In her brief outline of PER implementation, Matlala Sathekge of the Department of Labour was candid and told attendees,“ It’ s all good when there are no incidences, but the day something happens on site and damage occurs or harm to persons, it becomes a big, costly wake up call.”

The implementation of the PER is faced with three primary challenges, according to Sathekge. The first relates to new pressure equipment that is coming into South Africa and has never been checked for compliance. Secondly, many large role players have not taken the time to acquaint themselves with the PER; and lastly, the low level of compliance in the workplace is of concern.

Jacob Malatse, director of the Department of Labour, acknowledged the work done by the South African Qualification & Certification Committee( SAQCC) Fire, SALPGA, the Southern Africa Compressed Gases Association( SACGA), the Safety Compliance department of the Cape Town City Council, the Natural Gas Association, the inspectors of the PER and its implementation.“ The PER is about creating a safe environment for industry, commerce and business. It is not about restrictive regulations; but rather about having a safe workplace and preventing harm to all members of the public who use pressurised

equipment or visit places with pressurised systems, such as gas cookers in restaurants.”

The many issues raised by industry role players since the PER guidelines were gazetted on 3 February 2012, prompted further clauses to be added. Referring to the updated guidelines published on 27 February 2015, Paulo Pereira of Intertek and an advisor to the PER forum, provided insight into the new clauses added since 2012.

Many of the revisions referred to by Paulo were of particular relevance to the LPG and steam generation sectors. Some of the noteworthy updates for the refrigeration sector can be summarised as follows:

• An authorised person has been further defined as being registered by SAQCC( Gas) as a practitioner in the applicable field.

• In the instance of an installation by multiple parties, for example a refrigeration plant being completed by different parties, a single party has to be defined as being in overall control and responsible for issuing a certificate of manufacture.

• Refrigeration and air‐conditioning systems are classified in terms of the PER as closed recirculation systems.

• Semi-hermetic and open drive compressors for refrigeration and air‐conditioning applications are excluded from the scope of application of the PER.

• Plate heat exchangers are classified as pressure vessels and shall be categorised as per SANS 347.

• The importer of pressure equipment into South Africa for use and / or re‐sale, is deemed to be the manufacturer

and must declare conformance to the PER. Conformity assessment reviews are to be countersigned by an approved inspection authority( AIA) as applicable.

• The in‐service inspection of refrigeration systems after nine years can be performed in accordance with Annexure H of SANS 10147, in lieu of a RBI management system.

Pereira went on to answer some commonly asked questions: a

• Original records required in terms of the PER are to be kept for a minimum period of 12 years.

• The requirement of an AIA to inspect vessels and assemblies does not apply to pressure accessories.

• The intervals between the inspections of relief valves is to be the same as that for the pressure vessel to which it’ s attached.

• The required pressure gauge for a pressure vessel need not be attached to the vessel but can be remote.

• Insulation does not need to be removed for the three‐year inspection of pressure vessels. The decision to remove the insulation will depend on the outer appearance and will rest with the AIA.

Role of SANAS The technical infrastructure of South Africa rests on four conformity assessment bodies( CAB). Linda Grundlingh presented the role of the South African National Accreditation System( SANAS) as the only national body responsible for carrying out accreditations

in respect of conformity assessments. Accreditations done by SANAS include those of calibration and verification laboratories, certification bodies, inspection bodies and rating agencies.

The accreditations formally demonstrate the competency to carry out tasks against specified criteria in national and / or international guides and standards.

Grundlingh further explained the interrelationship between the other national assessment bodies, including the South African Bureau of Standards( SABS), the National Metrology Institute of South Africa( NMISA), and the National Regulator of Compulsory Specifications( NRCS). CLA

The complete Guidance Notes to the Pressure Equipment Regulations of July 2009 can be downloaded from the Department of Labour’ s website( www. labour. gov. za).

The updated guideline was published on 27 February 2015.