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Guideline A-37

  • WGP date: 15/03/2016

Question

  • Are items of pressure equipment such as manifolds, valves and piping used as well-control equipment and placed between a subsea well template and the processing platform for the oil and gas extraction and processing industry covered by the Pressure Equipment Directive (PED) ?

Answer

No

Reason:
The exclusion of Article 1 paragraph 2((i) applies to all the well-control equipment listed therein, plus all equipment UPSTREAM in relation to that well-control equipment.

Note 1:
In some cases, processing equipment is interposed on the seabed (e.g. separators) between the equipment listed in Article 1 paragraph 2(i) and the pipeline(s). In such cases, the processing equipment is covered by the PED.

Note 2:
The PED in general, and Article 1 paragraph 2(i) in particular, does not distinguish between subsea and surface equipment.

Note 3:
Specific solutions to essential safety requirements shall take account of the subsea use of this equipment, as a result of the hazard analysis.