the objective results (pressure drop,
deformations, leaks, …)
Verify that a distinction has been made with the tightness
test if required
Tests – functional testing (rotating Verify the characteristics of rotating machines

machines, valves, …) Evaluate whether the montage is executed correctly
(tension free, aligned, …)
Evaluate the characteristics of valves, non-return valves,
safety valves (opening and closing times, opening and
closing pressures, couples for the actuators, surveillance,
draining and venting, tightness of valves, pressure test of
the disk,…)
Overpressure protection etc. Evaluate the justification of the necessary venting

capacities
Evaluate the choice and number of the direct safety
appendages
Test the opening and closing pressures (calibration)
Test the tightness
Evaluate the correct installation of the ‘as designed’ other
(indirect) safety appendages (instruments with corrective
functions : SRMCR systems)

IV.17
Traceability Check whether during the entire fabrication process

traceability is maintained
Check whether in the final phase (final inspection) all
parts can still be identified (via hardware or software)
Nameplate Evaluate the nameplate. In addition to the identification

of the constructor and the device or installation, it is
important that the nameplate provides minimal
information that is important for the safe exploitation and
maintenance. (for example min/max pressure, min/max
temperature, weight, electrical tension,…)
Marking by the relevant authorities if applicable
Final Inspection Evaluate the conformity with drawings, isometrics and/or

schematics (support, fixed points, calibration shock
absorbers, anchorings, tilting, dimensional aspect of
supports,…)
Evaluate the correct execution of the installation/erection
(mechanical)
Conduct a dimensional check of, for example thicknesses
Conduct a dimensional check of, for example, overall
dimensions, functional, …
Evaluate whether an ‘as built’ conformity
assessmentbetween plans and calculation notes has been
carried out
Analysis of deviations Check the evaluation of all possible limitations,

deviations, derogations, limitations that have been set in
some document or other and that conflict with the design
specification or with legal requirements
Quality system Not considering an ongoing QS with the intervening

parties, an independent assessment of a part or the
whole of the components and/or activities can be
selected

IV.18
Data book Evaluate the contents set down in the design code and/or
regulations
Evaluate the efficiency of the use of the data book for the
future exploiter (repairs, spare parts, replacements,
alternative methods of inspection, …)
Evaluate the traceability between soft and hardware
(which document belongs to which component)

IV.19
COATING & ISOLATION

Aspect en subaspects SRC Check Inspection Activity Time of the
by x Inspection
Preliminary
Safety Analysis Verify availability
Test completeness and clarity
Paint Specification Verify the availability Before
Test completeness, clarity, and correctness activities
commence
Design Verification Verify the drawings for executability of the painting During design
activities
Design
Audit Painting Company Not considering an ongoing QS with the intervening Start of
parties, an independent assessment of the painting purchase phase
company can be envisaged (quality audit based upon
ISO 9001, evaluation of a recently completed
construction yard, general theoretical and technical
professional knowledge)
Vendors Evaluate the application procedure and the selected Start of
materials purchase phase
Paint manufacturers Evaluate / analyse the quality of the proposed products Start of
purchase
Execution
Inspection during application at Vendors’ Purchasing of steel for paintability During
workshops Evaluate the preparation of the substrate production
Analyze the chlorine ions on the substrate and in the
blasting means
Evaluate the application of the different layers
Evaluate the execution and/or results of the qualitative
tests
Measure the layer thickness in a sampling manner

IV.20
Inspection of the supplied materials Verify the painting systems used and their conformity At delivery
with the applicable specifications
Check the applied layers
Measure the layer thickness in a sampling manner
Conduct tensile tests
Execution before and during

montage
Piping Conduct a visual inspection Before
Measure the layer thickness in a sampling manner montage
Conduct a dielectric test for internal tanks/piping
Structures Conduct a visual inspection Before
Measure the layer thickness in a sampling manner montage
Conduct tensile tests
Execution after Montage

Piping Conduct a visual inspection During and at
Measure the layer thickness in a sampling manner delivery
Conduct a dielectric test for internal tanks/piping
Structures Conduct a visual inspection During and at
Measure the layer thickness in a sampling manner delivery

