Challenges for plant engineering in the Customs Union · PDF fileTR CU 020/2011...

1

Th. Raßhofer, Linde AG Linde Engineering11th European Pressure Equipment Conference

Fürstenfeldbruck, June 30th 2015

Challenges for plant engineering in the Customs Union (Russian Federation)Experiences of an engineering company with the new regulations

Contents

1. Challenging environment

2. New approach # Eurasian Customs Union (EACU) & Member states

3. Demarcation of legal requirements

4. Legal obligations

5. List of recognized standards

6. Conformity assessment scheme – at a glance

206/2015 Th.Raßhofer, ENQS

6. Conformity assessment scheme – at a glance

7. Project execution – Building permit to L2O

8. Process plant – 'placing on the market'

9. Summary

1. Challenging environmentA Déjà-vu with Europe

New legal requirements and changes of given legal requirements result in

• confusion about execution model regarding conformity assessment of single equipment and

package units, piping and process plant

• changes in split of legal responsibilties of SUPPLIER, LINDE Engineering, LE Rus

and USER / CLIENT

• changes in work-flow and interfaces


• changes in work-flow and interfaces

• necessity of involving partnes located in EACU

• new compulsory and recommended codes & standards

ü The change is neither completed nor uniform adopted

Equipment not covered by a TR CU

The obligation for attestation acc. to member

state requirements remains valid

TR CU 010/2011 ".On the safety of machinery and equipment"

TR CU 032/2013 "About safety of equipment operating

under excessive pressure"

TR CU 012/2011 "On the safety of equipment for works in explosive

atmosphere"

TR CU 020/2011 "Electromagnetic compatibility of technical equipment"

TR CU 004/2011 "On safety of low-voltage

equipment

TR CU 011/2011 "On safety of lifts

32 Technical regulations of Customs Union

2. Eurasian Customs Union (CU) & Member statesNew approach (Superordinate & federal set-up)

Belarus RussiaKazakhstan

4

Equipment neither covered by any regulation

SUPPLIER may provide an exemption letter, known as

'Letter of Refusal'.

Equipment covered by member state regulation:

• Pattern Approval (Metrology R), for all measuring

devices that fall under Federal Law “About Measuring

Unity”

• State registration certificate

(EEC hygienic registration)


KyrgyzstanArmenia

ü Certification bodies and testing laboratories accredited in the CU

monitor and assess compliance with the EACU market rules

ü Clarify application of TR CU regulations for Armenia and Kyrgyzstan

3. Demarcation of legal requirementsSurveillance power and responsibly – in the past

Design Installation

"116-FZ Federal Law on Industrial Safety of Hazardous Industrial Objects"

OperationMaintenance,

Repair,

Disposal


Responsibility

USER

ü Russia: Rostekhnadzor (RTN)

Federal State

Survelliance body

3. Demarcation of legal requirementsSurveillance power and responsibly - today

Design Fabrication

"Placing on the market"

OperationMaintenance,

Repair,

Disposal

"Intended operation"


Responsibility

Manufacturer

Responsibility

USER

ü Russia: Despite of the division of market surveillance an agreement of collaboration between

Rosakkreditatia and Rostekhnadzor (RTN) still exists !

Supranational

Survelliance body

Federal State

Survelliance body

4. Legal obligationsNew roles and duties influence supply-chain and lead times

Subject Reference What to observe

Legal entity See definitions in applicable TR CU's and EAC decision no. 621 dated 07.04.2011 andEAC decision no. 76 dated 09.04.2013

Attention: TR CU applicant must be registered in accordance with the legislation of the Russian Federation on its territory; with other words a legal entity is needed. I.e. responsibility is with an 'OOO' (like a GmbH, Ltd.)

Identification by means of the state main registration number of the company (OGRN) and tax number (INN).

Ratification of 'applicant contract' may become time

7Th.Raßhofer, ENQS

Ratification of 'applicant contract' may become time consuming

Manufacturer responsibility

For equipment subject to TR CU regulations dedicated persons/organizations and statutory obligations are defined, i.e. designer, manufacturer (or his authorized person), user and certification body.

Comparable to EU regulations like inDirective on machinery and Directive on Pressure Equipment etc.

Products subject to a TR CU must be affixed with the unified turn over mark and/or Ex mark.

