2. Contents
Part 1:
• MID vs. OIML & API
• Scope MI-005
p
• 30 minutes (hopefully less)
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3. Target
• Introduction Liquid metering in EU
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4. MID vs. API & OIML#1
vs
The good news:
• They are not in conflict
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5. MID vs. API & OIML#2
vs
The bad news:
• There are differences
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6. API
• No status under MID
• Legal Metrology:
– Span of API declining
– Span of OIML growing
• Suggestion: start looking at OIML
Suggest o sta t oo g O
• Please know OIML cooperates with
WTO,
WTO ISO and others
d h
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7. OIML
• R117-1 Normative Document under
MID
Advantages:
• Clarifies "suitable for use
suitable use"
• Provides a basis for solving a
fundamental MID challenge
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9. Scope MI-005
MI 005
• Measuring SYSTEMS for Liquids
other than Water
h h W
• Legal term: "Measuring
Instrument"
y
• Continuous and dynamic
measurement (not level gauging)
• Including cryogenics (e.g. LNG)
(e g
• Not restricted to Fuels
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11. Typical System
Flow
Printer DCS
computer
Supply Receiver
Gas
G
Elimination
/ Prevention Meter
Transfer
point
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12. Problem sketch
• Users wants:
– Meter Make A
– Flowcomputer Make B
– His existing piping
• Law: 1 single Manufacturer
g
• Will A apply for Approval of A and
B and the rest?
• Will B handover documentation?
• What to do about pre-MID parts
pre MID
combined with MID parts? (later
today)
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13. Please know …
• A fully modular Approach would
have been problematic too!!!
h b bl i !!!
• How to combine
Modules?
• Local authorities are
likely to implement
national legislation
-> (barrier to trade)
>
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14. Summary
• No problem with the standards
• What they call an "instrument"
y
• We consider as a collection of
devices
• Th l
The legal responsibility is unilateral
l ibilit i il t l
• The production responsibility is
multilateral
• Or, MID is not modular
,
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20. Welmec
• WG10 recognised the problem
• WG10 Participants:
– Authorities / Regulators
– Manufacturers
– N tifi d B di
Notified Bodies
• WG8 made the proposal
• We had to work fast with what we had
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21. Voluntary Modular Approach
Basic idea:
• Producers obtain "Part Approvals"
• Single entity has combination
Approved
Challenge:
• Who accepts responsibility?
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22. Easy for large manufacturer
• Because he has all components
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24. Practical issues
• (Part) Approvals contain
confidential information
• Party A does not want to "sell" p y
y party
B's instruments
• Party B does not want his Certification
investment to be abused
• Party C only makes flowcomputers
• …
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25. Available options (for now)
• EC Type Examination Certificate for
the complete Instrument
h l I
• EC T
Type E
Examination C tifi t
i ti Certificate
based on:
– Evaluation Certificates
– Part Certificates
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27. Essence of Modular Approach
• Voluntary
– Both in application and acceptance
• Restricted (for now) to OIML R117-1
Constituent Elements
• Each "Part Producer" obtains
Certification against MID
• Allows others to use that implicitly
or explicitly
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28. Part Certificate
• States compliance with relevant
requirements
i
• Describes the Part
• Documents the Part
• Truely detailed information on file
• U
Unrestricted use
ti t d
• So anybody can use that Certificate
/ that flowcomputer
p
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29. Evaluation Certificate
• States compliance with relevant
requirements
i
• Describes the Part
• Documents the Part
• Truely detailed information on file
• R t i t d use
Restricted
• So nobody can use that Certificate /
that flowcomputer without
permission
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30. Trusted Third Party
For Evaluation Certificates:
• Authorities may ask for detailed
information
• Type Approval file only to
Authorities in court cases
• EC Approval, Description and
Documentation only to authorities
• O
Owner system Approval accepts not
t A l t t
seeing details Evaluation Certificate
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31. Pre summary
Pre-summary
• An owner / end-user can become
applicant / manufacturer of
li f f
complete Measuring Instrument
• Possible to keep sensitive
p
information off the street
• Manufacturers / producers can block
competitor s
competitor's Certification
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32. Is it a Barrier to Trade?
Legally speaking NO, because:
• Everyone can apply for
another Approval in his name
• A (Part) Approval is not Public
Property
p y
• Or you are not allowed to drive
Or,
under my driving license
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33. Summary
• Practice and Law are not aligned
• A workaround is available
++++ / ----
• The workaround is voluntary
– Cooperation not guaranteed
– Acceptance not guaranteed
• The workaround is not perfect
p
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