Covering the documentation for both UKEX and ATEX this section is primarily aimed at site owners and end users', although it is of interest to systems integrators and panel builders who may have to supply the appropriate documentation to the end user.
Documentation required for manufacturer product certification is currently outwith the scope of this site although some may wish to take heed of the end users expectations as it is not unusual for manufacturers to supply documentation which is not 100% compliant
The 'hazardous area' industry is a conservative industry and changes happen slowly and they are almost always backward compatible. However, there have been a number of step changes and the documentation requirements historically can be split into 4 distinct periods where there have been significant changes.
For supply to Europe the CE marking remains the same as per the 2014 Atex Directive. Even though former UK Certification companies had their Notified Body status revoked all have re-applied via offices based within Europe and the net result to clients is no change.
For the UK, Brexit has brought changes to the Hazardous area certification
UK Documentation Requirements
Documents required
Technical file to include:
- UK or EU Declaration of Conformity(s)
- Installation/Product Manual
- EU or UK Type Certificate(s)
or details in manual
If intrinsic safety used
- Descriptive System Documents
Now the UK has fully left the EU the Atex Directive is not applicable with the relevant regulation being Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016 which was ammended in "The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019" (Statutory Instrument No 696. Section 25).
This requires the use of UK Type Certificates and UK Declaration of conformity.
However, following a u-turn by the government CE marked equipment (i.e Atex Certification) will be allowed indefinately.
Although the requirements for Hazardous Area certification are absolutely clear and Atex Type Certificates are allowed, the use of EU Declaration of Conformity for Atex labelled equipment within the UK is open to interpretation.
The status of a legal document (the EU Declaration of Conformity) which is declaring to a directive which does not apply to the UK is undefined.
We are no longer part of the EU legal framework, Atex is a legal construct not product certification. That is rather academic as it is 'whatever the end user decides to accept' until it is tested in a court of law and the regulations are unclear, they just say a 'Declaration of Conformity'
For equipment placed on the market April 2016 - January 2020
Documents required
Technical file to include:
- EU Declaration of Conformity(s)
- Installation/Product Manual
- EU Type Certificate(s)
or details in manual
If intrinsic safety used
- Descriptive System Documents
Since the 2014 Atex Directive replaced the 1994 Directive in 2016 the documentation requirements changed.
An EU Declaration of Conformity was required, which is a legal contract under EU law, confirming compliance to the 2014 Directive. The EC Declaration was no longer valid as it declared to the 1994 Atex Directive which had been revoked.
Supply of Type certificates, which are supporting evidence for the EU DoC's, were no longer mandatory providing the relevant information was supplied elsewhere e.g. in the installation or product manual.
Both EU Type certificates and the earlier EC Type certificates can be used to support an EU DoC.
If intrinsic safety circuits are used then Descriptive System Document(s) must be produced to demonstrate Intrinsic safety compliance the only exception is for self contained circuits e.g. portable equipment.
This is currently the requirement for any equipment supplied to the EU or UK
For Atex equipment placed on the market 2003 to April 2016
Documents required
Technical file to include:
- UK Declaration of Conformity(s)
- Installation/Product Manual
- EU or UK Type Certificate(s)
or details in manual
If intrinsic safety used
- Descriptive System Documents
This also applies to any Atex certified equipment prior to the 2003 mandatory implementation date. Early Atex equipment was labelled EEx to differentiate it from non-Atex hazardous area equipment labelled Ex.
Prior to the 2014 Atex Directive the EC Type Certificate was the mandatory evidence of compliance, this could be a notified body certificate for Category 1 & 2 or a manufacturers certificate for Category 3.
In addition the manufacturer should have supplied an EC declaration of conformity in order to CE Mark the product. However, evidence has shown that the Atex directive seemed to be largely ignored on many manufacturers EC DoC's.
As the Type certificate was merely a statement from the Notified Body that in there opinion the 'sample' submitted met the required standards, there was no real comback on the Notified Body at a later date.
This was recognised, which resulted in the European New Legal Framework (NLF) where Directives were rewritten resulting in the 2014 Atex Directive with the emphasis on liability with the complete supply chain.
For equipment placed on the market prior to 2003
Documents required
Technical file to include:
- Type Certificate
- Risk analysis
If intrinsic safety used
- I.S. System Cert
or drawing
The Atex equipment Directive 944/9/EC became mandatory in 2003, but equipment to the Atex standard started appearing in 1998. Early Atex certified equipment would be identified by EEx rather than just Ex.
Pre-Atex equipment was governed by national standards with certification based on Type Certificates. For intrinsic safety some manufacturers provided a system certificate similar to a Descriptive System Document outlining the circuit that the apparatus could be used in.
In the UK a hazardous Area type certificate from an approved issuer is required for equipment to be used in Zone 0 and Zone 1 and a manufacturers certificate was allowed for zone 2.
Installed Equipment certified pre-Atex can still be used if it has not been altered in form or function since the original installation, but a full risk assessment must exist and it is recommended to include a gap analysis against a you a more recent standard.
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