Presentation on theme: "SACEA SAFETY WORKSHOP WILL FLAME PROOF REPAIRS BE RESPONSIBLE FOR THE NEXT UNDERGROUND DISASTER IN THE COAL MINING INDISTRY? 16 October 2014 Main Hall,"— Presentation transcript:
1SACEA SAFETY WORKSHOPWILL FLAME PROOF REPAIRS BE RESPONSIBLE FOR THE NEXT UNDERGROUND DISASTER IN THE COAL MINING INDISTRY?16 October 2014Main Hall, Sasol Rec Club
2Agenda AGENDA Registration Tea & Coffee Opening and Welcome Typical deviation foundA Guideline for ex d equipment repairs as required by ARP0108 and SANSTea BreakComparison of the IECEX services scheme vs. RSA mark scheme requirementsSAFA responsibility of the repair facilityLegal Requirements and implications of non conformanceOpen DiscussionAcknowledgmentsMeeting ClosureLunch and NetworkingAgenda
12Process followed Make an appointment Explain purpose of audit Quick tour of the facilityRequest company to explain QA/QC processAsk clarifying questionsVisit shop floor to verify explained QA/QC process (Audit against what I was told)
14Audit results/ Audit Findings cont. Manufactured and certified empty enclosure without any entries and windows.Did not have M20, 25, 32, 40 Go/Not Go gauges to test gland entry threaded holes.The flameproof test report do not indicate the following:cylinder head and exhaust manifold temperature shut off sentinel spec’s and its actual shut off test temperaturePressure test values of scrubber box not indicated on test reportFindings raised by certification body has not been cleared and was raised again for the second time during an audit and action plan as requested by the certification body auditors was not submittedThe data pack of a completed machine lacked the test data for the engine safety shut off system at 60 seconds
15Audit results/ Audit Findings cont. No proof that Jigs are inspectedNo temperature gauge on the hot water testing facilityNo indication of what the water temperature should be.Could not find proof that the heating element was calibrated.The procedure to do hydraulic pressure testing indicate a test pressure between 800 and 1000kpa, the gauge on the hydraulic tester was scaled to measure pressure in BAR, PSI and MPANo documented proof could be supplied that any inspections or sizes of products were checked. The step was signed off on the final inspection document.
16Audit results/ Audit Findings cont. Threaded holes on flame proof manifolds are not tested with Go, Not Go gauges. Never had any Go, Not Go gauges for 19 years.When a product is received from the customer without the flame proof name plate indicating the equipment “D” number the name plate will not be replaced or the piece of equipment re-certified.No IA on name platesThe final inspection document of a motor found to be not flame proof was checked and all items were marked as correct
17Audit results/ Audit Findings cont. A flame proof motor that was about 80% assembled was inspected and the following deviations were found:The flp face of the terminal box was damaged, pitted and not cleaned.An unpermitted modification was made to fit the terminal box to the motor by welding the mounting plate to the motorThe connection hole between the barrel and the terminal box were not sealed off with a compound to prevent pressure piling.A threaded hole on the terminal box, to secure the cover, was found to be stripped.
18Audit results/ Audit Findings cont. The inspection sheet for the said motor was checked and the following deviations found:All threaded holes were marked off to comply.Sizes recorded when the barrel was measured were exactly the same, it appears that only one area was measured and the size then copied to the other areas.The reason for non complying threaded holes on pump panels was over tightening of bolts ( later acknowledged that panels was not checked, only certified, production pressure)
26The repair facility ISO 9001 Quality Management System + Certified by approved mark scheme or batch testing by an ATLRepair FacilityAdequate facilitiesPersonnel competency as per Annex B of SANSMeet Eddy…the fall guy..
