Suggested Answers to Questions on Repair of ATEX Plant
IMC: 12/02/05
Suggested Answers to Questions on Repair of ATEX Plant
General points
a)It is always the owner of the plant who must take responsibility for repairs to, or changes of duty of, his plant.
b)For changes of duty, the manufacturer’s instructions should be consulted. If there is any doubt, or the proposed change is outside the scope of duty specified by the GOEM, the plant owner should approach the GOEM for guidance.
c)It might be possible for the GOEM to extend the conformity assessment of the item to include a new duty or to cover modifications carried out by the plant owner.
d)ATEX conformity assessment always culminates in the GOEM issuing a declaration of conformity and supplying a copy, along with the instructions, to the end user. For Category 1 non-electrical products (e.g. pumps) and Category 1 and 2 electrical products (e.g. motors, instrumentation), the declaration needs to be backed up by an EC Type Examination Certificate and a Quality Assurance Notification (or a Verification Certificate) issued by a notified body. A notified body is a certification body appointed by the regulatory authorities (DTI in the UK) for conducting ATEX conformity assessment procedures. There is no legal requirement in the directive for the GOEM to supply copies of the certificates and notifications issued by the notified body. However the end user might require them as a contract condition.
e)In the case of a Category 1 non-electrical product or a Category 1 or 2 electrical product, it would be possible for the plant owner to apply directly to a notified body for the certification of the change of duty or the modification. However this could prove difficult unless the GOEM gives permission for his certification file to be accessed by the notified body.
f)Spare parts It is important to note that a spare part which is placed on the market as an item of ATEX equipment (or an ATEX component) must be replaced by an equivalent part when carrying out plant repairs. These items can be identified by their individual nameplates bearing the CE and markings.
Questions
Note: The “self-certification” referred to in these questions is taken to mean a risk assessment that the plant owner carries out under DSEAR to ascertain that the plant is suitable for its intended use.
1. A client has an existing non-certified piece of plant that's duty remains constant - Can this be self certified (risk assessed) by the normal means?
Yes
2. A client has an existing non-certified piece of plant & wishes to change the existing duty - Should he replace this piece of equipment for ATEX certified?
- No, if the changed duty is within scope of the manufacturer’s specification and the plant owner’s risk assessment concludes that it is suitable for the new use.
- If the plant is not capable of performing the changed duty and needs to be replaced, it must be replaced by an ATEX compliant one.
3. A client has an existing non-certified piece of plant that he repairs using GOEM spare parts & had previously carried out a self certification - will the existing self certification still be valid?
Yes, provided that the repair has restored the plant to its original condition.
4. A client has an existing non-certified piece of plant that he repairs using copied spare parts & had previously carried out a self certification using GOEM spare parts - will the existing self certification still be valid or would it be possible to re-certify knowing that the parts are not GOEM?
The existing “self-certification” will be valid provided that the repair has restored the plant to its original condition. The plant owner is responsible for the adequacy of the repairs that he carries out, or has carried out on his behalf, and of the parts that are used.
5. A client wishes to use a self certified or ATEX certified piece of plant on an alternative duty - will he need to carry out another self certification or apply to the governing body / GOEM for another certificate?
If the duty is outside the scope of the manufacturer’s specification then the plant owner must approach the GOEM for a new or amended declaration of conformity. For items requiring notified body certification, the GOEM would need to obtain the necessary supplementary certificate before being able to issue the declaration.
6. A client modifies a piece of plant for safety or environmental reasons but the duty remains the same - will he need to contact the GOEM to advise them of the changes or the governing body or would a self certification suffice in this instance?
If the modifications in any way affect the explosion safety properties of the plant, then the appropriate ATEX conformity assessment procedure must be followed. In case of doubt, the GOEM should be contacted.
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