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R - Sinclair - IECEx Integrating ATEX - Shanghai
R - Sinclair - IECEx Integrating ATEX - Shanghai
Shanghai
Ron Sinclair
Managing Director – Baseefa
Baseefa
Two ATEX Directives
• 94/9/EC – concerned with trade of
manufactured equipment intended for
installation in hazardous areas
“The ATEX Product Directive”
• 1999/92/EC – concerned with safety of
workers and the public in respect of
installations in hazardous areas
“The ATEX User Directive”
Baseefa
ATEX Directive 94/9/EC
• Council Directive 94/9/EC of 23 March
1994 on the approximation of the laws of
the Member States concerning Equipment
and Protective Systems intended for use in
Potentially Explosive Atmospheres
• ATEX = “Atmosphere Explosible” =
Potentially Explosive Atmosphere
Baseefa
ATEX Directive 94/9/EC
• Applicable throughout European
Economic Area (EEA)
= EU (25)+ EFTA (3) (+Switzerland) = 29
• Voluntary application since 1996
• Compulsory application since 2003
• It is a “Trading Directive”
• Concerns safety only to set minimum
levels to prevent concerns on safety being
a barrier to trade
Baseefa
ATEX Directive 94/9/EC
• Broad Scope
– Equipment (Motors, Luminaires, Diesel
Engines, Pumps, Fans, Conveyor Belts
Instrumentation, etc.)
– Protective Systems (Flame Arresters,
Suppression Systems, Venting, etc.)
– Safety Related Devices (IS Safety Barriers,
Motor Protection Relays, etc.)
Baseefa
ATEX Directive 94/9/EC
• Defines Categories of Equipment based
on risk of becoming an active ignition
source
• Definitions for mining and surface
industries differ slightly
• IEC TC31 has adopted the principle and
has started to allocate “Equipment
Protection Levels” (EPLs) with similar
definitions
Baseefa
ATEX Directive 94/9/EC
• Category 1
– Very high level of protection
– Ex ia, Ex ma, techniques in 60079-26
• Category 2
– High level of protection
– Ex d, Ex ib, Ex mb, Ex e, etc.
• Category 3
– Normal level of protection
– Ex n, Ex ic
Baseefa
ATEX Directive 94/9/EC
• Category M1
– Intended to remain energised when an
outbreak of gas has been detected
– Ex ia, Ex ma
• Category M2
– Intended to be de-energised when an
outbreak of gas has been detected
– Ex d, Ex ib, Ex mb, Ex e, etc.
Baseefa
94/9/EC plus 1999/92/EC
• The two ATEX Directives work together
to create safe installations
• Allocate Categories of Equipment for use
in Zones (unless a specific risk
assessment allows different)
– Category 1 – Zone 0, Zone 1 or Zone 2
– Category 2 – Zone 1 or Zone 2
– Category 3 – Zone 2
Baseefa
ATEX Directive 94/9/EC
• Compliance against “The Essential
Health and Safety Requirements”
(EHSRs) from Annex II
• Standards have a subsidiary role
supporting claims of compliance
• Harmonised standards are deemed to
demonstrate compliance
• Use of other standards has to be justified
Baseefa
Harmonised Standards
• IEC 60079 series (and other IEC
standards) are being adopted as EN
60079 series, etc.
• These replace older Cenelec Standards in
EN 50014 series
• Europe is committed to adoption of IEC
standards in Ex Field by “parallel
voting”
Baseefa
Harmonised Standards
• For list of current harmonised standards
see http://ec.europa.eu/enterprise/atex/stand.htm
• For information on how to deal with
changing harmonisation status see
http://www.baseefa.com/page58.asp
Baseefa
ATEX Directive 94/9/EC
• Compliance against EHSRs to be
reviewed against “State of the Art” of
technological development
• Harmonised standards are presumed to
show “State of the Art”
• Other standards may be even more valid
but justification for use must be provided
Baseefa
ATEX – Is it Certification ?