IV.21
CIVIL WORKS
Aspect and Subaspects SRC Check Inspection Activity Time of
by x Inspection
Basic Specifications Evaluate the availability and correct usage of soil At the start of
analyses the design
Evaluate the seismic risks
Evaluate the influence of the environment (sea…)
Evaluate the usage of a correct standard frame for design
calculations
Design Verify the availability and completeness of the risk Design

analysis:
○ primary elements (stability)
○ secondary elements (tank, reservoir) that have a
major influence on the safety, durability and the
usage
Determine the choice of foundation system
Verify the design and the dimensioning of the most
important elements
Verify the specification and its conformity with the
drawings
Evaluate the prescribed tests and checks
Evaluate the prescribed materials and techniques
Purchase Evaluate the quality plan of the company Purchase

Evaluate the purchase analysis designers

IV.22
Execution Verify the status of the drawings used on the Execution

construction yard to establish that correctly indexed
drawings are utilized on-site (drawings list)
Verify whether the set hold-points are respected and
verify the treatment of the observations on this
Verify whether the constructors veritably dispose of the
competence and qualifications as these are described in
the quality handbook
Verify the availability of, and the actual familiarity (of the
constructors) of the contents of the quality handbook
Evaluate whether the processing times of the concrete
delivered on the yard (mixer) matches the acceptable
processing times
Evaluate on the yard whether the means of protecting
freshly poured concrete (products and measures) are
available
Evaluate whether the delivered reinforcements (concrete
steel) conform with the quality as defined in the
specifications
Evaluate whether the parts that are to be poured into
concrete (flanges, pipes) are actually present on the yard
and whether these correspond with the specification and
with the certificate
Evaluate whether the program of keeping delivery
coupons, certificates, test reports is actually realized
Evaluate whether the concrete cover is respected (to be
measured with, for example, a packometer)
Evaluate whether the prescribed unpacking periods are
respected

IV.23
Test the conformity with the quality plan with particular

attention to the points of solving and dealing with
established deficiencies and shortcomings
Attend tests and/or verify their results
Verify the used and chosen techniques
Verify the conformity reports, designers and inspection

IV.24
Conclusions
CHAPTER 5 : CONCLUSIONS
It is no simple matter to report on the reliability level of the current supervision of

the construction of complex industrial installations, nor to expose the weaknesses
of said system.
The different specialists of Vinçotte that cooperated in writing this report have all
tried, following their experience and personal views, to direct the reader’s
attention to the surveillance and inspection aspects that seemed to them
important, sensitive, yes, even problematic, when surveying such projects.
After thoroughly reading through this report, its reader will realize that there are
really numerous aspects that can endanger the quality and safety of an
equipment or installation when approached erroneously.
In addition, it is so – and this aspect should certainly not be forgotten as well –

that the market is currently certainly not evolving towards a system that provides
more safety guarantees. Because globalization has led to an economical situation
with parties that engage in a competition that is becoming more and more grim:
prize wars, “up and coming” countries entering the market who only possess a
limited industrial experience as of now, fusions and take-overs that lead to
conglomerates and mammoth companies of which one wonders whether they can
still be controlled. These tendencies result in numerous reorganisations, an ever
larger will to decrease operational costs, a decrease of staff costs (first in the
departments that are not involved directly in production, such as the department
quality control and internal safety surveillance), outsourcing, scrapping jobs, not
replacing experienced employees going on retirement, …
‘Quality has its price’: this is as true today as it was one hundred years ago …
In addition, the freeing of the European market leads to a situation where the
economic players, who experience the consequences of this globalization in a very
concrete manner, are less and less controlled. More and more, they are
considered the sole entities responsible for their products (materials, equipments,
installations, …). That is generally what they like best, as the secretary-general of
Orgalime put it recently: “Test houses very often play an essential role in helping
manufacturers in the design and testing of their products. But this should be as
far as possible a B2B relationship and we do not like obligatory 3d party
certification (…).”
It is not easy to determine the weaknesses of the current certification and

inspection system exactly, unambiguously, and without discussion. Because said
weaknesses are very varied and diverse: their possible presence depends on the
project and can also be strongly dependent on the capabilities of the persons able
to trace them. We have attempted to highlight them in the different chapters of
this status report, without claiming to have mentioned and discussed all possible
cases.
In chapter 4, we wanted to draw the reader’s attention to the points we think

most important. Some of the problems raised should be taken care of by
legislation and inspection mandates that already exists but have unfortunately
been shown not to be efficient enough. Other problems are simply related with
shortcomings of the current inspection system.
Situations can be very different from country to country, however, when these
matters are regulated by national legislation. The extension of the LNG-terminal
of Zeebrugge was the origin of the request of the Dutch government, more
particularly the inspection services of the VROM, to draft this report. In the
framework of that extension, the mandate of Authorized Inspection Organization,
as defined in the Belgian regulation (‘Gaslaw’) and the license, was a

