Impact of the PER on SAQCC Competent Persons and a reminder of certification requirements, continuing professional development and ethical responsibilities CT Branch February 2011

Changes in responsibilities for periodic inspection from VUP to PER

VUP Responsibility for periodic inspections Responsibility squarely on the shoulders of the User. Constraints applying to User were Had to use a SAQCC CP certified inspector Obligated to ensure inspector had appropriate knowledge and experience for the specific job of inspection

PER Responsibility for periodic inspections Regulation 11 User may inspect Category 1 Equipment (SANS 347 categorisation) – Are you familiar with SANS 347? Higher categories must be inspected by an AIA In-Service (AIA-IS) – From April 2011 Inspection task has to be performed by an authorised person AIA-IS has to ensure the authorised person Is certified by SAQCC CP Has appropriate experience and knowledge for the specific task

PER Responsibility for periodic inspections Notes of caution There is a shift of responsibility (and accountability) to the AIA-IS as a body specialising in periodic inspections Not permissible for an AIA-IS to use a ‘non-certified’ inspector to perform work which is ‘signed-off’ by a certified CP

Requirements for AIA-IS approval Requirements for appointment as an AIA-IS by Dept. of Labour have recently been clarified and include SANAS assessment will be required prior to DoL approval SANAS will use SANS 10227 and ISO 17020 as the standards applicable for AIA-IS assessments

First let’s deal with the issue of whether an individual become an AIA-In Service?

SANS 10227 requirements

Pressure Equipment Regulations SANS 10227:2007 Criteria for the operation of inspection authorities performing inspection in terms of the Pressure Equipment Regulations

SANS 10227 Requirements for an AIA-In Service Permanent staff will need to include: Technical Manager (degree, T4, Cert. Eng. or B Tech) At least 1 Certified CP (PV/SG certified depending on scope of activities) Can be the same person!

SANS 10227 Requirements for an AIA-In Service The AIA In-Service management system will need to include documented procedures for the following: Step by step activities of an in-service inspection and how each step is carried out. Re-certification and re-rating equipment. Dispensation of internal inspections or hydro tests. Storage and filing of records. Stamping the nameplate, if necessary Stamp control

SANS 10227 Requirements for an AIA-In Service The AIA In-Service Personnel will need to comply with Table 1 requirements for: Design Verifier (Pr Eng, Pr Tech, Pr Cert Eng + 4 years experience) Technical Manager (Degree, T4, Cert Eng, B Tech + 4 years experience) Inspector (SAQCC CP)

SANS 10227 Requirements for AIA-IS approval? SUMMARY SANS 10227 requirements are not ‘over the top’ and are appropriate to an AIA-IS because: An AIA-IS deals with complex in-service issues including down-rating and re-certifying equipment. The AIA-IS will need to have most of the competencies associated with ‘traditional AIAs’ including a design evaluation

ISO 17020 requirements

SANS 17020:1998 General criteria for the operation of various types of bodies performing inspection

SANS 17020 Has been incorporated into SANS 10227 since 2007 Until recently SANAS did not audit compliance with ISO 17020 as PER was not enacted

SANS 17020 Content Administrative requirements e.g. legally identifiable body (SAN10227 specifically excludes sole proprietor) Independence, impartiality and integrity e.g. commercial influence cannot influence inspection results Confidentiality Organisation and management Quality system Personnel e.g. appropriate qualifications

SANS 17020 Content (cont.) Facilities and equipment Inspection methods and procedures Handling inspection samples and items Records Inspection reports and inspection certificates

SANS 17020 Content (cont.) Subcontracting (obligations on the inspection body) AIA shall itself normally perform work it contracts to undertake Advise the client of its intention to subcontract and the subcontractor has to be acceptable to the client Demonstrate subcontractors competence for service performed Maintain a register of all subcontracted work Record and retain details of investigation of competence and compliance of subcontractors When subcontracting specialised activities must have access to alternative resource able to independently assess results of subcontracted activities and retains responsibility for determination of conformity

SANS 17020 Content (cont.) Complaints and Appeals Co-operation (inspection body expected to share experiences with other inspection bodies)

ISO 17020 Requirements for AIA-IS approval? SUMMARY Compliance with ISO 17020 would be extremely demanding for an individual

Can an individual become an AIA-IS?

Can an individual CP become an AIA-IS? Theoretically yes but in reality it is just about impossible The reality is that the vast majority of CPs will need to find employment with an AIA-IS from April this year

What changes to the SAQCC CP system have the PER prompted?

Changes to the SAQCC CP Certification scheme? Certification criteria remain the same Physical capability Successful completion of approved training course Supervised practical training

SAQCC CP Certification Criteria Physical capability Satisfactory vision in at least one eye Ability to access vessels through manholes Any other deficiency which prevents the applicant from performing inspection duties

SAQCC CP Certification Criteria Successful completion of approved training course SAIW course and examination is approved by SAQCC CP

SAQCC CP Certification Criteria Supervised practical training Minimum periods are applicable Minimum number of vessels is applicable Credits for educational and trade qualifications reduce training period

SAQCC CP Certification Criteria Education qualifications or industrial certifications Minimum training period Practical experience requirement N2/ Std 8 /Gr 10 or lower 5 years (10 vessels) Minimum of 10 boilers and 10 pressure vessels for each category of certification N3 / Matric / Gr 12 N4 N5 3 years (10 vessels) As above Technikon S4 N6 / S3 G.C.C. IPE BSc or B.Tech 1 year (10 vessels) Note (1) Post schooling qualifications such N4, N5, N6, S3, S4, BSc degree should be in mechanical engineering, metallurgy or other relevant engineering or engineering science discipline. Qualifications are subject to review by the certification body. Note (2) Applicants who have successfully completed a trade test or apprenticeship contract as a boilermaker, welder, blacksmith, fitter, millwright and fitter & turner are given a 1 year credit with the proviso the minimum training period is not less than one year.

