By Grant Laidlaw
These systems are not exempt from the pressure equipment regulation (PER) and yes, you do have to issue certificates of conformance once you have worked on the pressure envelope.
Johan asks: Hi Grant, I am working with smaller air conditioning systems and automotive air conditioning. The systems are typically found in earth moving equipment. With regards to the pressure equipment regulations, are these smaller systems exempt? If not, to what extent are they covered in the regulation, for example do I have to issue a conformance certificate when I have worked on the system?
Hi Johan, for some reason there is confusion in the motor industry in that automotive air conditioning systems are exempt for the pressure vessel regulation; this is not the case.
The reality is that the regulation applies to any system with an operating pressure of more than 50kPa. The operating pressure is determined by the refrigerant utilised in the system rather than the size of the equipment.
But let us have a look at the regulation in greater detail.
What we are discussing is the Department of Labour Occupational Health and Safety Act, 1993 Pressure Equipment Regulations – 15 July 2009 No.323953.
There is a substantial list of definitions in the act but let us focus on the ones that are relevant to your questions.
- “Authorised person” means a person who is registered as competent within the scope of work for which an organisation approved by the chief inspector has registered that person;
- “certificate” means a written declaration of conformance to these regulations;
- “construction” includes materials, design, fabrication, modification, repair, installation, examination, inspection, testing and certification;
- “design pressure” means the gauge pressure used in the design formulae to determine the dimensions of the component parts of the pressure equipment;
- “design temperature” means the temperature used in the design formulae to determine the dimensions of the component parts of the pressure equipment;
- “fluid” means gases, liquids, vapours in pure phase and mixtures thereof and may contain solids in suspension;
- “gas” means gases, liquefied gases, gases dissolved under pressure, vapours, and those liquids whose vapour pressure at the design temperature is greater than 50kPa above normal atmospheric pressure;
- “gas system” means an assembly of tubes, pipes or similar ducts, fittings and valves for the reticulation, circulation and conveyance of a gas, excluding a pressure vessel or transportable gas container connected to the system;
- “manufacturer” means any person who has overall control and is responsible for the construction of the pressure equipment;
- “piping” means pipes, tubes or flexible pressure hose elements intended for the transport or distribution of any fluid at a pressure of 50kPa or above when connected together for integration into a system, including heat exchangers consisting of pipes for the purpose of cooling or heating air;
- “pressure accessory” means devices with an operational function having pressure-bearing housing;
- “pressure equipment” means a steam generator, pressure vessel, piping, pressure accessory and safety accessory, transportable gas container, and fire extinguisher and includes, but is not limited to, an accumulator, a hot water geyser, and hyperbaric chambers;
- “pressure vessel” means a housing designed and manufactured to contain a fluid under a design pressure equal to or greater than 50kPa;
- “repair” means restoration to original standard by the application of heat or welding to any pressure equipment, or the replacement of expanded tubes, and in the case of non-metallic equipment it means the application of heat, welding, solvent cement, laminate or curing of thermo-set;
- “risk-based inspection” means an inspection scope based on the results of a formal risk assessment, including inspection and test intervals;
Johan, as you can see there are several references to the pressure vessel containing a fluid ‘gas’ with a design pressure equal to or greater than 50kPa. So, in summary the systems mentioned in your question have to comply – in full with the regulation, as do you, the manufacturer, and the user.
Johan, the scope of application includes:
1. a) These regulations shall apply to the design, manufacture, operation, repair, modification, maintenance, inspection and testing of pressure equipment with a design pressure equal to or greater than 50kPa, in terms of the relevant health and safety standard incorporated into these Regulations under section 44 of the Act.
b) Regulations 3, 4, 5, 9(1), 9(2) and 9(3) shall not apply to pressure equipment in use or on order prior to the publication of these regulations, which equipment shall be designed and constructed according to the requirements applicable at the time of order.
General requirements:
2. (1) Any person who manufactures, imports, sells, offers, or supplies any pressure equipment described in these regulations for use in the Republic shall ensure that such equipment complies with these regulations.
(2) Any person who erects or installs any pressure equipment for use in the Republic shall ensure, as far as is reasonably practicable, that it is erected or installed in a safe manner and without risk to health and safety when properly used.
(3) All pressure equipment for use in the Republic shall be categorised and submitted to the applicable conformance assessments of SANS 347 in addition to the requirements of the relevant health and safety standard incorporated into these regulations under section 44 of the Act.
Johan, let’s have a look at duties of users that have specific impact on you.
The user shall ensure that the pressure equipment is operated and maintained within its design and operating parameters.
The user shall, subject to the relevant health and safety standard incorporated into these Regulations under section 44 of the Act
ensure pressure equipment has a certificate issued by the repairer or modifier, including a verification signature by an approved inspection authority when required, which certifies that the pressure equipment has been modified or repaired in accordance with the relevant health and safety standard incorporated into these Regulations under section 44 of the Act;
ensure that pressure equipment has a certificate issued by an approved inspection authority before commissioning, where applicable; and
ensure that a gas system has a valid certificate issued by an authorised person.
Records
Every user of pressure equipment shall keep a record, which shall be open for inspection by an inspector, in which the certificate of manufacture, and the results, after manufacturing, of an inspections, tests, modifications and repairs shall be recorded.
When pressure equipment is sold, the manufacturer shall ensure that it is accompanied, where relevant, with instructions for the user, containing “the necessary safety information relating to:
mounting, including the assembling of different pieces of pressure equipment;
putting into service; and
maintenance, including checks by the user:
Provided that those instructions shall cover information affixed to the pressure equipment in accordance with these Regulations and the relevant health and safety standard incorporated into these Regulations by section 44 of the Act, with the exception of serial identification, and be accompanied, where appropriate, by technical documents, drawings and diagrams that are necessary for a full understanding of the instructions: Provided further that, if appropriate, the instructions shall also refer to hazards arising from misuse of the pressure equipment.
The manufacturer shall keep the original manufacturing records of the pressure equipment for a minimum period of 12 years.
Johan, thank you for the question, as I have said before, there exists some confusion, particularly in the automotive air conditioning sector with regards to exemption of these systems under the pressure vessel regulation. These systems are not exempt, this has been confirmed by SARACCA and SAQCC gas.
References:
- SARACCA
- SANS 10147
- OHS Act / Pressure Vessel Regulation
- SAQCC gas
Thank you for all your questions. Send your problems (and sometimes your creative solutions) to acra@netactive.co.za with ‘Solutions Page’ in the subject line. You may include pictures.
Click here for the latest issue of RACA Journal