V.1
Conclusions
determinative factor in better controlling a great number of the problems that

were predicted in the report, and thus ameliorating the safety level of the
installation. Such a mandate certainly contributes to the safety of the
transportation and storage installations of gas in Belgium. The reader was also
able to inform himself/herself of the way in which the Belgian government
charged the bodies with the inspection of nuclear equipments and installations.
This mandate has proven its use in the course of time and got internationally
recognition. Ten-yearly accountability, for example, was also discussed, a
measure that in Belgium exists for civil constructions, and has already proven its
use there. Finally, attention also was devoted to domains where there is still a lot
to be done (fire safety, …). The testimonies included in this status report have the
purpose of guaranteeing the safety and quality of the installations during their
construction and thus also the safety of the personnel of the exploiter and general
public during the entire lifetime of the installation.
We therefore hope that they have been a useful source of inspiration and
information for the Dutch government. The Belgian governments, of which some
services were also involved in this study, will also have been very interested in
certain Dutch particularities, such as inspections before putting into operation of
industrial installations (a mandate nonexistent in Belgium in the conventional
sectors, especially for pressure risks, steam installations excluded) and the
importance of a regular communication between inspection bodies and the
authorities.
To conclude this study, we would like to stress a number of aspects that from our
point of view as an inspection body and on the basis of our experience,
indisputably contribute to a higher safety level of an industrial installation:
Most quality problems related to equipments or installations can only be

discovered via inspections of the products involved during their manufacture.
Although certification of quality systems is useful and complementary to
inspection activities, it cannot replace them if an equivalent efficiency and
reliability level has to be guaranteed.
The inspections and checks by the different project actors (manufacturers,…) are
particularly important. The economical realities and especially the pressures of
polyvalent nature that they cause make it even more essential that inspection
activities are conducted by independent inspection bodies (so-called third party
inspections).
Despite their independence and the attempts to generalize methods of approach,

one has to admit that inspection bodies, too, are subject to market pressures and
because of this experience heavy pressures on their prices and amounts of
inspections. In general however, that pressure will be smaller if the body
works directly for the exploiter (license holder), rather than for the
constructor.
An inspection by an independent body will only provide extra value if this body
disposes of competent and experienced staff. It is therefore proper that the
number of bodies that is designated by the government, is limited,
allowing them to gain and transmit expertise.
The problems related to quality and safety of equipments and installations can
often only be discovered via inspection activities. The individuals charged with
these inspections, have to dispose of a broad mandate, allowing them to
regularly check the different construction phases.

V.2
Conclusions
An efficient government control over the market and its different actors
remains essential. In this way, deviations can be discovered, and measures can
be taken to remedy them.
This study can be no endpoint, but, if and where deemed necessary, it can be a
start for further exploration (for example, by further developing an inspection
plan), for training and adapted coaching of the surveying personnel and for a
restructuring and optimisation of the surveillance structure.
We hope that this status report can modestly contribute to the amelioration and
reinforcement of the rules that guarantee the quality and safety when building
industrial installations. Without forgetting that quality is above all a mentality, a
philosophy that all levels of human organization should use as a guiding thread.
In 2003, the investigation commission of the accident with the spaceship

Columbia was therefore very justified in its conclusion:
“We are convinced that the management practices overseeing the Space Shuttle
Program were as much a cause of the accident as the foam that struck the left
wing.”
and
“It is our view that complex systems always fail in complex ways, and we believe
it would be wrong to reduce the complexities and weaknesses associated with
these systems to some simple explanation. Too often, accident investigations
blame a failure only on the last step in a complex process, when a more
comprehensive understanding of that process could reveal that earlier steps
might be equally or even more culpable.”

