By Andrew Perks
I suppose like everyone else you are getting sick and tired with all the new legislative requirements that just seem to keep coming and you need to conform to. Not so long ago we just got on with the job, now you have to be registered to do this and that.
Well, let’s face it, things have changed. The level of skills in the industry should have been improving but not at the rate of growth in the industry. Something had to be done to safeguard both the client and the contractor. Back in the day, our level of skills was mostly imported, but currently we seem to be suffering from attrition where the skilled artisans are retiring/emigrating or changing direction. So, we need to upgrade our home grown skills level. There is a lot going on behind the scenes with the Setas and QCTO setting new learnership material.
SAQCCGas has rearranged their different categories for A, B and C accreditation to a more specific list. We are waiting on the new Seta initiative. SANS 10147 is currently being reviewed (as it is every 5 years). Lots of things are in the mix and all are designed to quantify the skills levels and safety requirements for the industry.
Now that’s all well and good, but what about the clients themselves – what are they doing to ensure their plants are safe for their people to operate and by extension, the safety of their neighbours and site visitors? The general consensus is that any plant that has hazardous material on site is an MHI. Don’t give me that argument that it’s only after 20 000kg that an Ammonia plant becomes an MHI, read the OHS Act properly – that’s the level where you have to notify the Department of Labour that you have that quantity on site in a fixed vessel.
There are many large refrigeration plants in South Africa but none that I know of that meets that quantity in one vessel. Normally it’s spread all over the site. Let’s face it, if we were in a 12m² room and we open up a 63kg bottle of ammonia, we would all die. So, it’s not about quantity – it’s about the level of risk.
Statistically the majority of releases are caused while plant operators and technicians are working on a plant. An incident develops that for a variety of reasons escalates from an incidental release to a hazardous situation. Employing proper skilled artisans or contractors and undertaking a risk assessment for every procedure mitigates the risk, but if the plant is not compliant the level of risk escalates.
All refrigeration plants should have Certificates of Conformity for the complete installation with subsequent CoCs being issued for all modifications and upgrades that transpire during the life of the system. It is also a legal requirement that if a facility is sold it must be sold with all the compliance paperwork and that includes a CoC for the refrigeration system.
The question of course is how many plants are compliant with the legal requirements of SANS 10147. I have done many compliance audits and need to let you know there are not many plants that meet the criteria. While the majority of contractors may accept that that’s the way it is and get on with the job, it’s not right and they are putting their staff at risk. But just wait till there is an incident and the powers at be get involved – especially if there has been a fatality. Insurance companies are now starting to want to know their level of risk and the only way they can do that is to compare the site against the legal requirements which is SANS 10147.
Another requirement of the MHI regulations is that each site must have an Emergency Plan to SAN 1514:2018. It’s really all about systematically laying out the procedures that will kick in for all the possible site incidents.
In conclusion, all refrigeration plants must have a CoC to SANS 10147. If the refrigerant is hazardous, the site is an MHI and must have a site emergency plan. Legislation is there for a reason – to keep the plant compliant; to keep it safe.
Next month we’ll have a look at what an emergency plan to SANS 1514 entails.