Skid or machine?

Installation or machine?

Assembly or machine?

Interesting questions, specially if you are about to run a multi-billion USD value technology, and it turns out to be one solo machine rather than a complEx technology / installation / assembly.

Machine means it is a product of a manufacturer, so there is one manufacturer. In European Union there is a CE declaration of conformity (DoC), installation and operation manual (IOM), and in case it comes to possible hazardous environment (Ex Zone), then compliance to ATEX is a mandatory (minimum) requirement and local regulations shall be followed as well. Same is valid in case outside of European Union, E.g IECEx, but there is no CE marking required.

In terms of transparency it is a black box. Black box means user has no access to intel information, only connection inlets and outlets shall be inspected before start-up with relations to ambient incl IOMs.

From the perspective of the user / operational team it is not the best option, but still doable. From the other way around – EPC or similar – compliance to legal requirements in case of a product shall be completely different, than as per a complEx technology / installation / assembly.

I know IEC has introduced IEC 60079-46, which is about: Explosive atmospheres – Part 46: Equipment assemblies.


IEC TS 60079-46:2017 specifies requirements for the design, construction, assembly, testing, inspection, marking, documenting and assessment of equipment assemblies for use in explosive atmospheres under the responsibility of the manufacturer of the equipment assembly. The requirements of this document apply to individual items according to the IEC 60079 series or ISO 80079 series that comprise the assembly and that have individual certificates. These individual items are then integrated as part of the equipment assembly. Also included are requirements to address aspects for the assembly which may be beyond the certificates of the individual items forming the assembly. The scope of this document includes assessment of the additional requirements for assemblies for hazardous areas and does not include requirements for non-hazardous areas. It is assumed that compliance with other electrical or mechanical requirements that are applicable for non-hazardous areas will be verified by either the same or different party in addition to the requirements of this document. This document does not apply to:
– equipment which is covered, in its entirety, by one or more IEC 60079 and ISO 80079 equipment types of protection;
– pressurized rooms, “p”, in accordance with IEC 60079-13, artificial ventilation for the protection of analyzer(s) houses in accordance with IEC TR 60079-16, and other standards addressing specific Ex assemblies;
– installation at the end-user site under the scope of IEC 60079-14;
– classification of the hazardous area;
– equipment assemblies for mines susceptible to firedamp (Group I applications);
– inherently explosive situations and dust from explosives or pyrophoric substances (for example explosives manufacturing and processing);
– rooms used for medical purposes;
– electrical installations in areas where the hazard is due to flammable mist.
The specification is only intended to provide validation for the initial supply of an assembly.”


Or see IEC 60079-13 – Explosive atmospheres – Part 13: Equipment protection by pressurized room “p” and artificially ventilated room “v”.


IEC 60079-13:2017 gives requirements for the design, construction, assessment, verification and marking of rooms used to protect internal equipment:
– located in a Zone 1 or Zone 2 or Zone 21 or Zone 22 explosive atmosphere without an internal source of gas / vapour release and protected by pressurization;
– located in a Zone 2 explosive atmosphere with or without an internal source of gas / vapour release and protected by artificial ventilation;
– located in a non-hazardous area, containing an internal source of gas / vapour release and protected by artificial ventilation;
– located in a Zone 1 or Zone 2 or Zone 21 or Zone 22 explosive atmosphere containing an internal source of gas / vapour release and protected by both pressurization and artificial ventilation.
The term “room” used in this document includes single rooms, multiple rooms, a complete building or a room contained within a building. A room is intended to facilitate the entry of personnel and includes inlet and outlet ducts. An acoustic hood and other like enclosures designed to permit the entry of personnel can be considered as a room.
This document also includes requirements related safety devices and controls necessary to ensure that artificial ventilation, purging and pressurization is established and maintained.
A room assembled or constructed on site, can be either on land or off-shore. The room is primarily intended for installation by an end-user but could be constructed and assessed at a manufacturer’s facility, where the final construction such as ducting can be completed on site.
This document does not specify the methods that may be required to ensure adequate air quality for personnel with regard to toxicity and temperature within the room. National or other regulations and requirements may exist to ensure the safety of personnel in this regard.
This second edition cancels and replaces the first edition published in 2010. This edition constitutes a technical revision.
This edition includes the following significant technical changes with respect to the previous edition:
a) modification of the title of this document to include artificially ventilated room “v” in addition to pressurized room “p”;
b) addition of types of protection “pb”, “pc”, and “vc” and removal of types of protection “px”, “py”, “pz” and “pv”;
c) definition of the differences between pressurization and artificial ventilation types of protection;
d) removal of protection of rooms with an inert gas or a flammable gas from the scope of this document;
e) addition of an informative annex to include examples of applications where types of protection pressurization or artificial ventilation or pressurization and artificial ventilation can be used and associated guidelines.”


Both are not harmonized under ATEX, so product compliance to ATEX is not possible, only with Ex h (ISO 80079-36/-37) – which means it shall be considered as a non-electrical product – here for category 2 we can only speak about Technical File Registration (TFR) by an ATEX Notified Body in terms of compliance to ATEX.

Product is a black box, which means no intel information will be shared about its detailed design and later on more for local compliance issues. No internal connections, installation shall be inspected in details as per part of commissioning, certainly it shall be delivered by the manufacturer as part of their internal QMS, BUT not shared to client. Any later maintenance, repair work to deliver will be related to a product and not a complEx technology / installation / assembly.

So all these aspects shall have an immediate effect to overall concept of the project at the time contracting. Which is better and why, all have pro.s and con.s. Pls have a look in time!!!

Recently we have been involved in many similar projects, where this statement has been made at final stage of the project, and now there is a disagreement between the parties.

Keep up the good work!


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