Author: Richard Holohan, director, BioPharma Engineering Steam boilers, steam receivers and air receivers were previously subject to the requirement of the Factor Act 1955. Those acts detailed the construction and fittings must be suitable and gave requirements for periodic examination and prescribed reports to be used for such equipment. The 2013 Irish Pressure Systems Regulation (Safety, Health and Welfare at Work General Application Amendment Regulations 2012 – Addition of Part 10 and 12 - Pressure System) came into operation on 1 January 2013. The new legislation means that there are now a number of pressure vessels, pressure equipment and systems that have a statutory requirement for inspection and examination that were not covered under the previous regulation. It should also be noted that the new regulations are similar, but not identical, to the UK Pressure Systems Safety Regulations 2000. The scope of the Pressure Systems Regulation Act (PSR) applies to pressure vessels, pressure equipment (e.g. heat exchangers, filters, dryers, instruments) and pressure systems (e.g. pressurised process equipment and piping that includes a pressure vessel). It also applies to systems containing a relevant fluid such as steam at any pressure, gas at >0.5BarG and liquid that exerts a vapour pressure of >0.5 BarG at maximum operating temperature or 110^oC. This will also include any process vessels that contain relevant fluids that are purged/inerted with nitrogen and/or at max operating temperature relevant fluids that can exert a pressure >0.5BarG. [login type="readmore"] A number of exclusions from the regulations are listed in Schedule 12 (Part A):

	Exclusion	Typical Exclusion
2	Water systems <110degC	Mains water and purified water systems
8	Hydraulic systems	Hydraulic power packs associated with equipment control (e.g. filter dryers)
14	Radiators and piping associated with space heating	Water-based heating, ventilation and air-conditioning equipment
22	Vapour compression-based refrigeration systems where total installed power<25kW	Chillers below the 25KW threshold (note: most chillers are likely to be above this threshold)
26	<0.5 bar MAWP	e.g. Atmospheric solvent storage tanks, vessels with PSV/Disc Set P<0.5 BarG
27	< 250 bar litre for non-steam systems	E.g. 500L vessel with DP<0.5 Bar, 40 litre DP=6Bar – this excludes cartridge filters, pumps and other small volume vessels.

Any pressure vessels, pressure equipment and pressure systems that fall under the remit of the PSR will take on a number of requirements including:

• Clearly identified labeling including unique ID and safety operation limits;
• A frequency of statutory examination by competent person with Cat 1 – steam generation equipment at 14 months and Cat 2 – all other pressure vessels at 26 months, including protecting devices and pressure accessories associated with the vessel;
• A report of examination must be completed by a competent, independent person and must be a separate independent report that is not a maintenance or operational activity;
• All employees (user and non-users of pressure equipment) to be made aware of health and safety risks of pressure systems near their place of work;
• Sufficient information on safe use and operation, abnormal situations, emergency action, inclusion of learning from previous ‘incidents’ on pressure equipment/systems;
• Employers should ensure that designers and installers employed are aware and comply with their own obligations under the PSR regulations, including sufficient written information on any modification/repair to equipment to the user of a system before the system is put back into operation;
• Examination is also required after a major modification or repair where it is significant in relation to the vessel being able to withstand pressure or at the request of the Health & Safety Authority;
• New pressure systems must be inspected by a competent person and safety devices tested prior to first commissioning;
• A maintenance file must be maintained for pressure systems life and handed over if the equipment is sold;
• Pipework is excluded from periodic examination (but will be part of a pressure system from a new installation and maintenance aspect).

For existing users, a survey of existing pressure systems, equipment and vessels will be required to generate the pressure vessel register required under regulation 193. This will also allow items to be checked against the Schedule 12 (Part A) criteria to determine if covered under the scope of the regulations. For each equipment item, establish broadly as Schedule 12 (Part C) nameplate requirements plus additional relevant information. Data that should be gathered to compile the register is:

• Type: e.g. reactor, storage tank, filter, filter-dryer, heat exchanger;
• Manufacturer;
• Serial number;
• Equipment number;
• Date of manufacture;
• Vessel code/standard (e.g. ASME Div 1);
• Design pressure/minimum and maximum allowable working pressure;
• Design temperature/minimum and maximum allowable working temperature;
• Volume (total and nominal) – to establish bar litre value;
• Bursting disc/relief valve set point;
• Bursting disc/relief valve tag number/make/model;
• Contents: relevant fluid – steam or other – to establish if it is Cat 1 or Cat 2;
• System piping and instrumentation diagrams to identify the scope of each pressure system and pressure vessel associated pressure accessories.

In summary, the failure of pressure systems can result in fatalities and serious injuries and cause major damage to property. The PSR regulations aims to provide a robust regime for the management of pressure systems and also to include pressure systems that were previously not part of the Boiler Explosions Act or Safety in Industry Acts 1955 and 1980 into a statutory regime with duties and responsibilities clearly defined for employers, employees, designers and contractors. Richard Holohan is a director in BioPharma Engineering. BioPharma is a multi-disciplinary design firm that focuses on engineering design and project delivery in the pharmaceutical sector, with a strong emphasis on process engineering and project management. Further information can be found at www.bpe.ie.