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SACEA SAFETY WORKSHOP WILL FLAME PROOF REPAIRS BE RESPONSIBLE FOR THE NEXT UNDERGROUND DISASTER IN THE COAL MINING INDISTRY? 16 October 2014 Main Hall,

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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:

1 SACEA SAFETY WORKSHOP WILL FLAME PROOF REPAIRS BE RESPONSIBLE FOR THE NEXT UNDERGROUND DISASTER IN THE COAL MINING INDISTRY? 16 October 2014 Main Hall, Sasol Rec Club

2 Agenda Registration Tea & Coffee Opening and Welcome Typical deviation found A Guideline for ex d equipment repairs as required by ARP0108 and SANS Tea Break Comparison of the IECEX services scheme vs. RSA mark scheme requirements SAFA responsibility of the repair facility Legal Requirements and implications of non conformance Open Discussion Acknowledgments Meeting Closure Lunch and Networking AGENDA

3 REGISTRATION TEA & COFFEE 08:00-08:30

4 OPENING AND WELCOME 08:30 – 08:45 Louis Botha Presenting - SACEA

5 TYPICAL DEVIATION FOUND 08:45 – 09:15 Piet Prinsloo Presenting - SASOL

6 better together... we deliver SACEA Safety Workshop Presenter - Piet Prinsloo

7 better together... we deliver SACEA Flame Proof Safety workshop Deviations found during audits

8 better together... we deliver Contend Introduction Process followed Audit results/ Audit Findings Post audit actions Questions 8

9 better together... we deliver Introduction

10 better together... we deliver Introduction Piet Prinsloo 35 Years service Qualified in ISO 9001, 14001, OHSAS Head of SHEQ department at SMCW Function started after a major incident at Sasol Audited more than 100 companies 10

11 better together... we deliver Process followed

12 better together... we deliver Process followed Make an appointment Explain purpose of audit Quick tour of the facility Request company to explain QA/QC process Ask clarifying questions Visit shop floor to verify explained QA/QC process (Audit against what I was told) 12

13 better together... we deliver Audit results/ Audit Findings

14 better together... we deliver Audit 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 temperature Pressure test values of scrubber box not indicated on test report Findings 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 submitted The data pack of a completed machine lacked the test data for the engine safety shut off system at 60 seconds 14

15 better together... we deliver Audit results/ Audit Findings cont. No proof that Jigs are inspected No temperature gauge on the hot water testing facility No 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 MPA No documented proof could be supplied that any inspections or sizes of products were checked. The step was signed off on the final inspection document. 15

16 better together... we deliver Audit 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 plates The final inspection document of a motor found to be not flame proof was checked and all items were marked as correct 16

17 better together... we deliver Audit 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 motor The 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. 17

18 better together... we deliver Audit 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) 18

19 better together... we deliver Post audit actions

20 better together... we deliver Post audit actions A written report is discussed with the company Some instances business was suspended or terminated All companies acknowledged that audit was value adding 20

21 better together... we deliver Questions ? 21

22 Confidential Document better together... we deliver

23 A GUIDELINE FOR EX D EQUIPMENT REPAIRS AS REQUIRED BY ARP0108 AND SANS :15 – 09:45 David Maree Presenting - EXPLOLABS

24 Presented by : David Maree A guideline for Ex ‘d’ equipment repairs in accordance with SANS and ARP0108

25 Introduction Original Equipment Manufacturer End User Repair Facility

26 The repair facility Repair Facility ISO 9001 Quality Management System + Certified by approved mark scheme or batch testing by an ATL Personnel competency as per Annex B of SANS Adequate facilities Meet Eddy…the fall guy..

27 Documentation SANS Clause should seek “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.” What basic data is required? Difficulty in obtaining the data/information Technical specifications Flameproof Drawings Operating & Installation instructions The IA Certificate Documentation after the repair has been completed Job card Maintain records

28 Repair without documentation

29 MODIFICATIONS DURING REPAIR No unauthorized modifications Examples: Additional entries Adding or removing compartments Major dimensional changes Changes in the connection facilities In 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.