Warranty EAC decision no. 621 dated 07.04.2011

Legal body to affirm

06/2015

5. List of recogonized standardsManufacturer is obliged to obtain presumption of conformity

List of standards which ensures compliance

with

TR CU 032/2013 "Pressure equipment "

(EEC Decision No. 22, dated Feb 25, 2014)

List of standards which ensures compliance

with

TR CU 010/2011 "Machinery & Equipment "

(EEC Decision No. 823, dated Oct 18, 2011)

Equipment shall be designed and manufactured so that it ensures its conformance to safety

requirements in the course of its intended use, operation and maintenance.

Compliance of the equipment to the safety requirements is provided by:


European (EN) and ISO standards adopted by Russian Federation and Belarus are considered to

provide presumption of conformity with the respective TR CU essential safety requirements

ü Use of other standards requires a particular assessment by the manufactuer & A.B

against TR CU essential requirements and standards listed in the applicable EEC Decisions

(EEC Decision No. 22, dated Feb 25, 2014) (EEC Decision No. 823, dated Oct 18, 2011)

ü Not a single American standard is cited

ü For machinery and equipment sourced in one of the member states of the EACU, locally

established code of construction should be selected from the respective list of accepted standards

6. Conformity assessment - at a glanceEEC decision no. 621 – An approach similar to Europe ?

Conformity assessment schemes have to applied

Manufacturer to provide a set of 'compulsory documents' at the time 'placing a product' on the market

Manufacturer to form documents to show compliance with the essential TR CU requirements

ü 'Placing on the market'

A product is placed on the market when it is made available for the first time on the Union market

9Th.Raßhofer, ENQS06/2015

ü Russia; RTN 'permit for operation' for new objects is not required and not issued anymore.

Previously issued permits remain useful for reference purposes and as additional confirmation of

safety. Expert Conclusions can still be obtained, if requested by the USER/CLIENT

For products out of TR CU scope federal attestation process have to be complied with

6. Conformity assessment - at a glanceTR CU 032/2013 and TR CU 010/2011, overlap for some products

For example …..

TR CU 032/2013Scope

§ Pressure Vessels

§ Valves, larger DN 25

TR CU 010/2011Scope

§ item 9. Chemical and oil and gas refining equipment

§ item 59. Industrial piping accessories


ü European manufacturer's associations have an opinion about. In CU no recognized discussion.

ü As a consequence, manufacturer should be prepared to serve both TR CU

Query è A contradiction, ambiguity or a conscious requirement ?

The consideration of application-related hazards should help to solve this subject in question

6. Conformity assessment - at a glanceEach TR CU has it's particular set-up; Example TR CU 032/2013

Hazardcategory

Production type SchemeTests

conducted by

Production assessment(audit) by

Manufacturingsupervision by

Declarant

1, 2

Batch (serial) -producedequipment

1 d- Test lab., or- Accr. test lab.

n/a Manufacturer- Manufacturer or- Person authorized by manufacturer

Single batch of equipment(or one-off item)

2 d- Test lab., or- Accr. test lab.

n/a n/a- Manufacturer,- Vendor, or- Person authorized by manufacturer

Batch-produced components and component parts(for equipment of hazard cat. 1 or 2)

3 d - Accr. test lab. n/a Manufacturer- Manufacturer or- Person authorized by Manufacturer

Single batch of components and component parts(for equipment of hazard cat. 1 or 2)

4 d - Accr. test lab. n/a n/a- Manufacturer,- Vendor, or- Person authorized by manufacturer

1, 2, 3, 4 Equipment which is finalized using 5 d- Equipment type examination 1)

by cert. bodyn/a Manufacturer

- Manufacturer or- Person authorized by manufacturer

Batch (serial) - produced


1, 2, 3, 4 Equipment which is finalized using permanent joining at site

5 dby cert. body

n/a Manufacturer- Person authorized by manufacturer

3, 4

Batch (serial) -producedequipment

1 c- Accr. test lab.,- Evaluation by cert. body

Cert. body Cert. body- Manufacturer or- Person authorized by manufacturer

Single batch of equipment 3 c- Accr. test lab.,- Evaluation by cert. body


One-off item 4 c- Accr. test lab.,- Evaluation by cert. body


Equipment purposed for launching into batch and mass production as well as in case of planning equipment modifications

7 c- Equipment type examination

by cert. bodyCert. body Cert. body

- Manufacturer or- Person authorized by manufacturer

1) Type-examination certificate in the Eurasian Economic Commission approved form. This certificate shall be an essential part of the DoC

ü What about conformity assessment of components for equipment of hazard category 3 and 4?