27Documentation SANS 60079-19 Clause 18.104.22.168.1 “The repair facility should seek to obtain all necessary information/data from the manufacturer or user for the repair and/or overhaul of the equipment.”Difficulty in obtaining the data/informationWhat basic data is required?Technical specificationsFlameproof DrawingsOperating & Installation instructionsThe IA CertificateDocumentation after the repair has been completedJob cardMaintain records
29MODIFICATIONS DURING REPAIR No unauthorized modificationsIn some cases end users use the repair process as an opportunity to modify the product to suit their current needs. However, if the certification documents and manufacturers design drawings don’t make provision for the modification, it is unauthorized and therefore not certified.Examples:Additional entriesAdding or removing compartmentsMajor dimensional changesChanges in the connection facilities
30SUMMARYLack of proper documentation = substandard repairs and result in product failures or not operating as they are expected, or in worst case scenario’s compromise the flameproof properties of the equipment.Manufacturers can’t be held responsible for unauthorized modifications or changes to the original product design during the repair process.What happened to the fall guy EddieThank you!
3210:15 – 10:45Comparison of the IECEX services scheme vs. RSA mark scheme requirementsRoelof ViljoenPresenting - MASC
33Repair Markschemes in RSA IECEx services schemevs.RSA requirements / IssuesPresenter: R. ViljoenMining And Surface Certification (MASC)
34Standards and rules: Manufacturing of new product: Repairs: Rules: IECEx: IEC/ISO ………………RSA Markscheme: No formal indication / standardRepairs:IECEx: OD0013/14/15………………RSA Markscheme: No formal indication / standardRules:RSA one of the front runners for Ex quality systems worldwide.And now?MP87 (Aus) / IECEx rules (IECEx 01… IECEx 03-5 repairs)MASC proposed a “rule book” for Ex in RSA be compiled. (Extension of ARP0108?)
441. How does the culture of compliance in RSA compare with other countries? Quality system comparisonTechnical manufacturing comparison.Auditor culture / integrityAuditee culture / integrity2. How does RSA companies with existing MARK Schemes compare under IECEx scrutiny?Manufacturing audits on companies under IECEx.
453. Is SANAS accreditation required for RSA CB’s? DMR/DOL approvalTesting ISO (Test labs)Certification under SANAS ISO17065…
464. Is repair included when a company has a manufacturing markscheme? Industry perceptionLegal statusQuality system requirementsCompetenceLabel requirementsMarkscheme Permit numberEtc.
475. What is a product list (RSA) IECEx certificates are web based and linked to their QAR.End users do not know about product lists.Permit incomplete without product listIs a product list required for repairs mark holder?Can a flameproof repairer repair any flameproof equipment?6. Can a markscheme incorporate certificates from different EXTL’s?Product list with different certf numbers.Does a Markscheme indicate that all products on a product list is correctly certified?What is the auditing function?
487. Golden thread of Ex Auditing Manufacture / repair to standard?Certification drawings… system… productVsStandard / Certification Drawings… system… productQuality of drawings / available drawingsModifications to standard?IEC/SANS … E.g. Annex C for Flamepaths.Intrinsic safety repairs without information?8. Repair processWHAT activities will be undertaken? Decision making by mark holder on each repair…..Competence (RSA… two inspectors required)
4910. Empty enclosure sales by Markholders. 9. Is a COC from a markholder issued with equipment (new or repaired) sufficient?Some manufacturer’s state that an IA certificate is confidential and their COC is sufficient.Permit / product list required with equipment?IA certificate number is added on COC.OD015 COC10. Empty enclosure sales by Markholders.Sale of empty enclosures by markholdersCertf number…. XCertf does not indicate internal content.
5011. “I will have my equipment certified by a markholder” Perception in industry.Ex n MotorsMarkholders “certifying” machines
58In my opinion, not many, but why not? Production pressure, bonus, knowledgeDoes that CH4 monitor ensure safety?Lets look at the knowledge factor
59Available training Plenty to choose from, good and bad How do you choose?How long does it take?What does it cost?How long is it valid?What value does the trainee put on it?How long is the training remembered?What is the value to the employer?What about SANS ?
60Competency The DRC experience….. Competency is not the same is trainingTraining without experience does not result in competencyExperience without training does not result in competenceIn the workplace, peer and production pressures will normally take precedence over formal training (on the job training)The DRC experience…..
