Routine examination of pressure vessel equipment during the Covid-19 pandemic
At DD, we appreciate that employers have many compliance issues to deal with during their working life let alone during the current pandemic, so this letter is to bring you up to date with the current advice about pressure vessel/plant equipment routine examination or testing during this difficult time.
UK safety of pressure systems legislation [1] together with associated guidance, is aimed at duty holders who are involved with pressure systems used at work. It is for users, owners, competent persons, designers, manufacturer’s, importers and installers of pressure systems used at work.
At the time of posting this information, and during our interactions with UK regulators, no indication has been given that compliance is to be ‘relaxed’ with respect to routine examination/testing of pressure vessel equipment. You should, therefore, continue to address this issue in order to comply with the legislation and any associated guidance. Recently issued guidance from the Health and Safety Executive (HSE) and British Compressed Air Society (BCAS) states;
- “Duty-holders have a legal responsibility to maintain work equipment and carry out thorough examinations, written schemes and Statutory Inspections. These legal duties exist to help manage the significant hazard that the failure of such equipment can pose. Not complying with these duties can significantly increase the risk of harm to workers and members of the public.
- HSE expects duty holders to make all reasonable efforts to arrange for TE&T to be carried out within the statutory time limits. This will include:
- Ensuring inspection bodies have access to equipment in a timely manner.
- Working with the inspection body to manage appropriate SD in the workplace, to satisfy both your needs and those of the inspection body, as part of the Government drive to manage the spread of COVID-19.
- If your business is not currently operating and staff are furloughed, consider allowing access to the inspection body so that equipment is ready for when your business reopens. Otherwise you may have to delay restarting that equipment until it has been subjected to a TE&T.
To access the full HSE guidance issued to Duty holders and Pressure Vessel Inspectors, please see: https://www.hse.gov.uk/news/assets/docs/loler-pssr-during-outbreak.pdf
You should, therefore, seek advice from your Engineering Company/Competent Person (CP) and Practice Insurance Provider/Pressure Vessel Insurance Provider. Our guidance, as a general principle, is that you should:
- Check the date of the last time each pressure vessel (autoclave and/or compressor) was subject to routine examination i.e. a pressure vessel inspection or test; this information should be available on the latest report you received from DD, or any other testing provider that you have used. Testing should be carried out as per the Written Scheme of Examination (WSE) which in most cases is every twelve months
- Check the inspection paperwork of the last time the pressure vessel (autoclave and/or compressor) inspection/test was completed, to confirm that the vessel was deemed fit for purpose/compliant, there were no remedial actions or comments from the Engineer/CP and that the pressure vessel is within its inspection date/test cycle.
If you identify that your pressure vessel equipment is due a routine examination/inspection test or remedial actions are required, you should plan for the equipment to be appropriately tested as soon as practicable and before your practice is due to re-open. The testing may be arranged through DD by calling 0800 028 1697 selecting option 2.
If you, as the employer, or your employer take the decision to postpone the routine examination/inspection test or any remedial work, we suggest that the reason and justification for this decision be documented in the practice’s plant equipment safety management documentation, as you or your employer, may need to be prepared to defend the decision during any future inspection or potential insurance claim.
Please note that if you benefit from the free block policy pressure vessel insurance cover provided through the DD Group, Allianz have stated the below:
- the Insured shall take all reasonable precautions to safeguard the Insured Property against loss or damage and
- the Insured shall maintain the Insured Property in an efficient condition and take all reasonable steps to ensure that all Government and other regulations relating to the operation and use of the Insured Property are observed.
If you should have any queries regarding the contents of this letter, please contact the DD Compliance Team via 0800 0281 697 selecting option 1 and then option 3 or email compliance@ddgroup.com
Many thanks for your continued support,
Donna Hickey
Head of Compliance
For and on behalf of DD Products & Services Ltd
