Working for the European standards: is it worth while doing it?

I started working as a pressure vessel designer about 50 years ago. As all the young engineers, at that time I had no ideas about the work needed for the preparation and maintenance of Pressure Vessel safety standards: I simply knew that different standards, laws and regulations existed in the different countries, and that a pressure vessel designer is bound to their knowledge and use.

At that time those standards were composed only by a few pages, and the required design calculations were very simple. The usual device to make such calculation was the sliding rule, now completely disappeared from all the engineering departments, and possibly still to be found in some engineering museum. However in a few years this situation started to change: the first modern Italian standards (the so called “Raccolte ANCC”, which later became the “Raccolte ISPESL”) introduced new and more sophisticated calculation methods, which required more efficient tools to be performed in a reasonable amount of time. Fortunately this refinement of the methods went hand in hand with the evolution of computers, whose dimensions started progressively to decrease: so that the calculation power which in the 60s required enormous rooms filled with huge pieces of equipment, today can be found in much smaller devices, up to the dimensions of the modern laptops, or even to the smaller dimensions of tablets and smartphones.

But the increasing complication of the calculation methods caused other problems: in fact after the coming into force of the Raccolte (1973) the pressure vessel and heat exchanger manufacturer for which I was working discovered that the new rules had bugs and doubtful areas, that needed further amendments and clarifications in order not to jeopardize the design of some special units for which the company was particularly renowned. Having discovered that the industrial associations had the possibility to send delegates to the committees charged for the preparation of the Raccolte, in a few weeks the company became member of UCC-ANIMA (the Italian association of Pressure Equipment Manufacturers), and I became an expert of the “Commissione Calcolo” of ANCC (“Associazione Nazionale per il Controllo della Combustione”, the governmental inspection body responsible for the certification of Pressure Vessels and Steam Generators).

In that committee, responsible for the preparation of the Italian design and calculation standards (Raccolta VSR and Raccolta VSG), there were experts of all the main Italian manufacturers and users, as well as experts of ANCC. There I started to understand that different people may have different views on the safety of pressure vessels, and that different philosophies may exist on pressure vessel design. Of course all the design standards are based on the classic Construction Science; but Construction Science, although it makes large use of mathematical formulae, is not at all mathematics: in fact the concept of “safety factor” has nothing to do with mathematics, while it is more conditioned by the greater or lesser probability that unfavourable events will occur, such as materials having lower characteristics than the ones provided in the specification, or presence of various types of weld defects.

Moreover, apart from the almost obvious fact that pressure vessel engineers employed by inspection organizations tend to increase the safety factors while designers employed by manufacturers and engineering companies always tend to decrease them, a given safety standard may give priority to thicknesses and weights  (thus increasing the safety factors used in design), while another safety standard may give priority to material and weld testing, as well as to NDT examinations.

Having at the end found a solution for my company’s problems (the “Regola VSR.1.N.6”, concerning fixed thin tubesheets of heat recovery steam generators, was proposed by myself and approved by the Commissione Calcolo around the year 1975, and still exists in the Raccolta VSR) I received the warmest compliments by the company’s General Manager. But from that moment on, I cannot say that he was particularly happy about my participation to the meetings of the Commissione Calcolo (which were held in Roma), despite of the fact that I used to go from Milano to Roma and back by Sleeping Car, in order to spare money and time: of course I never received an official remark about those business trips: at the end I was a manager, so I had the possibility to organize my time without particular constraints, considering also that extra hours made by managers were not paid. However from time to time I was obliged to hear some minor comments like “Ah! Yesterday we were looking for you! You were in Roma again?”

However at the beginning of the 80s the Italian legislative and standardization system underwent a radical change: ANCC, which formerly was a private organization (although officially and exclusively mandated by the government to conduct all activities concerning the safety of pressure equipment), became part of ISPESL – “Istituto Superiore per la Sicurezza sul Lavoro” – a fully governmental organization subject to the Ministry of Health, with a joint responsibility of the Ministry of Industry and the Ministry of Labour. In this revolutionary change (the so called “Riforma Sanitaria”), some narrow minded politician decided that the Italian safety standards on pressure equipment should become binding laws of the Italian Republic, so that the most negligible detail of those standards could only be changed by means of a joint legislative decree of the three responsible ministries, and not by technical committees composed by experts, as it was before: in fact, considering that politicians have generally more important things to discuss than pressure equipment regulations, it took more than 15 years to get the first modifications of the Raccolte.

However in this period of time also the situation in Europe underwent a radical change: not so sudden as it was the “Riforma Sanitaria” in Italy, but in any case revolutionary, since it brought to a new and original philosophy about the entire setting of the technical legislation in Europe: the so called “New Approach”. In fact for years the European Commission had tried to issue laws on technical matters containing all the possible details about design, construction and testing of different products: not only pressure vessels, but also electrical devices, gas appliances, machines, toys, civil constructions, etc. But this attempts were always unsuccessful: in fact the difference in the safety standards and in the legislation of the various European countries were so important, that a common basis was very difficult to be found. On the other end the different procedures, standards, regulations and responsible authorities were causing great troubles to European manufacturers wishing to export goods in another European country: in the case of pressure equipment, a German manufacturer wishing to export a vessel into Italy was obliged to design it in accordance with the Raccolte, to use materials provided in the same standards and to get the approval from the central bureau of ISPESL in Rome, which later had to send an inspector to test the vessel at the manufacturer’s shop; and vice versa an Italian manufacturer wishing to export a vessel into Germany was obliged to use the German standards and to get the approval and the inspection visit of the competent TÜV department, with consequent additional costs in both cases.

