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Compliance reports and site emergency plans

Compliance reports and site emergency plans

By Andrew Perks

I get asked this question repeatedly, “Why must I do a compliance report on my plant and how often?”

We all know that we need to drive a roadworthy vehicle, but seem to forget (or choose to ignore) this. And this really should apply to all mechanical equipment we use and operate. The issues only arise when an incident occurs and the inspector of machinery appears — a bit late to start thinking about it then.

The OHS Act’s major hazardous installation regulations stipulate that a review should be carried out every five years, or whenever there has been an alteration/upgrade, or an incident, or a near-hit incident. This holds good for a plant compliance report, too. So, you may ask yourself: compliance with what?

Well, we have the OHS Act and all its sub-regulations. That is really what we need to comply with. As specifically noted in the driven machinery section, clause 16, all our air-conditioning and refrigeration systems and equipment must conform to SANS 10147. So, a compliance report looks at operational systems and sets in place documentation highlighting non-compliance, with recommendations and procedures to bring the plant in line with the given standards and requirements of SANS 10147.

Are you compliant and do you have a site emergency plan in place? Best address it now if not.

This really should not be difficult as these regulations are common sense, but sadly, in my travels, very few sites actually conform. The common issues revolve around safety training, equipment, and staff awareness. Mandatory three-yearly pressure vessel and relief valve re-certification is another area of concern, not to mention the ongoing requirement for plant operators and technicians to be trained and certified by the South African Qualification and Certification Committee for Gas (SAQCC Gas) to their appropriate level of operation.

So, how is a compliance report compiled? Normally it will require a visit to the site installation to do a physical inspection of the equipment and to discuss issues and situations with the plant owners, operators, and sometimes the emergency services. From the visit a portfolio of evidence is drawn up (normally photographically), highlighting problems and providing solutions. For the past 10 years, I have been undertaking this work, but sadly, I return to some sites and nothing has changed in the past five years.

Doing the investigation does not make the problem go away; it just highlights the issues. You cannot really say you did not know about it once you have had the report; in actual fact, you are worse off.

So, who should be doing these reports? It should be an experienced subject matter expert. The objective at the end of the report is to get the compliance issues addressed and when compliant, to issue a Certificate of Conformity as per the Pressure Equipment Regulations’ requirements. This can only be done by a registered SAQCC Gas Level C inspector.

Another issue that is ignored or conveniently neglected, is a site emergency plan. When I recently did some training at the fire brigade / emergency services in Durban, I was asked, “Do all the ammonia plants have emergency plans?” I had to think about that and must confess, I haven’t seen many — and I have been around quite a few.

What is a site emergency plan? Well, it lays out the procedures that will go into place as and when an emergency like an ammonia release or a fire takes place, and how it will affect the entire site, the neighbours, and the surrounding areas. It is a set of procedures that identifies everyone’s roles and allows a format to be identified where all the role players know what to expect and who is who when the situation takes place.

Are you compliant and do you have a site emergency plan in place? Best address it now if not.

Click below to read the February 2018 issue of RACA Journal



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