Getze Consulting · Conformity and Documentation Test report 05 of 5

Everything certified.And still not right.

A plant builder delivers a hydrogen transfer station to a research institute. Material certificates complete, ATEX certificates for every component, leak test recorded, an explosion protection concept from an assessor. And the operating instructions fail to pass on one condition from that report — the one the non-hazardous classification depends on.

Conditions of this test
  • A real, anonymised project
  • Every point with a quotation and a source
  • Check questions for the manufacturer, not legal advice

The knowledge agent behind this report is on Sheet 6 · Conformity. Where your data sits is your decision — three deployment models are set out on Sheet 1.

Test object

A project folder like any other.

Hydrogen, fluid group 1, outdoor installation, hazardous area. One-off build for a customer with its own safety function. The documentation is above average — that is not a courtesy, it is the reason this case is interesting.

No
Item
Volume
What it holds
Condition
01
Files in the folder
480
Grown over the project, with old revisions sitting alongside current ones.
complete
02
Bought-in components
26
Each with its own limits, its own certificates and its own conditions.
certified
03
Directives involved
3 and more
Pressure Equipment Directive, ATEX, possibly the Machinery Regulation.
1 considered
04
Individual documents
all reviewed
Every document present, signed and technically sound.
in order
A completeness check would have found almost nothing here. What the agent does instead is on Sheet 6 →
The finding

Two documents, the same release date.

7 open points from one day of review — in a folder where every individual document is in order. The first of them is the one that counts.

The explosion protection concept declares the plant non-hazardous, but ties that to two explicit conditions. The operating instructions the operator actually receives pass on neither in that form. Both documents were released on the same day — and the expert report refers to a draft from three days earlier.

FOUR DAYS BEFORE DELIVERY Day −3 Release day DRAFT Operating instructions, day −3 EXPLOSION PROTECTION CONCEPT · ASSESSOR Non-hazardous — under two conditions: regular He leak test · replace compression fittings after opening the report refers to the day −3 draft OPERATING INSTRUCTIONS · TO THE OPERATOR He leak test “may” be used, where practical Fitting replacement: not mentioned in the maintenance chapter This handover never happened. Both documents are careful. Both were released on the same day. Nobody was tasked with reading one against the other. DAY −3 DRAFT Operating instructions RELEASE DAY EXPLOSION PROTECTION CONCEPT Non-hazardous — under two conditions: He leak test · fitting replacement refers to day −3 handover missing OPERATING INSTRUCTIONS He leak test “may” be used, where practical Fitting replacement: not mentioned Both documents are careful. Both released on the same day. Nobody was tasked with reading one against the other.
Four days, three documents, one link that is missing The finding · Test report 05
The fourth gap. Every certificate is on file, every individual document is in order. The contradiction only arises between them: the condition the non-hazardous classification rests on never reaches the operator. The operating instructions grew out of a template, and the template knew nothing of the expert report. When documents get copied, nobody asks. The agent asks.
Test procedure

Checking finds the contradiction. Writing stops it arising.

This report is a diagnosis: seven points, found after the fact. Checking after the fact is better than not at all — but it is not the point.

Checking afterwards

Finds the error once it exists

  • The manual is written, released, signed
  • Only then does the missing condition surface
  • Somebody has to go back, correct, re-release
  • And explain why
While writing

The error does not arise

  • The agent derives the draft from template and documents
  • The expert report is one of its sources
  • The condition lands in the right chapter before anyone reads it
  • What it cannot evidence, it reports
Anyone writing operating instructions has to read the expert report — otherwise they do not know what belongs in them. The cross-check falls due while writing anyway. It costs no extra round, it is the round.
Test result

Seven points, each with a quotation and a source.

All phrased as questions — there may be an explanation for each that does not appear in the folder. A reported missing source is worth more than documentation that merely looks complete.

01
The condition never reaches the operator.
The explosion protection concept requires the He leak test and fitting replacement as mandatory. The manual calls the test optional and never mentions the replacement.
02
The expert report rests on a superseded design revision.
It is based on revision C of the P&ID. The folder holds revision D. Other documents reference the drawing with no revision at all — across seven existing versions.
03
The stated hazardous zone never reaches the operator.
The report requires a zone 2 of 8.6 metres around the blow-off opening. The manual mentions only the non-hazardous classification at the panel.
04
Two protective shutdowns whose reliability nobody owns.
Wiring and programming sit with the operator according to the manual. No PL or SIL verification exists anywhere.
05–07
An “X” without explanation, three design pressures, one open scoping question.
Four gauges marked X, whose conditions appear nowhere. Three documents with three different design pressures. And the Machinery Regulation does not come up anywhere in the project.
The view breaks off here — the test report carries on
  • Verbatim quotation for every point, with document, chapter and page
  • Revision status of all seven P&ID versions and who references which
  • Limits of the 26 bought-in parts, held against the plant nameplate
  • Zone plan with the 8.6 metres and how much of it reached the operator
  • Cross-check matrix expert report against manual, line by line
  • Document index with release date and signatory
  • Check questions on the Machinery Regulation scope of the four valves
  • Withdrawn finding and why it did not hold

One finding had to be withdrawn — it rested on file names rather than on the drawing as read. That is exactly why the agent discloses the source for every point. What is not evidenced is marked as not evidenced.

Seven check questions from one day of review Test result · Test report 05
Assessment

What the agent may do. And what it may never do.

In machinery safety this boundary is not a formality, it is liability. A checklist asks whether the document is there. The question is whether it matches the next one.

This side of the line

This is what the agent does

  • opens up the folder without anyone having to prepare anything
  • derives the draft from template and documents
  • carries every condition into the chapter where it belongs
  • reports when a verification rests on a superseded revision
  • evidences every point and flags what stays unevidenced
Beyond the line

This stays with the engineer

  • the technical judgement
  • the decision on a substantial modification
  • the declaration of conformity
  • the signature
The agent fills the sheet. The signature stays with the engineer. The case described comes from a real project and is reproduced anonymised. The findings are check questions for the manufacturer, not a determination of legal breaches and not legal advice.
Full report

All seven points as a PDF.

With a quotation and source for every point, the four gaps at a glance and the line between agent and engineer. You get the PDF straight after submitting, plus a short email from me.

Further test reports

Four more process chains, same method.

All five at a glance →

Next step

On your folder, not on our example.

We take a completed project of yours — you release the folder as it is, with no preparation. Exactly the effort you would otherwise face falls away. If we find nothing, it ends there and you have certainty.

Arrange a 30-minute call →
Test object
Hydrogen transfer station · fluid group 1, hazardous area
Data basis
480 files, 26 bought-in components, 3+ directives
Method
One day of review on the completed project
Tested by
Andrej Getze · Machinery and pump engineering
Report
Test report 05 of 5 · Revision 28.08.2026
Approval
Stays with you
Test report 05 of 5