The Guidebook, do I apply or not apply?

What is the Guidebook? Who is it for and what is it used for?

What is the Guidebook?

The Guidebook is a“Professional Guide for the Development of Professional Guides and Technical Books for the Development of Inspection Plans for the In-Service Monitoring of Pressure Equipment and Simple Pressure Vessels(GPI 2019-01 rev 0 Version 0 of March 26, 2019).”

This professional guide has been prepared in application of the 2nd paragraph of article R.557-14-4 of the environmental code

And Article 13-IV of theMinisterial Order of November 20, 2017

Refer to ” Guidebook “I. INTRODUCTION and Chapters I.1 Purpose and I.2 Regulations, for more information

Who is the Guidebook for?

The Guidebook allows manufacturers who do not have a Recognized Inspection Service (RIS) to monitor their pressure equipment through an inspection plan.

What is it used for?

It gives manufacturers the possibility of derogating from the general regime for monitoring pressure equipment, and in particular from the rules on inspection and requalification periods to which they are subject.

When applying the Guidebook, do manufacturers without a CRS have the same benefits as manufacturers with a Recognized Inspection Service (RIS)?

The advantages and constraints are the same, whether the manufacturer has a CRS or not. We will review different examples in several applications.

The organization

The competence of the personnel must meet point 4 of Article 2 of theMinisterial Order of November 20, 2017, which means that the industrialist must have at least one competent person in its midst who meets all the requirements, namely all the required knowledge.

It is important to note that the training of a competent person is equivalent to the training of a Certified Plant Technical Inspector Level I or II for an Inspection Department.

Development of the Inspection Plan

An operator developing an IP must haveone or more individuals within their organization who areknowledgeable about the regulations and standards applicable to the equipment being tracked (e.g., codes and standards). In addition, this person or these persons have specific skills for the following missions:

• Determination of degradation modes,
• The drafting of the Inspection Plan following the structure described in III.4.
• Etc.

Implementation of the Inspection Plan

An operator, for the implementation of an IP, defines the organization and skills needed to:

• Carry out the monitoring actions foreseen in the Inspection Plan and analyze the results of the controls,
• Monitor the implementation of the Inspection Plan
• Etc.

However, there is a notable difference, depending on whether or not the manufacturer has a CRS:

• For an industrial company with a recognized inspection department, it has total autonomy insofar as it respects the corresponding rules and regulations
• For an industrialist who does not have a Recognized Inspection Service, he must set up an equivalent system, but must call upon an OH (Authorized Organization) which becomes in a way the guarantor of the system, subsisting to the supervisory body the DREAL

All these constraints imply that the industrialist who does not have a CRS :

• Has personnel capable of carrying out this task.
• Set up the whole system and the organization that follows
• Use an OH to approve its organization and inspection plans

In conclusion

For an industrialist who does not have a large fleet of pressure equipment, he must ask himself the question and analyze the merits of taking this step, because it will generate direct costs (personnel and organization ) and indirect costs ( the intervention of an OH )

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