Well, the main idea behind the New Approach was to establish a clear distinction between the Law and the Standards: in fact all the New Approach directives (the Law) should not contain the detailed prescriptions to be followed for the construction of a vessel, generally given in a pressure vessel standard, but simply the so called “Essential Safety Requirements”. The task to establish the details, that is to prepare the standards, was given to CEN, the European Federation of the various national standardization bodies (BSI for UK, DIN for Germany, AFNOR for France and so on): and since in the constitution of CEN it was officially provided that all the CEN members are obliged to replace their national standards concerning a given product with the corresponding European standards agreed in the CEN technical committees, in a few years the “harmonized standards”, that is the standards prepared considering a given directive, would have completely replaced all the existing national standards (at least, this was the theory). However the harmonized standards are not compulsory: they simply should give the so called “presumption of conformity” with the directive (in the case of Pressure Equipment, the PED = Pressure Equipment Directive), while the use of different standards (also non-European standards) is not prohibited. But the manufacturer should be aware that in this case he will have the responsibility to prove that the standard he is using is in full compliance with the Essential Safety Requirements of the Directive. The authorities charged for the verification of such compliance are the “notified bodies”, qualified by each country and authorized to work in the entire European Union.

To explain advantages and disadvantages of this new situation would take too much time: and more time would also be required to explain why this wonderful project, which is fully working for many other product types, is still causing some problems in the case of unfired pressure vessels, for which the transition from the various national standards to the corresponding EN standard (EN 13445), 16 years after the coming into force of the Pressure Equipment Directive, is still in course. As far as that young engineer was concerned (which at the end of the 80s was certainly less young, but probably with a little bit more experience), he had lost his role of expert in the Italian Commissione Calcolo ANCC, but he had started to represent his company in CTI (Comitato Termotecnico Italiano), a subsidiary of UNI (the Italian standardization body, member of CEN) officially responsible for pressure equipment. Although at that time the Pressure Equipment Directive was still in preparation, the principles of the new approach were already widely known: therefore all CEN TCs were already actively working for the preparation of the corresponding harmonized standards.

The CEN Technical Committee responsible for unfired pressure vessels is TC54, chaired by BSI, the British standardization body. Therefore according to the CEN rules, all the meetings are held in London. However 30 years ago it was not possible to hold a meeting without the help of two ladies responsible for the translations: in fact CEN has 3 official languages, English, French and German: so that the experts, coming from all the European countries (the countries of the European Union and the countries of the European Free Trade Area), could decide to speak in any one of the 3 official languages, but before getting a reply from any other expert they should wait until the two interpreters had completed the translation into the other two languages. Of course this procedure was rather time consuming, with the additional problem that sometimes the two ladies, despite their patience and good will, were not always in the position to fully understand the specific technical problems under discussion. The situation underwent a definite improvement with the creation of the Working Groups: A for general problems, B for materials, C for Design and Calculations, D for welding, E for inspection and testing. For each group a convenor was nominated, and separate meetings were held in the city where the convenor was based, using the English language only (which nowadays has become the rule also for the TC meetings). In 1990 I was appointed convenor of WGC (now WG 53), and from that moment on I have kept this position.

Fortunately in 1988 I had founded, with the help of some friends, my own company: so I was no longer exposed to the whispered comments of my bosses: I could finally decide to give a substantial percentage of my man hours to the standardization work. Of course I had always to justify to myself the time I was spending for the European standardization: and the real justification I was able to find was the fact that through the participation to this work, with the continuous comparison of my technical opinions with the sometimes different opinions of the other European experts, I was really growing in my profession: so that I can easily say that I have learnt more engineering in the latest 28 years than in the preceding 22.

In the years 1995-2002 all the experts working for the harmonized standards received a fee from the European Commission: but after the publication of the 2002 Edition of EN 13445, these retributions were suspended. What I was able to get, at least till 2012, was the reimbursement of the travel expenses for the plenary meetings of TC54, made by UCC-ANIMA; after that, my only saint in Paradise was Sant’Ambrogio. At the end, as I said before, I have always considered the man hours spent for standardization as training hours, for which I should possibly pay a fee to all the other experts coming from France, Germany, UK and many other countries.

For this reason, I was really surprised when the Pressure Systems Group of the British Institution of Mechanical Engineers decided to award me the Donald Julius Groen Prize 2017 for “Leading and developing the design rules of the European Pressure Vessel Code EN 13445 and a wider international contribution to European Pressure Systems”.  In 28 years of work for the European standardization this was the first time that somebody decided to tell me “Thank you, Fernando”: thanks that do not come either from my national standardization body or from the Management of CEN, but from a country which is now leaving the European Union: may be the task of building Europe should be better given to engineers than to politicians! Therefore I was very proud to accept the invitation to the annual Christmas lunch of this British group, despite of the fact that the amount of money I have received was less than the cost of the plane ticket from Milano to London: but the value of what I received in terms of esteem and affection from my British friends (David, John, Sarah, Simon, Tim) was far greater than the sum of money received with the prize.

 

Of course the task of building a European Pressure Vessel standard is less important than the task of building a bridge, a ship or an airplane: however I am confident that my small group of European pressure vessel engineers, who all believe in this work, will make further progress in order to update and improve a European standard which is becoming a model also outside Europe.