Documentation

This section is primarily aimed at site owners and end users, although it is of interest to systems integrators and panel builders who may have to supply the appropriate documentation to the end-user.
Documentation required for manufacturer product certification is currently out with the scope of this site although some may wish to take heed of the end users expectations as it is not unusual for manufacturers to supply documentation which is not 100% compliant.

The 'hazardous area' industry is a conservative industry and changes happen slowly and they are almost always backward compatible. However, there have been a number of step changes and the documentation requirements can be split into 5 distinct periods where there have been significant document changes.

Documentation requirements

2003 2016 1st Feb
2020
1st
Jan 2021
Pre Atex 1994 Atex Directive 2014 Atex Directive Interim Brexit Full Brexit

The information on this page is the situation as understood from discussions with certifying bodies, government publications1: and many years of industry experience. Should you have any questions, different interpetation or believe there are errors feedback would be appreciated. The information provided is in good faith and no liability is accepted for errors or ommissions.


Bexit Transition period

Documents required
Technical file to include:

  • UK Declaration of Conformity(s)
  • Installation/Product Manual
  • EU or UK Type Certificate(s)
    or details in manual
    If intrinsic safety used
  • _Descriptive System Documents

For equipment placed on the UK market post 31st January 2020.
As the UK is no longer part of the EU Atex, being the authority to supply into the EU, no longer applies although its principles are written into UK law and Atex certification will be accepted 'As is' for the transition period.

For hazardous area equipment UKCA marking will replace CE marking with subsequent changes to documentation.
In the 11 month interim period both the EU and UK type certificates will be accepted. Although it seems that EU DoC's can be used as we have temporarily accepted the continuing validity of the EU directives including Atex. Although there is no reason why manufacturers should not supply UK DOCs as they are produced in-house with no significant cost implications and are future proof.
Going forward it is believed all the UK (former) notified bodies will issue UK type certificates in addition to exiting EU ones at a minimal charge.
For hazardous area equipment the only change is likely to be the legal status of the certification and consequent changes to CE marked equipment which is still accepted but within this transition period there should be a gradual change to UKCA marking for the UK.


For equipment placed on the market April 2016 - January 2020

Documents required
Technical file to include:

  • EU Declaration of Conformity(s)
  • Installation/Product Manual
  • EU Type Certificate(s)
    or details in manual
    If intrinsic safety used
  • _Descriptive System Documents

Since the 2014 Atex Directive replaced the 1994 Directive in 2016 the documentation requirements have changed.
An EU Declaration of Conformity is required, which is a legal contract under EU law, confirming compliance to the 2014 Directive. The EC Declaration is no longer valid as it declares to the 1994 Atex Directive which has been revoked.
Supply of Type certificates, which are supporting evidence for the EU DoC's, are no longer mandatory providing the relevant information is supplied elsewhere e.g. in the installation or product manual.
Both EU Type certificates and the earlier EC Type certificates can be used to suport an EU DoC.

If intrinsic safety circuits2 are used then Descriptive System Document(s) must be produced to demonstrate Intrinsic safety compliance.


For Atex equipment placed on the market 2003 to April 2016

Documents required
Technical file to include:

  • UK Declaration of Conformity(s)
  • Installation/Product Manual
  • EU or UK Type Certificate(s)
    or details in manual
    If intrinsic safety used
  • _Descriptive System Documents

This also applies to any Atex equipment prior to the 2003 mandatory implementation date. Early Atex equipment was labelled EEx to differentiate it from non-Atex hazardosu area equipment labelled Ex.
Prior to the 2014 Atex Directive the EC Type Certificate was the mandatory evidence of compliance, this could be a notified body certificate for Category 1 & 2 or a manufacturers certificate for Category 3.
In addition the manufacturer should have supplied an EC declaration of conformity in order to CE Mark the product. However, evidence has shown that the Atex directive seemed to be largely ignored on many manufacturers EC DoC's.


For equipment placed on the market prior to 2003

Documents required
Technical file to include:

  • Type Certificate
  • Risk analysis
    If intrinsic safety used
  • I.S. System Cert
    or drawing

The Atex equipment Directive 944/9/EC became mandatory in 2003, but equipment to the Atex standard started appearing in 1998. Early Atex certified equipment would be identified by an EEx rather than just Ex and in the labelling and the documentation rules were that offprior to that Compliance relied on manufacturers type certificates.
For intrinsic safety some manufacturers provided a system certificate, similar to a Descriptive System Document outlining the circuit that the apparatus could be used in.

A hazardous Area type certificate from an approved issuer is required for equipment to be used in Zone 0 and Zone 1 and a manufacturers certificate was allowed for zone 2. Installed Equipment certified pre-Atex can still be used if it has not been altered in form or function since the original installation3, but a full risk assessment must exist and it is recommended to include a gap analysis against a you a more recent standard.


After the Brexit interim period

Documents required
Technical file to include:

  • UK Declaration of Conformity(s)
  • Installation/Product Manual
  • UK Type Certificate(s)
    or details in manual
    If intrinsic safety used
  • _Descriptive System Documents

The Brexit interim agreement is scheduled to end 31st December 2020 (unless a deal is agreed earlier, or it is extended). Although the terms are not yet defined the Atex requirements are currently written into UK law Even in the worst case scenario of a final no deal it it is likely the UK hazardous area requirements will mirror Atex ones with UK equivalent documentation, just not declaring to the EU Directives although it is envisaged equipment would be dual marked.

It is fairly certain a 'UK Declaration of Conformity' will be required and UK type certificates to support them. However, subject to the 'deal' as to whether EU documents will be accepted. This should not create a major issue for manufacturers or end users, But being pessimistic there could be issues about legal standing if Atex EU documentation is used for equipment for the UK and purchased after 2020.


Notes


  1. For general UK government information:
    Placing Goods on the UK market
    UKCA Mark
    No Deal Scenario 

  2. Descriptive System Documents are not required for portable equipment or where the intrinsic safety components are used internally to a product as compliance would be covered by the Type Certificate. 

  3. It must not have been changed or altered since the original installation, although if no currently certified alternative is available it can be replaced by an equivalent and the risk assessment conducted. However this is NOT recommended and generally Atex inspectors will not look favourably on this. 

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