V.3
Annexes

Annexes
Annex 1 :
Bibliography
(standards for fire safety)

Annex 1
Standard reference Title

EN 54-1:1996 Fire detection and fire alarm systems - Part 1: Introduction
Fire detection and fire alarm systems - Part 2: Control and indicating
EN 54-2:1997
equipment
EN 54-2:1997/A1:2006
equipment
EN 54-2:1997/AC:1999
equipment
Fire detection and fire alarm systems - Part 3: Fire alarm devices -
EN 54-3:2001
Sounders
EN 54-3:2001/A1:2002
Sounders
EN 54-3:2001/A2:2006
Sounders
Fire detection and fire alarm systems - Part 4: Power supply
EN 54-4:1997
equipment
EN 54-4:1997/A1:2002
equipment
EN 54-4:1997/A2:2006
equipment
EN 54-4:1997/AC:1999
equipment
Fire detection and fire alarm systems - Part 5: Heat detectors - Point
EN 54-5:2000
detectors
Fire detection and fire alarm systems - Part 5: Heat detectors - Point
EN 54-5:2000/A1:2002
detectors
Fire detection and fire alarm systems - Part 7: Smoke detectors -
EN 54-7:2000
Point detectors using scattered light, transmitted light or ionization
EN 54-7:2000/A1:2002
EN 54-7:2000/A2:2006
Fire detection and fire alarm systems - Part 10: Flame detectors -
EN 54-10:2002
Point detectors
Fire detection and fire alarm systems - Part 10: Flame detectors -
EN 54-10:2002/A1:2005
Point detectors
EN 54-11:2001 Fire detection and fire alarm systems - Part 11: Manual call points
EN 54-11:2001/A1:2005 Fire detection and fire alarm systems - Part 11: Manual call points
EN 54-12:2002 Fire detection and fire alarm systems - Part 12: Smoke detectors -

Annex 1
Line detectors using an optical light beam

Fire detection and fire alarm systems - Part 13: Compatibility
EN 54-13:2005
assessment of system components
Fire detection and fire alarm systems - Part 16: Voice alarm control
EN 54-16:2008
and indicating equipment
EN 54-17:2005 Fire detection and fire alarm systems - Part 17: Short-circuit isolators
EN 54-17:2005/AC:2007 Fire detection and fire alarm systems - Part 17: Short-circuit isolators
EN 54-18:2005 Fire detection and fire alarm systems - Part 18: Input/output devices
EN 54-18:2005/AC:2007 Fire detection and fire alarm systems - Part 18: Input/output devices
Fire detection and fire alarm systems - Part 20: Aspirating smoke
EN 54-20:2006
detectors
Fire detection and fire alarm systems - Part 20: Aspirating smoke
EN 54-20:2006/AC:2008
detectors
Fire detection and fire alarm systems - Part 21: Alarm transmission
EN 54-21:2006
and fault warning routing equipment
Fire detection and fire alarm systems - Part 24: Components of voice
EN 54-24:2008
alarm systems - Loudspeakers
Fire detection and fire alarm systems - Part 25: Components using
EN 54-25:2008
radio links

Annex 1
NFPA 1 Fire Code

NFPA 11 Standard for Low-, Medium-, and High-Expansion Foam
NFPA 12 Standard on Carbon Dioxide Extinguishing Systems
NFPA 13 Standard for the Installation of Sprinkler Systems
NFPA 14 Standard for the Installation of Standpipes and Hose Systems
NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection
NFPA 16 Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray
Systems
NFPA 20 Standard for the Installation of Stationary Pumps for Fire Protection
NFPA 25 Standard for the Inspection, Testing, and Maintenance of Water-Based Fire
Protection Systems
NFPA 30 Flammable and Combustible Liquids Code
NFPA 51B Standard for Fire Prevention During Welding, Cutting, and Other Hot Work
NFPA 54 National Fuel Gas Code
NFPA 55 Standard for the Storage, Use, and Handling of Compressed Gases and
Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks
NFPA 58 Liquefied Petroleum Gas Code
NFPA 59 Utility LP-Gas Plant Code
NFPA 59A Standard for the Production, Storage, and Handling of Liquefied Natural
Gas (LNG)
NFPA 68 Standard on Explosion Protection by Deflagration Venting
NFPA 69 Standard on Explosion Prevention Systems
NFPA 101 Life Safety Code®
NFPA 110 Standard for Emergency and Standby Power Systems
NFPA 329 Recommended Practice for Handling Releases of Flammable and Combustible
Liquids and Gases
NFPA 550 Guide to the Fire Safety Concepts Tree
NFPA 551 Guide for the Evaluation of Fire Risk Assessments
NFPA 750 Standard on Water Mist Fire Protection Systems
NFPA 1250 Recommended Practice in Emergency Service Organization Risk Management
NFPA 1452 Guide for Training Fire Service Personnel to Conduct Dwelling Fire Safety
Surveys
NFPA 1561 Standard on Emergency Services Incident Management System
NFPA 1600 Standard on Disaster/Emergency Management and Business Continuity
Programs
NFPA 1620 Recommended Practice for Pre-Incident Planning
NFPA 5000 Building Construction and Safety Code®