Changes to the SAQCC CP Certification scheme? Certification categories remain the same Pressure vessels Unlimited scope Limited scope – air receivers with and without physical access, accumulators, medical or other small autoclaves Boilers (renamed Steam Generators)

Changes to the SAQCC CP Certification scheme? Training course requirements have been changed significantly to address longstanding concerns about the inadequacy of the scope and depth of training the clear allocation of responsibilities of the AIA-IS and the CP in job of work

Changes to the SAQCC CP Certification scheme? There is one change to supervised practical training requirement When a certification candidate is already certified in one of the unlimited categories of equipment the duration of supervised experience required for certification in the other unlimited category is reduced to 1 year irrespective of the educational qualification level

What are the new SAQCC CP training requirements?

New SAQCC CP PV and SG training requirements

New CP training scheme requirements Persons intending to apply for limited PV certification will need to attend only weeks 1 and 2 of the PV stream. Those intending to apply for Unlimited will need to attend all 6 weeks Persons intending to apply for Steam Generator certification will need to attend all three weeks of the Steam Generator stream

When and how were the new courses introduced? New course requirements came into effect from January 2011 Industry experts worked with SAIW to develop new course material SAIW lecturers have been trained by industry experts and have undertaken bridging exams covering the new material

Will changes to the SAQCC CP system impact on existing certified persons?

What will happen to existing certified persons? All existing certifications will be retained Renewals and recertification will be treated as they are currently

How long is certification valid?

But SAQCC CP Certification Rules Validity of certification Certification is valid for 9 years But Certification must be renewed after 3 years then again after 6 years else it lapses After 9 years in total certification expires and an application for recertification must be submitted

SAQCC CP Certification Rules Requirements for 3 year and 6 year renewals are the same Evidence of continued satisfactory eye sight Evidence that you have inspected at least ten vessels (CP-PV) or six boilers (CP-B) in three years Evidence of at least 24 hours CPD in the three year period of certification Additional Requirements for re-certification As above plus there is also a requirement to pass an examination which will assess awareness of changes to regulations and codes

SAQCC CP Certification Rules Re-newal and recertification applications Apply using SAQCC CP form for periodic renewal or recertification Apply at least 3 months before certification lapses Any inspections carried out after the expiry date stated on the certificate are not valid and you are acting fraudulently If you apply late usually no penalty will be applied for up to three months after expiry date on your certificate After three months you may be asked to attend a professional interview and penalties will apply

Continuing professional development

SAQCC CP Certification Rules CPD requirements Structured or developmental activities where each hour is recognised as a CPD hour (minimum 25% of the total CPD credits must be this type) Semi-structured activities where two hours are recognised as a CPD hour (maximum 50% of total CPD credits shall be of this type) Unstructured activities where each four hours are recognised as a CPD hour (maximum 25% of total CPD credits shall be of this type

SAQCC CP Certification Rules Examples of structured CPD activities Attendance at approved conferences, seminars, technical meetings presented by professional institutions Presentations at approved technical events Preparation of technical articles for publication Approved teaching or lecturing In-house training on a formal recorded and auditable programme Further education studies relevant to field of certification Approved relevant short courses

SAQCC CP Certification Rules Examples of semi-structured CPD activities Further education studies not necessarily directly related to CP activities Private study of relevant publications and journals

SAQCC CP Certification Rules Examples of unstructured CPD activities Private study involving distance learning Attendance at technical meetings within an employer organisation (excludes progress, planning and production meetings)

Competent person ethical responsibilities

SAQCC CP Certification Rules Code of Ethics is aimed at Protecting the public and users and workers operating pressurised equipment Reinforcing the professional standards expected of Competent Persons Enhancing the professional standing of Competent Persons

SAQCC CP Certification Rules Examples of requirements of the Code of Ethics Do not undertake work for which you do not have the necessary experience and don’t go beyond your scope of learning and capability e.g. don’t de- rate equipment and return to service – this is the job of expert engineers Do not sign an equipment inspection and test report if you have not personally performed the work e.g. don’t allow anyone else to perform work and then sign off a report – protect your signature jealously

SAQCC CP Certification Rules Examples of requirements of the Code of Ethics Where warranted make use of specialists e.g. it is your responsibility to identify and report corrosion damage but not to decide on useful remaining service life Indicate to your employer adverse consequences if your advice is overruled by a non-technical authority or supervisor e.g. don’t be bullied for commercial convenience

Failure to comply with the Code of Ethics can have very serious SAQCC CP Certification Rules Failure to comply with the Code of Ethics can have very serious consequences. Maintain your integrity.

SUMMARY

SUMMARY From April the individual CP will disappear Many AIAs have included in-service inspection in their scope of activities informally in the past. Now they are required to demonstrate their capabilities for these activities by assessment PER enhances the status of AIAs significantly and there is an expectation of professionalism by the regulatory authorities AIA-IS will take on the legal responsibility for inspections so they should be extremely careful about their relationship with contracting CPs

SUMMARY The changes made by SAQCC CP are intended to improve the competence of CP inspectors and support AIA-IS companies in meeting their responsibilities Existing CPs are unaffected by changes to the certification training requirements CPs must enhance their standing through professionalism and ethical responsibility