61YOU – the end user hold all the aces! Can we change things?Culture change required – takes time!YOU – the end user hold all the aces!Downstream – actively support your ethicsUpstream – Demand that your suppliers do the right thing. Audit them yourselves. Set your own standards! It’s competitive out there!
62Resistance to Change AWARENESS DESIRE KNOWLEDGE ABILITY REINFORCEMENT ADKAR – A 5 step modelAWARENESSDESIREKNOWLEDGEABILITYREINFORCEMENT
63You rely on certificates…….. But you don’t read them!
64Almost all of you will have this report Estimated 500+ issued to industry!So what about special conditions of use?What about the “U” suffix?
65Lets look at “the System” ILACGlobalSANASNational - STCCB’s & TL’sNational
66Lets look at “the System” cont……. MnfrNeeds Mnfr LicenceRepairerMay need a licencePirateUse at own risk!
67So, how can we improve things? Take ownership of your FLP products, relying solely on the certificate is not always good enough.Employ or train an expert – give that position the authority to keep order, develop in implement policies and procedures
68Audit your choice of CB and TL Audit your suppliers, whether manufacturers, repairers, or suppliersAudit your own operations!COMPLAIN! about sub standard service
69Finally, when everything is in place, ENFORCE your plan, your policy, and your procedures.It can be done – If you plan ahead
71Legal Requirements and implications of non conformance 11:15- 12:00Legal Requirements and implications of non conformanceNtabiseng MphahlelePresenting - DMR
72AA COUTINHO Director Mine Safety Manufacturers’ Legal Obligations in Terms of the Mine Health and Safety ActMine Health and Safety Act (Act 29 of 1996)Regarding Hazardous LocationsAA COUTINHODirector Mine Safety
73Hazardous LocationsThe employer must take reasonably practicable measures to prevent persons from being injured in any hazardous location as a result of fire, explosion or the ignition of gas, dust, mist or vapour.Such measures must ensure that:All hazardous locations are identified, clearly marked and recorded on a plan or a register, which must be kept updated and readily available at the mine;Only explosion protected apparatus and systems certified for use in a hazardous location in accordance with the South African National Standard ARP 0108: 2005, “Regulatory requirements for explosion protected apparatus”, are used in any hazardous location;The selection of explosion protected apparatus used in any hazardous location is done in accordance with SANS 10108: 2005, “The classification of hazardous locations and the selection of apparatus for the use in such locations”. The normative references as listed in SANS are not applicable to the employer;
74Hazardous Locations … continue The installation, inspection and maintenance of explosion protected apparatus used in a hazardous location is carried out in accordance with SANS , “The installation, inspection and maintenance of equipment used in explosive atmospheres Part 1: Installations including surface installations on mines” and SANS , “The installation, inspection and maintenance of equipment used in explosive atmospheres Part 2: Electrical equipment installed underground in mines” as appropriate;Any repair, overhaul or modification to any explosion protected apparatus used in any hazardous location does not alter its design characteristics and is carries out in accordance with SANS ; “The installation, inspection and maintenance of equipment used in explosive atmospheres Part 3: Repair and overhaul of apparatus used in explosive atmospheres”;Explosion protected apparatus used in any hazardous location is installed, maintained, repaired, overhauled, inspected and tested by a competent person;
75Section 21 (of the Act) Manufacturer's and Supplier's duty for Health and Safety 21. (l) Any person who –Designs, manufactures, repairs, imports or supplies any article for use at a mine must ensure, as far as reasonably practicable -(i) that the article is safe and without risk to health and safety when used properly; and(ii) that it complies with all the requirements in terms of this Act;
76Repairs to be carried out according to SANS 10086-3 “The installation, inspection and maintenance of equipment used in explosive atmospheres Part 3: Repair and overhaul of apparatus used in explosive atmospheres”;
77Repair company responsibilities and mark holders Compliance that haveA quality systemEnsure compliance with SANSAre regularly audited to ensure compliance
78Manager responsibilities Ensure that the equipment that has to be repaired is sent to a mark holder.Check that the repairer has a quality systemHas the equipment to repair hazardous location equipmentThe repair equipment complies to the relevant standard