Annex 1
Annex 2 :
Used Abbreviations

Annex 2
Abbreviation Explanation
AISI American Iron and Steel Institute
AK Anforderungs Klasse
AKI Aangewezen Keuringsinstantie (Nederland) / Authorized Inspection
Organisation, The Netherlands
ARAB Algemeen Reglement op de Arbeidsbescherming (België) / General
Health and Safety Regulation (Belgium)
ARBO Arbeidsomstandigheden (Nederland) / Labour Conditions, Law on
(The Netherlands)
AREI Algemeen Reglement op de Elektrische Installaties (België) / General
Electrical Installations Regulation (Belgium)
ATEX Atmosphère Explosible / Explosive atmospheres
AUT Automatisch Ultrasoon Onderzoek / Automatic ultrasonic testing
AVG Abstand - Verstärkung - Grosse/Distance-Amplification-Size
BC Besturingscategorie / Control category
Bevi Besluit externe veiligheid inrichtingen (Nederland) / External Safety
of Installations, Decree on (The Netherlands)
BPCS Basic Process Control System
BRZO Besluit Risico op Zware Ongevallen (Nederland) / Control of major-
accident hazards involving dangerous substances, decree on (The
Netherlands)
BWR Boiling Water reactor
CEN Comité Européen de Normalisation / European Standardisation
Committee
CENELEC Comité Européen de Normalisation Électrotechnique / European
Electrotechnical Standardisation Committee
CFK Chloorfluorkoolstofverbinding / carbonfluorinechlorine compound
COP Conformity of Production
CPR Commissie voor Preventie van Rampen (Nederland) / Commission for
Prevention of Disasters (The Netherlands)
CUR Centrum Uitvoering Research en Regelgeving (Nederland) / Centre
for Execution of Research and Legislation (The Netherlands)
DAC Distance Amplitude Connection
DCMR Dienst Centraal Milieubeheer Rijnmond (Nederland) / Public Service
Department Environmental Control Rijnmond (The Netherlands)
DIN Deutsches Institut für Normung
DOC Declaration of conformity
DOW F&EI Dow Fire and Explosion Index
EC Europese commissie / European Commission
EDTC Externe Dienst voor Technische Controle (België) / External Service
for Technical Inspection (Belgium)
EMC Electromagnetic compatibility
EN Europese norm / European Standard
EPC Engineering, Procurement, Construction
ESD Emergency Shut Downs
ETA European Technical Approval (see European Construction Products
Directives)
ETSI European Telecommunications Standards Institute
FM Factory Mutual
FMEA Failure Modes and Effect Analysis