ü Do not apply scheme 5d for field constructed piping spools and piping systems (pipelines)

6. Conformity assessment - at a glance

Process – foreign scenario

The Manufacturer’s authorised (Applicant) is to perform

all the obligations of a foreign Manufacturer to ensure

compliance with the regulations of the CU


7. Process Plant – Building permit to L2O A statutory predefined sequence for new Hazardous Industrial Objects

Stage # Action Legal Reference

Building

Permit

1 Licence for project planning/engineering (SRO membership; SRO = self-regulated organizations) Prikaz No. 624 dated 30.12.2009

2 Basic data / basic engineering Regulation dated 30.01.2002

3 Engineering - technical researching (SRO licence) Prikaz No. 624 dated 30.12. 2009

4 Unified system for design documentation, Specifications GOST 2.114-95 dated 01.07.1996

5 Basic engineering - (SRO licence) Decree No. 87 dated 16.02.2008

6.1 Expertise of the Project P documentation Decree No. 145 dated 05.03.2007

6.2 àGLAVGOSTEXPERTISA 190-FZ dated 29.12.2004, Art. 49, P. 4.2.

7 Construction (Licence) and supervising Prikaz No. 624 dated 30.12.2009, CN 11-110-89

8 Inspection and confirmation of ZOS (GOSTSTROINADZOR) Decree No. 54 dated 01.02.2006

9 Permit after Construction Codex 190-FZ dated 29.12.2004, Art. 55

13Th.Raßhofer, ENQS

Licence to

operate

(L2O)

11 Change in surveillance power in legislative acts 186-FZ dated 02.07.2013

12 Categorization of hazardous production facility – process plant116-FZ dated 20.06.1997, Art. 2

amended by 22-FZ dated 04.03.2013

13.1 Conclusion of Expertise of Industrial Safety for the process plant 116-FZ dated 20.06.1997, Art. 13

amended by 22-FZ dated 04.03.201313.2 Registration within 5 working days in Register of Industrial Safety Expertise Conclusions

14.1 Development of Declaration of Industrial Safety 116-FZ dated 20.06.1997, Art. 14

amended by 22-FZ dated 04.03.201314.2 Registration within 5 working days in Register of Industrial Safety Declarations

15 Expertise PLAS, Attestation of involved personnel116-FZ from 20.06. 1997


16 Program and Methods for Acceptance Testing in Service (i.e. ISI)116-FZ dated 20.06.1997, Art. 16


17 L2O of process plant by RTN, incl. plant registration in the state register Postanovlenie No. 454 dated 05.05. 2012

Conformity

Assessment

10.1Conformity assessment acc. to TR CU or GOST R/TR for equipment constituting process plant by

manufacturer or applicantEEC Decisions 319, 620, 621

10.2 Applicant must be a legal body registered in the EACU 129-FZ dated 08.08.2001

10.3 Issued DoC or CoC to be registered in Unified Register of DoC and CoC 99-FZ dated 04.05.2011

06/2015

8. Process Plant – 'Placing on the market'Assessment of Machinery Units and Package Units acc. to TR CU 010/2011


Burning platform : Is a machinery unit, a package unit or a process plant subject to an conformity

assessment in acc. with TR CU 010/2011?

• Machinery unit è always

• Package unit è depends, may be voluntary

• Process plant è legally not required and even not prohibited

06/2015

ü Clarify expectation with the USER/CLIENT

ü Assembly approach like in the PED hasn't adopted

8. Process Plant – 'Placing on the market'Superordinate EACU market rules meets RF federal rules

'Project P'

documentation

USE

R/

CLIE

NTRegister to

RTN

Rules of industrial

safety of hazard

facilities

USER

&

RTN

Inspection &

DocumentsFeed/Basic documents

RDI


Eng

ine

eri

ng

co

mp

an

y

TR CU

CertificationPID

HAZOPConformity

Assessment

Manufacturers

Equipment

Documentation

Engineering

Documentation

E.C.

&

A.B.

Handover

Documentation

ü USER is required to have and perform a 'program of inspections'

Documents

9. SummaryRecommendations to manage the challenges

Establish on a early stage a concept for the conformity assessment

Consider currently longer lead times and higher efforts

Clarify in due time responsibilities and scope


ü Lead an active communication with the parties involved

06/2015

Select as soon as possible an accredited body or a service provider

Pay utmost attention to the content of the 'Project P documentation'

Establish a handling process for the 'compulsory documents'

Thanks for your attention.

Refrain from trying to understand Russia, just belief in it.

Challenges for plant engineering in the Customs Union · PDF fileTR CU 020/2011...

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