• ATEX is a mandatory legal device
• Only partly certification
– Process depends on Category
– The key document, “The Declaration of
Conformity” (DoC) is always issued by the
manufacturer without any monitoring by a
third party
– The DoC may, or may not, be reliant on
evidence from a third party
Baseefa
IECEx vs ATEX
• IECEx is a true Type 5 Certification
Scheme for all equipment, giving the
identical level of confidence for
everything
• ATEX only approaches Type 5 level for
Category 1 (and M1) Equipment and
Protective Systems, giving progressively
lower confidence for the lower Categories
Baseefa
IECEx vs ATEX
• IECEx
– ExTR + QAR >> Certificate of Conformity
(issued by IECEx Certification Body and
searchable on IECEx web site)
• ATEX Category 1 (or Cat. 2 electrical)
– EC-Type Examination Certificate + Quality
Assurance Notification (or ??) >> Declaration
of Conformity (issued by manufacturer on own
responsibility)
Baseefa
IECEx vs ATEX
• IECEx
– ExTR + QAR >> Certificate of Conformity
(issued by IECEx Certification Body and
searchable on IECEx web site)
• ATEX Cat. 2 non-elec. + Cat 3
– Manufacturer constructed Technical File >>
Declaration of Conformity (issued by
manufacturer on own responsibility)
Baseefa
ATEX Advantages
• Flexibility
– need not stick to exact wording of standards
if alternative justification against EHSRs is
contained in Technical File
• BUT
– Not transparent as the only publicly
available document is the Declaration of
Conformity
– Technical file invisible to purchaser
Baseefa
IECEx Advantages
• Transparency >> Confidence
– Conformity is exactly against requirements
in declared IEC Standards and Certificates
are available on web site
• BUT
– Cannot use useful developments in draft
standards until finally published and
included in ExCB scope
Baseefa
ATEX Advantages
• Notified Bodies are readily appointed by
Member States
– Plenty of choice for manufacturers
• BUT
– Some bodies have limited expertise and basis
for notification is not clear
– Some bodies treat essentials (such as
provision of a report) as a chargeable extra
Baseefa
IECEx Advantages
• Appointment of ExCBs and ExTLs is by a
system of peer assessment
– Transparent and leads to mutual confidence
– Reporting is obligatory and subject to random
peer review
– Leads to customer confidence in the scheme and
therefore value of certificates
• BUT
– Prevents those that may be so inclined from
cutting corners
Baseefa
The Route for Europe
• Target End Point
– IECEx Certificates of Conformity fully
accepted without further paperwork
• Problem
– IECEx is about Safety
– ATEX is about Trade
– European Commission would need to change
the whole structure of its approach to
trading directives !
Baseefa
The Route for Europe
• Interim Solution 1
– IECEx Documentation accepted with an
ATEX “Cover Sheet”
– All the technical work is done once within
the IECEx framework
– Possible currently for all 60079 series
standards plus some others
Baseefa
Interim Solution 1
• Works best when single body does all the
work
– ATEX QAN based on IECEx QAR
– EC-Type Examination Certificate based on
ExTR
• N.B. Purpose of IECEx CoC and EC-
Type Examination Certificate are
different
Baseefa
Interim Solution 2
• Involving two certification bodies
– One outside Europe
– One inside Europe
• Need for additional report to show how
the ExTR is accepted for ATEX
• Need for QAN based on QAR
• Issues of accreditation, notification and
public liability insurance for the
European Body
Baseefa
Interim Solution 2
• The ATEX Notified Body has to take full
legal responsibility and show the
necessary paperwork
• The Notified Body is responsible to the
European Commission via its national
government
Baseefa
The Paper Trail
• All certification activities require a paper
trail
• The IECEx Scheme paper trail is
prescribed to a major extent within the
scheme
• The ATEX Directive does not prescribe
particular forms of paperwork
Baseefa
The Paper Trail
• The IECEx paper trail is satisfactory for
ATEX
• Most forms of paper trail devised for
ATEX would not be acceptable for
IECEx
– It is not unknown for a European Notified
Body to refuse to release the report to its
customer !
Baseefa
The Baseefa Philosophy
Production Control
• All work being done for ATEX QANs is
being reported in a format acceptable for
an IECEx QAR
• The customer gets exactly two for the
price of one
• We do no extra work, so there is no extra
charge
Baseefa
The Baseefa Philosophy
Design Test and Assessment
• If our customers are able to use
standards acceptable to IECEx, there is
no extra charge for the technical work
• There are additional sheets of paper to
cover ATEX and IECEx, but the cost is
minimal for most projects
Baseefa
IECEx plus ATEX
The Benefits
• For very little extra cost
– Future proofed acceptability
throughout the world as the IECEx
Scheme grows
– Legal acceptability in Europe
Baseefa