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Thoughts on the EC guideline for breathing air filling systems

WHY ``MADE IN GERMANY``

The existing legal provisions are partly replaced or repealed by the European Pressure Equipment Directive, whose 5-year transitional or implementation period began on 29.11.1999. This means that during these 5 years the national pressure vessel regulation and the new EC directive can be applied. If a manufacturer certifies a pressure vessel or assembly after 29.11.1999 under the new EC Directive, this certification and the associated treatment under the new EC Directive must be recognized by the authorities of the member countries.

Over and over again, fill station operators are making a big deal of dissatisfaction and misunderstandings, because some authorities are still struggling with the implementation of the new guidelines and in some Länder are steadfastly ignoring this EC directive and even federal guidelines.

Contact person

Sebastian Mayer

Mayer Sebastian - Made in Germany

IDE & Bavaria Compressors

In many discussions on this subject, it quickly becomes clear that no arbitrariness or harassment on the part of the authorities is shown here, but it is often rather due to the uncertainty in the application of the new provisions and above all in the for us Germans (by the way, some of our neighbors think the same way here) a serious step backwards from the safety standards we have achieved, for which the licensing authority may eventually end up in the event of an accident must stand up.

The liberalization of pressure vessel and equipment provisions, which are intended to bring the safety standards to a common level within the EC in the future, will in some areas entail significant and not entirely harmless safety-related losses for the operators of such facilities.

At this point you should be demonstrated by an example, why here (in my view with right, opinion of the author) some authorities, and above all the experts of the TÜV, with great concern at a new adapted and contemporary national regulation work and with Permits currently so hard to do.

Example:

The final filter housing made of aluminum from a known compressor manufacturer from other European countries corresponded to the German Pressure Vessel Ordinance a pressure vessel class II.

(Volume content x max pressure = <200) in this case (0.749 L x 265 B = 198.49)

Class II pressure vessels did not require a type examination, but only a manufacturer’s certificate and a corresponding marking.

According to the new EC directive, the same pressure vessel with a volume content of 0.749 L can be loaded with an unimaginable 1000 bar without the requirement for a type examination or similar.

It only needs a manufacturer’s certificate from which it must be clear that this pressure vessel and its production correspond to “good engineering practice”.

To this end, the question, which everyone can answer themselves, is allowed: “What is good engineering practice in Germany compared to Portugal or Greece?”

Without wanting to get too close to our neighbors, this may be a serious difference, but for us it means a safety-related retrogression of several decades. Imagine that the Austrian counterpart to our pressure vessel ordinance, the steam boiler ordinance, which is almost identical in the most important points, still comes from the K + K monarchy.

Pressure vessels exceeding the value of 200 always require a type examination of BAM (Federal Office for Materials Testing). If the above-mentioned Mediterranean manufacturer manufactured 300 bar compressors and the corresponding filters, in order to save expensive type tests and costs, the filter tubes were shortened for simplicity, thereby remaining in class II of the pressure vessels. Of course, he did this only if German or Austrian customers demanded it (in other countries and especially in the country of this manufacturer, regulations do not interest regulations so much, especially if they are from other countries – they are far away). An action that would be unthinkable for German manufacturers for liability reasons alone.

As a conclusion, you can assume that responsible manufacturers in Germany or Austria are still using their systems in accordance with proven regulations such as Build “AD-Merkblätter” or “technical rules for compressed gases and pressure vessels”. This is a way to once again justify the proverbially so-called “Made in Germany” and thus to demonstrate technological progress and quality.

For decades Italian manufacturers preferred to buy German cars or German machines to make their products. This did not happen by accident, and the German manufacturers are well advised to remember the old traditions a bit and to use this security technological step back, as prescribed by Brussels, as an opportunity to win back a piece of “Made in Germany”.

There must be no compromise and certainly no setbacks when it comes to the safety of equipment and machinery. Rather, the backward countries must try to catch up with the help of high technology members. Technological regression brings no progress, no innovation and are therefore also a step backwards in education standard or cause an even more massive exodus of good professionals.

Under no circumstances should this article give the impression that the author or the industry is against Europe or wants to call for a boycott against some manufacturers from the member states.

The European idea is certainly not that every member gives up his identity. Europe is more and more in danger of technologically losing its already tarnished image, making it an increasingly convenient “partner” (or “takeover candidate” in the age of globalization and market takeover) for Americans.

One thing we can look down on and take advantage of the Americans, a little more national pride.

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