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 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
Registration Tea & Coffee

4. 08:30 – 08:45
Opening and Welcome
Louis Botha
Presenting - SACEA

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

6. SACEA Safety Workshop
Presenter - Piet Prinsloo

7. SACEA Flame Proof Safety workshop
Deviations found during audits

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

9. Introduction

10. 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

11. Process followed

12. 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)

13. Audit results/ Audit Findings

14. 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

15. 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.

16. 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

17. 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.

18. 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)

19. Post audit actions

20. 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

21. Questions ?

23. 09:15 – 09:45
A Guideline for ex d equipment repairs as required by ARP0108 and SANS
David Maree
Presenting - EXPLOLABS

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

25. Original Equipment Manufacturer
Introduction
Original Equipment Manufacturer
End User
Repair Facility

26. 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
Meet Eddy…the fall guy..

27. 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

28. Repair without documentation

29. 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

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. 10:00 -10:15
TEA BREAK

32. 10:15 – 10:45
Comparison of the IECEX services scheme vs. RSA mark scheme requirements
Roelof Viljoen
Presenting - MASC

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

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

36. How does IECEx and RSA Markscheme Requirements
differ in practice?

38. Flameproof enclosures
OD015 helpful templates
Flameproof enclosures

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

43. Some specific issues / questions

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

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. 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. 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. 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.

50. 11. “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
SAFA responsibility of the repair facility
Paul Meanwell
Presenting - SAFA

53. Flameproof
Repairs
Maintenance
and Standards

54. 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

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

56. When does safe become unsafe?

57. Who will stop a machine for this?

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

59. 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 ?

60. 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…..

61. 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!

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

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

64. 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?

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

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

67. 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

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

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

70. Thank You

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

72. 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

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:
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 are not applicable to the employer;

74. Hazardous Locations … continue
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;
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”;
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
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;

76. 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”;

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
Thank you for listening

81. 12:00-12:30
Open Discussion

82. 12:30- 12:55
Acknowledgements

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

84. 12:55-13:00
Meeting closure

85. 13:00
Lunch & networking