30 SUMMARY Lack 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 Eddie Thank you!

31 TEA BREAK 10:00 -10:15

32 COMPARISON OF THE IECEX SERVICES SCHEME VS. RSA MARK SCHEME REQUIREMENTS 10:15 – 10:45 Roelof Viljoen Presenting - MASC

33 Repair Markschemes in RSA IECEx services scheme vs. RSA requirements / Issues Presenter: R. Viljoen Mining And Surface Certification (MASC) 33

34 34 Standards and rules : Manufacturing of new product: IECEx: IEC/ISO ………………RSA Markscheme: No formal indication / standard Repairs: IECEx: OD0013/14/15………………RSA Markscheme: No formal indication / standard Rules: 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?)

35 35

36 36 How does IECEx and RSA Markscheme R equirements differ in practice?

37 37

38 38 OD015 helpful templates Flameproof enclosures

39 39

40 40 OD015 helpful templates Flameproof – equipment installed inside enclosures

41 41

42 42

43 43 Some specific issues / questions

44 44 1. How does the culture of compliance in RSA compare with other countries? Quality system comparison Technical manufacturing comparison. Auditor culture / integrity Auditee culture / integrity 2. How does RSA companies with existing MARK Schemes compare under IECEx scrutiny? Manufacturing audits on companies under IECEx.

45 45 3. Is SANAS accreditation required for RSA CB’s? DMR/DOL approval Testing ISO (Test labs) Certification under SANAS ISO17065…

46 46 4. Is repair included when a company has a manufacturing markscheme? Industry perception Legal status Quality system requirements Competence Label requirements Markscheme Permit number Etc.

47 47 5. 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 list Is 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?

48 48 7. Golden thread of Ex Auditing Manufacture / repair to standard? Certification drawings… system… product Vs Standard / Certification Drawings… system… product Quality of drawings / available drawings Modifications to standard? IEC/SANS … E.g. Annex C for Flamepaths. Intrinsic safety repairs without information? 8. Repair process WHAT activities will be undertaken? Decision making by mark holder on each repair….. Competence (RSA… two inspectors required)

49 49 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 COC 10. Empty enclosure sales by Markholders. Sale of empty enclosures by markholders Certf number…. X Certf does not indicate internal content.

50 “I will have my equipment certified by a markholder” Perception in industry. Ex n Motors Markholders “certifying” machines

51 Questions??? Contacts: Roelof Viljoen (012)

52 SAFA RESPONSIBILITY OF THE REPAIR FACILITY 10:45 – 11:15 Paul Meanwell Presenting - SAFA

53 South African Flameproof Association Flameproof Repairs Maintenance and Standards

54 South African Flameproof Association Training and competence Training and competence We’ve all seen this…. We’ve all seen this…. Is it safe? Is it safe? I don’t know! Not legal! I don’t know! Not legal! Flange thickness Flange thickness Depth of thread Depth of thread Flame path length Flame path length Free internal volume Free internal volume Pressure piling Pressure piling

55 South African Flameproof Association Question is……….. Will it get fixed, and when? Question is……….. Will it get fixed, and when?

56 South African Flameproof Association When does safe become unsafe? When does safe become unsafe?

57 South African Flameproof Association Who will stop a machine for this? Who will stop a machine for this?

58 South African Flameproof Association In my opinion, not many, but why not? In my opinion, not many, but why not? Production pressure, bonus, knowledge Production pressure, bonus, knowledge Does that CH4 monitor ensure safety? Does that CH4 monitor ensure safety? Lets look at the knowledge factor Lets look at the knowledge factor

59 South African Flameproof Association Available training Available training Plenty to choose from, good and bad Plenty to choose from, good and bad How do you choose? How do you choose? How long does it take? How long does it take? What does it cost? What does it cost? How long is it valid? How long is it valid? What value does the trainee put on it? What value does the trainee put on it? How long is the training remembered? How long is the training remembered? What is the value to the employer? What is the value to the employer? What about SANS ? What about SANS ?

60 South African Flameproof Association Competency Competency Competency is not the same is training Competency is not the same is training Training without experience does not result in competency Training without experience does not result in competency Experience without training does not result in competence Experience without training does not result in competence In the workplace, peer and production pressures will normally take precedence over formal training (on the job training) In the workplace, peer and production pressures will normally take precedence over formal training (on the job training) The DRC experience….. The DRC experience…..

