DM 329/2004: commissioning and management of pressure equipment
DM 329/2004: commissioning and management of pressure equipment
A piece of pressure equipment that is compliant and correctly marked is not automatically ready to be used in an Italian plant. After manufacture and placing on the market, a second phase in fact begins, concerning installation, commissioning and the maintenance of safety conditions during operation.
This is the scope of DM 329/2004, one of the main Italian reference points for those who use pressure vessels, generators, piping and assemblies.
Which equipment does it concern, when is the declaration to INAIL required, and which obligations remain with the user after the plant is started up?
Let us look at how it works and why documentation management begins as early as the construction of the equipment.
What DM 329/2004 is and what it governs
Ministerial Decree no. 329 of 1 December 2004 establishes the rules for the commissioning and use of pressure equipment and assemblies. It came into force on 12 February 2005 and governs what happens after a piece of equipment has been placed on the market and installed within a plant.
|
Aspect |
PED Directive 2014/68/EU |
DM 329/2004 |
|
Phase |
Before placing on the market |
Use in Italy, after installation |
|
Subject |
Design, manufacture, conformity |
Commissioning, inspections, requalification, repairs/modifications |
|
Responsible party |
Manufacturer |
User / employer |
The difference from the PED Directive is important: the PED 2014/68/EU concerns mainly design, manufacture and conformity assessment before placing on the market, while DM 329/04 comes into play during the use phase in Italy and governs the first-installation check, the declaration of commissioning, the periodic inspections, requalification and repair or modification work.
“Commissioning” means the first use of a piece of pressure equipment or an assembly by the user.
Which equipment is subject to DM 329
The decree concerns various types of pressure equipment and assemblies, including steam or superheated water generators, vessels containing compressed, liquefied or dissolved gases, simple pressure equipment, piping and vessels for liquids that fall within the conditions laid down by the regulations.
Application does not, however, depend solely on the name of the equipment. Parameters such as the following must be assessed:
- maximum allowable pressure;
- volume or nominal diameter;
- type and hazardousness of the fluid;
- category of the equipment;
- configuration and method of installation.
The decree also provides for a number of exclusions. These include, within specific limits, equipment with a maximum allowable pressure not exceeding 0.5 bar, small-capacity vessels, certain piping, valves and components with defined characteristics.
To correctly establish whether a piece of equipment is subject to the requirements, it is therefore necessary to examine the specific case, avoiding the automatic application of the same procedure to every vessel or component.
Commissioning and the mandatory declaration to INAIL
When a piece of equipment or an assembly is installed and assembled by the user in the plant, a commissioning check may be required. The check serves to verify correct installation and is carried out at the request of the user company: if the outcome is negative, the equipment cannot be started up.
Today the notification is submitted to INAIL through the CIVA platform. If the equipment is not among those excluded from the check, the employer must also request the commissioning verification provided for by Article 4 of the decree.
The declaration must report the data of the individual items of equipment, such as pressure, temperature, capacity and operating fluid, and must include a technical report with the plant diagram, the installation and use conditions, the safety measures adopted and the statement that the installation has been carried out in accordance with the operating manual. Where required, the certificate of the first-installation check must also be attached.
The commissioning of pressure equipment is therefore not a purely administrative step: it links the manufacturer’s data to the actual installation and operating conditions.
The user’s obligations during operation
Once the equipment has been started up, responsibility for its correct management passes to the user, who must keep the identification data available, allow checks to be carried out, report any periods out of service and notify the subsequent restart.
The user must also submit the equipment to the inspections required for pressure equipment and to periodic requalification activities. These include operational and integrity inspections, with intervals that change according to the category, the fluid and the type of equipment.
Failure to meet the deadlines results in the equipment being taken out of service until the inspections needed for restart have been carried out.
To learn more about roles, checks and responsibilities, also read our article: Periodic inspections of pressure vessels: who carries them out and the manufacturer’s role. [link to the July article]
Conformity in operation begins with those who build the equipment
The obligations relating to the operation of pressure equipment fall to the user, but the ability to manage them correctly also depends on the quality of the design and the documentation received.
Nameplate data, the declaration of conformity, the operating and maintenance manual, material certificates, drawings and information on operating limits make it possible to identify the equipment, install it correctly and plan subsequent checks. The manufacturer’s instructions may also provide for more restrictive intervals than the ordinary ones, particularly in the presence of corrosion, erosion or phenomena capable of compromising structural stability.
At Baglioni we design and manufacture pressure vessels in accordance with the applicable European directives and the main international standards. Our certifications include PED, ASME, National Board, CRN and numerous registrations for specific markets and applications.
As a certified partner, we integrate technical and documentation requirements throughout the design and construction process, providing the customer with a solid basis for the installation, commissioning and subsequent management of the equipment.
Do you need to choose or commission a piece of pressure equipment for your plant? Contact us.
