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 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 & Coffee 08:00-08:30 Registration Tea & Coffee

08:30 – 08:45 Opening and Welcome Louis Botha Presenting - SACEA

Typical Deviation found 08:45 – 09:15 Typical Deviation found Piet Prinsloo Presenting - SASOL

SACEA Safety Workshop Presenter - Piet Prinsloo 16.10.2014

SACEA Flame Proof Safety workshop Deviations found during audits

Contend Introduction Process followed Audit results/ Audit Findings Post audit actions Questions

Introduction

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

Process followed

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)

Audit results/ Audit Findings

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

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.

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

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.

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)

Post audit actions

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

Questions ?

09:15 – 09:45 A Guideline for ex d equipment repairs as required by ARP0108 and SANS 60079-19 David Maree Presenting - EXPLOLABS

Presented by : David Maree A guideline for Ex ‘d’ equipment repairs in accordance with SANS 60079-19 and ARP0108 Presented by : David Maree

Original Equipment Manufacturer 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 Adequate facilities Personnel competency as per Annex B of SANS 60079-19 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.” 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)

Standards and rules: Manufacturing of new product: Repairs: Rules: 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?)

How does IECEx and RSA Markscheme Requirements differ in practice?

Flameproof enclosures OD015 helpful templates Flameproof enclosures

Flameproof – equipment installed inside enclosures OD015 helpful templates Flameproof – equipment installed inside enclosures

Some specific issues / questions

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.

3. Is SANAS accreditation required for RSA CB’s? DMR/DOL approval Testing ISO 17025 (Test labs) Certification under SANAS ISO17065…

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.

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?

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)

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

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

Questions??? Contacts: Roelof Viljoen 083 235 5256 viljoenr@masc-ex.co.za (012) 653 7594

SAFA responsibility of the repair facility 10:45 – 11:15 SAFA responsibility of the repair facility Paul Meanwell Presenting - SAFA

Flameproof Repairs Maintenance and Standards

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

Question is……….. Will it get fixed, and when?

When does safe become unsafe?

Who will stop a machine for this?

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

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?

Competency The DRC experience….. 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…..

YOU – 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 ethics Upstream – Demand that your suppliers do the right thing. Audit them yourselves. Set your own standards! It’s competitive out there!

Resistance to Change AWARENESS DESIRE KNOWLEDGE ABILITY REINFORCEMENT ADKAR – A 5 step model AWARENESS DESIRE KNOWLEDGE ABILITY REINFORCEMENT

You rely on certificates…….. But you don’t read them!

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?

Lets look at “the System” ILAC Global SANAS National - STC CB’s & TL’s National

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

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

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

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

Thank You www.flp.co.za

Legal Requirements and implications of non conformance 11:15- 12:00 Legal Requirements and implications of non conformance Ntabiseng Mphahlele Presenting - DMR

AA COUTINHO Director Mine Safety 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: 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 10108 are not applicable to the employer;

Hazardous Locations … continue 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; 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”; 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

Thank you for listening Questions Thank you for listening

12:00-12:30 Open Discussion

12:30- 12:55 Acknowledgements

Sasol Club Presenters Attendees Simon Orchardson Leoni / Lynette Acknowledgements Sasol Club Presenters Attendees Simon Orchardson Leoni / Lynette

12:55-13:00 Meeting closure

13:00 Lunch & networking