Annex 2
FMECA Failure Modes and Effect Criticality Analysis

FOD Federale Overheidsdienst (cfr. Ministerie) (België) / Federal
Government Service (cfr. Ministry) Belgium)
FOD WASO Federale Overheidsdienst Werkgelegenheid, Arbeid en Sociaal
Overleg (België) / Federal Government Service Employment
(Belgium)
HAZOP Hazard and Operability Analysis
IEC International Electrotechnical Committee
IPPC Intergrated Pollution Prevention and Control
IR Infrarood / Infrared
ISO International Organisation for Standardisation
KB Koninklijk Besluit (federale wetgeving) (België) / Royal Decree
(Belgium)
KvI Keuring voor indienststelling / Putting into Service Inspection
LNG Liquified Natural Gas
LOPA Layers of Protection Analysis
LVD Low Voltage Directive
MB Ministerieel Besluit (federale wetgeving) (België) / Ministerial decree
(Belgium)
Minszw Ministerie van Sociale zaken en Werkgelegenheid (Nederland) /
Ministry of Social Affairs and Employment (The Netherlands)
MORT Management Oversight Risk Analysis
NBN Bureau voor Normalisatie of Belgische Norm / Standardisation Office
(Belgium)
NDO Niet-destructief onderzoek / Non destructive testing
NEN Nederlands Normalisatie Instituut of Nederlandse norm / Dutch
Standardization Institute or Dutch standard
NFPA National Fire Protection Association (USA)
NLF New Legislative Network
OJEU Official Journal of the European Union
OVR Omgeving Veiligheidsrapport / Environmental Safety report
OVR Veiligheidsrapport / Safety Report
P&ID Piping and Instrumentation Diagram
PBZO Preventiebeleid Zware Ongevallen / Policy on Prevention of Major
Accidents
PED Pressure equipment Directive
PFD Probability Failure on Demand
PGS Publicatiereeks Gevaarlijke Stoffen / Publication series on Dangerous
Substances
PLANOP Progressive Loss of Containment Analysis
PLC Programmable Logic Controller
PPS Privaat Publieke Samenwerking / Private Public Cooperation
PQR Procedure Qualification Record
PRD Praktijkrichtlijn drukapparatuur (Nederland) / Practical Guideline on
Pressure Equipment (The Netherlands)
PSV Pressure Safety Valve
PWR Pressurised Water reactor
QA Quality Assurance
QC Quality Control
QM Quality Management

Annex 2
QRA Quantitative Risk Assessment

QS Quality System
RIK Rapport Ingebruikneming Keuring / Report of Putting into Service
Inspection
RIVM Rijksinstituut voor Volksgezondheid en Milieu (Nederland) / State
Institute for Public Health and Environment (The Netherlands)
RWA Rook- en warmte-afvoer systeem / Fluegas- and Heat- discharge
system
SCH Schedule
SIL Safety Integrity Level
SLS Serviceability Limit State
SMS Safety management system
SRC Safety Related Category
SRMCR Safety Related Measuring Control and Regulation system
SWA Samenwerkingsakkoord / Cooperation agreement
SWIFT Structured what-IF checklist
TIS Technical Inspection Service
TOFD Time Of Flight Diffraction
TQR Training Quality Report
ULS Ultimate Limit State
UV Ultraviolet
VLAREM Vlaams Reglement op het Milieu (Vlaanderen, België) / Flemish
Environmental legislation (Flanders, Belgium)
VR Veiligheidsrapport / safety report
VROM Ministerie van Volkshuisvesting,Ruimtelijke Ordening en
Milieubeheer, (Nederland) / Ministry of Public Housing,
Environmental/Town and Country Planning and Environmental
Control (The Netherlands)
VVI Verklaring voor Ingebruikneming (Nederland) / Certificate of Putting
into Service Inspection (The Netherlands)
WM Wet Milieubeheer (Nederland) / Environmental Law (The
Netherlands)
WPS Welding Procedure Specification

Annex 2
Annex 3 :
Materials - Examples

Annex 3
Annex 3.1 (17 Pages)

Annex 3
Annex 3.2 (7 Pages)

Annex 3
Annex 3.3 (4 Pages)

Annex 3
Annex 3.4 (4 Pages)

Annex 3
Annex 3.5 (2 Pages)

Annex 3
Annex 3.6 (8 Pages)

Annex 3
Annex 3.7 (1 Page)

Annex 3
Annex 3.8 (1 Page)

Annex 3
Annex 3.9 (2 Pages)

Annex 3
Annex 3.10 (7 Pages)

