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SACEA SAFETY WORKSHOP

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

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SACEA SAFETY WORKSHOP

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  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 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

  3. 08:00-08:30 Registration Tea & Coffee

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

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

  6. SACEASafety Workshop Presenter - Piet Prinsloo 16.10.2014

  7. SACEAFlame 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 ?

  22. 09:15 – 09:45 A Guideline for ex d equipment repairs as required by ARP0108 and SANS 60079-19 David Maree Presenting - EXPLOLABS

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

  24. Introduction Original Equipment Manufacturer Repair Facility End User

  25. 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..

  26. 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

  27. Repair without documentation

  28. 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

  29. 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!

  30. 10:00 -10:15 TEA BREAK

  31. 10:15 – 10:45 Comparison of the IECEX services scheme vs. RSA mark scheme requirements Roelof Viljoen Presenting - MASC

  32. Repair Markschemes in RSA IECExservices 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. How does • IECEx • and • RSA Markscheme • Requirements • differ in practice?

  35. OD015 helpful templates • Flameproof enclosures

  36. OD015 helpful templates Flameproof – equipment installed inside enclosures

  37. Some specific issues / questions

  38. 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.

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

  40. 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.

  41. 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?

  42. 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)

  43. 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.

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

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