SACEA Safety Workshop SASOL learnings

Report
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
•
•
•
•
08:00-08:30
REGISTRATION TEA & COFFEE
08:30 – 08:45
OPENING AND WELCOME
Louis Botha
Presenting - SACEA
08:45 – 09:15
TYPICAL DEVIATION FOUND
Piet Prinsloo
Presenting - SASOL
SACEA
Safety
Workshop
Presenter - Piet Prinsloo
16.10.2014
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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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8
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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10
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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12
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
better together ... we deliver
14
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.
better together ... we deliver
15
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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16
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.
better together ... we deliver
17
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)
better together ... we deliver
18
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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20
Questions ?
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21
Confidential Document
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09:15 – 09:45
A GUIDELINE FOR EX D EQUIPMENT
REPAIRS AS REQUIRED BY ARP0108
AND SANS 60079-19
David Maree
Presenting - EXPLOLABS
A guideline for Ex ‘d’ equipment
repairs in accordance with
SANS 60079-19 and ARP0108
Presented by : David Maree
Introduction
Original Equipment Manufacturer
End User
Repair Facility
The repair facility
ISO 9001 Quality Management System
+
Certified by approved mark scheme or
batch testing by an ATL
Repair Facility
Meet Eddy…the fall
guy..
Adequate facilities
Personnel competency as per Annex B of
SANS 60079-19
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.”
• Difficulty in obtaining the data/information
• What basic data is required?
 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
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.
Examples:
Additional entries
Adding or removing compartments
Major dimensional changes
Changes in the connection facilities
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!
10:00 -10:15
TEA BREAK
10:15 – 10:45
COMPARISON OF THE IECEX SERVICES
SCHEME VS. RSA MARK SCHEME
REQUIREMENTS
Roelof Viljoen
Presenting - MASC
Repair Markschemes in RSA
IECEx services scheme
vs.
RSA requirements / Issues
Presenter: R. Viljoen
Mining And Surface Certification (MASC)
33
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?)
34
35
How does
IECEx
and
RSA Markscheme
Requirements
differ in practice?
36
37
OD015 helpful templates
Flameproof enclosures
38
39
OD015 helpful templates
Flameproof – equipment installed
inside enclosures
40
41
42
Some specific issues / questions
43
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.
44
3. Is SANAS accreditation required
for RSA CB’s?
• DMR/DOL approval
• Testing ISO 17025 (Test labs)
• Certification under SANAS ISO17065…
45
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.
46
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?
47
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)
48
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.
49
11. “I will have my
equipment certified by a
markholder”
• Perception in industry.
• Ex n Motors
• Markholders “certifying” machines
50
Questions???
Contacts:
Roelof Viljoen
083 235 5256
[email protected]
(012) 653 7594
51
10:45 – 11:15
SAFA RESPONSIBILITY OF THE
REPAIR FACILITY
Paul Meanwell
Presenting - SAFA
South African Flameproof
Association
Flameproof
Repairs
Maintenance
and Standards
South African Flameproof
Association

Training and competence
We’ve all seen this….
 Is it safe?

I don’t know! Not legal!
 Flange thickness
 Depth of thread
 Flame path length
 Free internal volume
 Pressure 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 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 10086-2?

South African Flameproof
Association

Competency
Competency is not the same is training
 Training without experience does not result in
competency
 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)


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 ethics
 Upstream – 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 Change

ADKAR – A 5 step model
AWARENESS
 DESIRE
 KNOWLEDGE
 ABILITY
 REINFORCEMENT

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

Global
SANAS

National - STC
CB’s & TL’s

National
South African Flameproof
Association

Lets look at “the System” cont…….
Mnfr

Needs Mnfr Licence
Repairer

May need a licence
Pirate

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
11:15- 12:00
LEGAL REQUIREMENTS AND
IMPLICATIONS OF NON
CONFORMANCE
Ntabiseng Mphahlele
Presenting - 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 COUTINHO
Director 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
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
Questions
Thank you for listening
12:00-12:30
OPEN DISCUSSION
12:30- 12:55
ACKNOWLEDGEMENTS
Acknowledgements
• Sasol Club
• Presenters
• Attendees
• Simon Orchardson
• Leoni / Lynette
12:55-13:00
MEETING CLOSURE
13:00
LUNCH & NETWORKING

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