Annex 3
CABF PED/SPV
08/004
Pressure Vessel Failure during Hydrotest-Nov. 2007 in China
January 9, 2008
Thomas Eun
Folks,
Please find attached photos of a pressure vessel that recently failed whilst under hydrotest during post
fabrication testing. This vessel was manufactured by a vessel vendor in China and the plate was of
Chinese mill origin. Unfortunately this is another example of serious equipment/material failures with
equipment being sourced out of the rapidly developing economies such as China, Eastern Bloc and
others. These examples are becoming almost a weekly occurrence now and are exhibiting failure modes
not seen in the mature manufacturing economies since the 1930's. Again we need to ensure vigilance in
the acceptance of manufacturers and once more I stress the need to know where the base materials are
sourced from.
Apparently this pressure vessel had reached fifty percent of the required test pressure when the shell
ruptured. A metallurgical failure report is not available however from the photographs a number of
observations could be made regarding the quality of the material and the welding.
Lesson learned
(1) All base metal requirements shall be specified in P.O Requisition per project/Industry Code
requirements.
(2) Consult specialists (i.e., Materials and Corrosion Engineers) whenever you doubt.
(3) All inspection (from base materials to final products) should be performed per the codes, specs &
standards.
(4) Especially when you selected the manufacturers in China, the above (1), (2) & (3) will be a very
important message.
1
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3
4
5
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Group VINÇOTTE

Safety surveillance approach

Status report on behalf of

Vilvoorde, 20 March 2009

Ir. Frédéric Dewint Prof. Dr. Ir. Marc Van Overmeire

Report VROM-Inspectorate  Vinçotte

0.0. Introduction: Problem Statement

Chapter 1 : Legal Restrictions Pertaining to the Construction of (Complex)

1.0. Contextualization of the European Legislation

1.1. European Legislation

1.1.1 The Pressure Equipment Directive

1.2. National Legislation

1.2.1 The Situation in Belgium

Chapter 3 : Approach and Inspection Philosophy in the Context of the First

Chapter 4 : Concerns and Start of an Inspection Plan

Annex 1 : Bibliography (standards for fire safety)

Report VROM-Inspectorate  Vinçotte

0.0. Introduction: Problem Statement

In mutual agreement, the following topics were withheld:

Report VROM-Inspectorate  Vinçotte

After an introductory paragraph which sketches the general context of European

Report VROM-Inspectorate  Vinçotte

CHAPTER 1 : LEGAL RESTRICTIONS PERTAINING TO THE CONSTRUCTION OF

1.0. Contextualization of the European Legislation

1.0.1 The regulatory acts related to the free movement of goods.

Whereas 3 of directive 2006/42/EC of the European Parliament and of the Council

1.0.2 The regulatory acts related to the protection of the workers at

Report VROM-Inspectorate  Vinçotte

Council resolution of 3 June 2002 on a new Community strategy on health and

1.0.3 The “New Approach”: a revolutionary measure requested by the

a) The Evolution of the European Doctrine for Harmonizing Legal

1 Council directive of 12 June 1989 on the introduction of measures to encourage improvements in

Report VROM-Inspectorate  Vinçotte

FREE CIRCULATION OF GOODS THE IMPORTANT STEPS IN THE

Report VROM-Inspectorate  Vinçotte

In thus mess or “creative disorganisation”, it is of the utmost importance to have

b) By Removing Technical Limitations Create an Instability that Creates

c) A European Doctrine Built in Five Steps

We draw the reader’s attention to an important point. The redistribution of roles

Report VROM-Inspectorate  Vinçotte

Starting Point: National Standards and Regulations

Usually, three kinds of technical limitations are distinguished:

Since originally provided community mechanisms have not lessened or prevented

• Differences relating to the means that have to be applied to protect public

A classical example in this area is the judgement of the amount of trust

Report VROM-Inspectorate  Vinçotte

• Different traditions of standardisation, testing, and certification. We all

• The national competent authorities (Ministry branch): establishes the

In case of standardization, the structure is very similar: there is a national organ

We are dealing with co-existent, independent regulating systems. The

MANUFACTURER RECOGNISED BODY

In such a system the manufacturer, should he have questions, can directly

Report VROM-Inspectorate  Vinçotte

First Step of the Harmonization: the Extrapolation of National Systems

1969 : harmonization of technical regulation

The Member States have a technical regulation. Creating a harmonized European

• Competent authority (Ministry branch): issues the certificates (and

• Regulatory texts are drafted on a community level and no longer on the

Report VROM-Inspectorate  Vinçotte

When I hear somebody sigh, "life is hard", I am always tempted to ask,

Second Step of the Harmonization: the New Approach

1985 : harmonization of technical regulations

+ the use of standards