sacea safety workshop will flame proof repairs be responsible for the next underground disaster in...
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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, Sasol Rec Club
Agenda
• Registration Tea & Coffee• Opening and Welcome• Typical deviation found• A Guideline for ex d equipment repairs as required by
ARP0108 and SANS 60079-19• 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
REGISTRATION TEA & COFFEE08:00-08:30
OPENING AND WELCOME08:30 – 08:45
Louis BothaPresenting - SACEA
TYPICAL DEVIATION FOUND 08:45 – 09:15
Piet PrinslooPresenting - SASOL
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SACEASafety Workshop
16.10.2014
Presenter - Piet Prinsloo
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SACEA Flame Proof Safety workshop
Deviations found during audits
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Contend
Introduction
Process followed
Audit results/ Audit Findings
Post audit actions
Questions
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Introduction
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Introduction
• Piet Prinsloo
• 35 Years service
• Qualified in ISO 9001, 14001, OHSAS 18001
• Head of SHEQ department at SMCW
• Function started after a major incident at Sasol
• Audited more than 100 companies
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Process followed
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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)
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Audit results/ Audit Findings
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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
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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.
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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
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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.
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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)
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Post audit actions
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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
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Questions ?
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Confidential Document
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A GUIDELINE FOR EX D EQUIPMENT REPAIRS AS REQUIRED BY ARP0108
AND SANS 60079-19
09:15 – 09:45
David MareePresenting - EXPLOLABS
Presented by : David Maree
A guideline for Ex ‘d’ equipment repairs in accordance with SANS
60079-19 and ARP0108
Introduction
Original Equipment Manufacturer
End User Repair Facility
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 60079-19
Adequate facilities
Meet Eddy…the fall guy..
Documentation
SANS 60079-19 Clause 4.4.1.5.1
“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.”
• 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
Repair without documentation
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.
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!
TEA BREAK
10:00 -10:15
COMPARISON OF THE IECEX SERVICES SCHEME VS. RSA MARK SCHEME
REQUIREMENTS
10:15 – 10:45
Roelof Viljoen Presenting - MASC
Repair Markschemes in RSAIECEx services scheme
vs.
RSA requirements / Issues
Presenter: R. ViljoenMining And Surface Certification
(MASC)
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Standards and rules:
• Manufacturing of new product:
• IECEx: IEC/ISO 80079-34………………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?)
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How does IECEx
and RSA Markscheme
Requirements differ in practice?
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OD015 helpful templates
Flameproof enclosures
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OD015 helpful templates
Flameproof – equipment installed inside enclosures
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Some specific issues / questions
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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.
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3. Is SANAS accreditation required for RSA CB’s?
• DMR/DOL approval• Testing ISO 17025 (Test labs)• Certification under SANAS ISO17065…
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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.
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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?
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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 60079-19… 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)
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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.
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11. “I will have my equipment certified by a markholder”
• Perception in industry.• Ex n Motors• Markholders “certifying” machines
SAFA RESPONSIBILITY OF THE REPAIR FACILITY
10:45 – 11:15
Paul MeanwellPresenting - SAFA
South African Flameproof Association
FlameproofRepairs
Maintenanceand Standards
South African Flameproof Association
Training and competence
We’ve all seen this…. Is it safe?
I don’t know! Not legal!Flange thicknessDepth of threadFlame path lengthFree internal volumePressure piling
South African Flameproof Association
Question is……….. Will it get fixed, and when?
South African Flameproof Association
When does safe become unsafe?
South African Flameproof Association
Who will stop a machine for this?
South African Flameproof Association
In my opinion, not many, but why not?
Production pressure, bonus, knowledge
Does that CH4 monitor ensure safety?
Lets look at the knowledge factor
South African Flameproof Association
Available trainingPlenty to choose from, good and badHow 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 10086-2?
South African Flameproof Association
CompetencyCompetency 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…..
South African Flameproof Association
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!
South African Flameproof Association
Resistance to ChangeADKAR – A 5 step model
AWARENESSDESIREKNOWLEDGEABILITYREINFORCEMENT
South African Flameproof Association
You rely on certificates……..But you don’t read them!
South African Flameproof Association
Almost all of you will have this report
Estimated 500+ issued to industry!
So what about special conditions of use?What about the “U” suffix?
South African Flameproof Association
Lets look at “the System”
ILAC
SANAS
Global
CB’s & TL’s
National - STC
National
South African Flameproof Association
Lets look at “the System” cont…….
Mnfr
Repairer
Needs Mnfr Licence
Pirate
May need a licence
Use at own risk!
South African Flameproof Association
So, 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
South African Flameproof Association
Audit your choice of CB and TL
Audit your suppliers, whether manufacturers, repairers, or suppliers
Audit your own operations!
COMPLAIN! about sub standard service
South African Flameproof Association
Finally, when everything is in place,
ENFORCE your plan, your policy, and your procedures.
It can be done – If you plan ahead
South African Flameproof Association
Thank You
www.flp.co.za
LEGAL REQUIREMENTS AND IMPLICATIONS OF NON
CONFORMANCE
11:15- 12:00
Ntabiseng MphahlelePresenting - DMR
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 COUTINHODirector Mine Safety
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 10108 are not applicable to the employer;
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 10086-1 2005, “The installation, inspection and maintenance of equipment used in explosive atmospheres Part 1: Installations including surface installations on mines” and SANS 10086-2 2004, “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 10086-3 2005; “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;
Section 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;
Repairs 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”;
Repair company responsibilities and mark holders
• Compliance that have
– A quality system
– Ensure compliance with SANS 10086-3
– Are regularly audited to ensure compliance
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
Closing Summary / Key Points
• Consumer Protection Act Implications
• Manufacturer’s compliance with MHSA
• Product Risk Assessment / repaired equipment
T h a n k y o u f o r l i s t e n i n g
Questions
OPEN DISCUSSION12:00-12:30
ACKNOWLEDGEMENTS
12:30- 12:55
Acknowledgements
• Sasol Club
• Presenters
• Attendees
• Simon Orchardson
• Leoni / Lynette
MEETING CLOSURE12:55-13:00
LUNCH & NETWORKING
13:00