61 South African Flameproof Association Can we change things? Can we change things? Culture change required – takes time! Culture change required – takes time! YOU – the end user hold all the aces! YOU – the end user hold all the aces! Downstream – actively support your ethics Downstream – actively support your ethics – Demand that your suppliers do the right thing. Audit them yourselves. Set your own standards! It’s competitive out there! Upstream – Demand that your suppliers do the right thing. Audit them yourselves. Set your own standards! It’s competitive out there!

62 South African Flameproof Association Resistance to Change Resistance to Change ADKAR – A 5 step model ADKAR – A 5 step model AWARENESS AWARENESS DESIRE DESIRE KNOWLEDGE KNOWLEDGE ABILITY ABILITY REINFORCEMENT REINFORCEMENT

63 South African Flameproof Association You rely on certificates…….. You rely on certificates…….. But you don’t read them! But you don’t read them!

64 South African Flameproof Association Almost all of you will have this report Almost all of you will have this report Estimated 500+ issued to industry! Estimated 500+ issued to industry! So what about special conditions of use? So what about special conditions of use? What about the “U” suffix? What about the “U” suffix?

65 South African Flameproof Association Lets look at “the System” Lets look at “the System” ILAC SANAS Global Global CB’s & TL’s National - STC National - STC National National

66 South African Flameproof Association Lets look at “the System” cont……. Lets look at “the System” cont……. Mnfr Repairer Needs Mnfr Licence Needs Mnfr Licence Pirate May need a licence May need a licence Use at own risk! Use at own risk!

67 South African Flameproof Association So, how can we improve things? So, how can we improve things? Take ownership of your FLP products, relying solely on the certificate is not always good enough. 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 Employ or train an expert – give that position the authority to keep order, develop in implement policies and procedures

68 South African Flameproof Association Audit your choice of CB and TL Audit your choice of CB and TL Audit your suppliers, whether manufacturers, repairers, or suppliers Audit your suppliers, whether manufacturers, repairers, or suppliers Audit your own operations! Audit your own operations! COMPLAIN! about sub standard service COMPLAIN! about sub standard service

69 South African Flameproof Association Finally, when everything is in place, Finally, when everything is in place, ENFORCE your plan, your policy, and your procedures. ENFORCE your plan, your policy, and your procedures. It can be done – If you plan ahead It can be done – If you plan ahead

70 South African Flameproof Association Thank You

71 LEGAL REQUIREMENTS AND IMPLICATIONS OF NON CONFORMANCE 11:15- 12:00 Ntabiseng Mphahlele Presenting - DMR

72 Manufacturers’ Legal Obligations in Terms of the Mine Health and Safety Act Mine Health and Safety Act (Act 29 of 1996) Regarding Hazardous Locations AA COUTINHO Director Mine Safety

73 Hazardous Locations The 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: a)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; b)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; c)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;

74 Hazardous Locations … continue d)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; e)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”; f)Explosion protected apparatus used in any hazardous location is installed, maintained, repaired, overhauled, inspected and tested by a competent person;

75 Section 21 (of the Act) Manufacturer's and Supplier's duty for Health and Safety

76 Repairs to be carried out according to SANS “The installation, inspection and maintenance of equipment used in explosive atmospheres Part 3: Repair and overhaul of apparatus used in explosive atmospheres”;

77 Repair company responsibilities and mark holders Compliance that have – A quality system – Ensure compliance with SANS – Are regularly audited to ensure compliance

78 Manager responsibilities Ensure that the equipment that has to be repaired is sent to a mark holder. Check that the repairer has a quality system Has the equipment to repair hazardous location equipment The repair equipment complies to the relevant standard

79 Closing Summary / Key Points Consumer Protection Act Implications Manufacturer’s compliance with MHSA Product Risk Assessment / repaired equipment

80 Thank you for listening Questions

81 OPEN DISCUSSION 12:00-12:30

82 ACKNOWLEDGEMENTS 12:30- 12:55

83 Acknowledgements Sasol Club Presenters Attendees Simon Orchardson Leoni / Lynette

84 MEETING CLOSURE 12:55-13:00

85 LUNCH & NETWORKING 13:00


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