CE marking, European Union and Australian requirements.

Read full letter of Opinion on anti-static reverse filter cleaning heavy system 

Vacteck products as of May 2008 fall outside the scope of the European Union directives that relate to the marking of products with the CE mark which certifies that they conform to certain directives that relate to the safety of the product and its performance in certain environments. The closest directive that has any relevance is the European ATEX certification. But as you will see from the information below, Vacteck products fall outside the scope of ATEX as they have...

• no moving parts
• no electricazl ignition sources
  
• no electrical components
• no mechanical moving parts
• no sparking sources

Vacteck products regularly are exposed to a certified authority who assesses our systems and provides a professional letter of opinion of certification as necessary.

In regard to Vacteck anti-static units for the recovery of flammable fluids the following is relevant;

ATEX approval is only required in the European Union under safety directive
ATEX 95 (94/9/EC) and has no relevance outside of the European Union, unless
ATEX approved apparatus has been legislated as being acceptable under a
particular national scheme (for example, in New Zealand).

In any case, the requirements upon which the ATEX approval is based are
incorporated in CENELEC standards.
These standards are largely identical to the equivalent IEC standards, which
have a more global acceptance, with IEC and CENELEC standards for the same
explosion protection technique being, for all intents and purposes at this time,
identical in content, structure, requirements and verbiage.

The following discussion and argument applies to both sets of standards.
The above apparatus is intended to remove combustible and flammable liquids
(and other matter) by means of a vacuum applied to the reservoir (2), created by
the air motor and pump assembly (3), and collected by the metal wand (6).

An earth strap (7) has been fitted to the metal wand (6) in order to prevent static
build up, which is possible when transporting non-conductive liquids at some
velocity, this being caused by the triboelectric effect. This earth strap (7) also
bonds the entire apparatus to the system earth.

Either CENELEC or IEC explosion protection standards provide specific design
requirements for various explosion protection philosophies which prevent ignition
of explosive, flammable or combustible mixtures of gases, vapours or dusts in air
by any of the following means, either alone or in combination:
a. Energy and heat reduction (cannot ignite)
b. Ignition containment (ignition is controlled and cannot spread)
c. Ignition avoidance (explosive, flammable or combustible mixtures cannot gain
access to an ignition source).

POTENTIAL ELECTRICAL IGNITION SOURCES – THIS APPARATUS
The apparatus in Figure 1 contains no electrical sources of ignition and is bonded
to the system earth in order to prevent any build up of static electricity, therefore
preventing ignition by electrostatic sparking.

POTENTIAL MECHANICAL IGNITION SOURCES – THIS APPARATUS
From the manufacturer’s statement, there are no moving parts in either the motor
or pump assembly that can produce heat from friction. The particulars of this
device are subject to an application for a Patent and may not be discussed
further.
Therefore no heat generating mechanical components exist within the apparatus,
based on an affirmation from the manufacturer and designer of the air motor and
pump assembly.

CONCLUSIONS
This apparatus, by its nature and design, is inherently and unconditionally safe in
a constantly hazardous explosive or combustible atmosphere as there are no
ignition sources or mechanisms for ignition incorporated within it, under normal
operation.
Certification under any national or international explosion protection scheme,
including ATEX Approval or IECEx Certification or to any explosion protection
standards is therefore unnecessary as this apparatus is outside of the scope of
these schemes and those standards.

Paul Spresser
Principal Consultant
E.P.E.E. Consulting Services Pty Ltd
Bachelor Engineering (Electrical and Computers) - QUT 1992
Associate Diploma Electrical Engineering – DDIAE 1986
Electrical Equipment in Hazardous Areas (EEHA) Auditor No. 02/0093 Category 3 (Gas, Vapours and Combustible Dusts) (DEIR/ESO
Queensland)
Member – Engineers Australia
Member – Standards Australia EL-014, EL-023 and MS-011 subcommittees
Past Member – IECEx Assessment Team

EPEE Consulting Services
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Unit 47
16 Arcadia Street
Eight Mile Plains Qld 4113
ph: (07) 3341 9553 m: 0415 340 477