It sounds like it. Any machine that makes frothy coffee is probably going to need a written scheme of examination. Ask the person who inspects your compressed air, etc systems, or your insurer. While there is a 250 bar litre threshold for most pressure systems, for steam systems the trigger is 'steam, at any pressure'. We have far more failures on these systems, compared with our nitrogen/helium/air systems. Many makes/models/designs suffer from a tendency for the pressure relief valve to jam.