Last edit: 03/08/2023
THE DOUBT
Do Equipment containing potentially explosive atmosphere and installed in safe areas, fall under the ATEX Directive 2014/34/EU (also called ATEX 114)?
CONSIDERATIONS
Consider for example a Mixer, that contains a potentially explosive atmosphere but completely closed when it works. It is installed in a non-classified area while the manufacturer, during the risk assessment, has defined a Zone 0 inside it. Shall it be CE Marked Category 1 according to the ATEX Product Directive, therefore involving a Notified Body before it is placed on the market? The answer is no.
The ATEX Directive is applicable to Equipment installed in ATEX Classified Areas, in other words in areas that are classified before the machine is installed. Here what the directive states:
[2014/35/EU] Article 1 – Scope
1. This Directive shall apply to the following, hereinafter referred to as “products”:
(a) equipment and protective systems intended for use in potentially explosive atmospheres;
And what the Official guide states:
[2014/35/EU] § 34 Place of intended use
[…] It is important to underline in this context how machinery having a potentially explosive atmosphere inside under operating conditions, but having no interface to external potentially explosive atmospheres has to be considered. Such machines, as an integral whole, do not fall under scope of the ATEX Directive 2014/34/EU.
The same approach is for the Machinery Directive. Hereafter the language from its official guide:
[2006/42/EC] ANNEX I: Essential health and safety requirements relating to the the design and construction of machinery
1.5.7 Explosion. Machinery must be designed and constructed in such a way as to avoid any risk of explosion posed by the machinery itself or by gases, liquids, dust, vapours or other substances produced or used by the machinery […].
In the official Guide to the Machinery Directive the following text is written:
[Guide to 2006/42/EC] §228 Explosion
[…] Although the ATEX Directive is not applicable as such to explosion risks generated within the machinery itself, […]
CONCLUSIONS
When the Equipment or the Assemblies, or in general the Machinery contains a potentially explosive atmosphere, a risk assessment according to EN 1127-1 shall be done. If equipment, independently placed on the market, are used inside the machine, those shall be CE Marked according to the ATEX Directive 2014/35/EU. However, the Machine itself, if installed in a non-classified area, does not fall under the ATEX Directive.