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SABS response to media enquiry regarding Q & A SANS 10254
By
Rory Macnamara
Plumbing Africa requested a response to questions below from SABS which they have provided . The questions form part of the ongoing verbal inputs from others regarding this matter and questions being raised from a variety of interested / concerned parties . The SABS answers and questions are published as supplied to Plumbing Africa from the point of view that we see no reason to make a ‘ story ’ when the Q & A is self-explanatory . This also avoids misquoting or misrepresenting a point .
Plumbing Africa wishes to make it very clear , we do not have sight of Technical Committee minutes , access to appeals and subsequent discussions around the appeals and finally we do not have access to the Lead Administrator ’ s adjudication . This is important to note as we sit on the outside looking in and rely on publishable statements or documents to furnish the market with information . Finally , we do not rely on social media to provide answers .
This having been stated , we publish the Q & A in the hope that patient and not so patient readers can get definitive answers to the different stories going around , i . e ., the COC that was in the compulsory standard SANS 10254 , will be removed or is in the process of being removed according to whatever the process in SABS to remove this is and including to never include COCs in any standard in the future , be it voluntary or compulsory if called up by an Act of Parliament .
“ Please find the following responses to the enquiry submitted to SABS on 19 January 2022 ”. 1 . What consultation took place with all industries where a COC is mentioned in the standards ? ( HVAC & R , Mining , Water , Plumbing , Housing , Timber – the industries that we are involved with ) The development of South African National Standards is conducted through various stakeholder representatives that are members of the relevant SABS technical committees or subcommittees . SABS administers more than 250 technical and sub-committees that develop national standards within a diverse range of sectors and subsectors .
The number of national standards published to date by the SABS is more than 7400 and the review and maintenance of these publications for relevance are some of the tasks of the members of the SABS committees . Once a committee draft ( CD ) has been endorsed by the SABS committee i . e ., SANS 10254 it subsequently progresses to a public enquiry process ( DSS ) to which any stakeholder outside of the SABS TC / SC membership can comment on the draft national standard . This is the national consultation process through which all national standards are published .
2 . If the ARP was gazetted on the 12th of November when did the work start on the review and when was it finalised by SABS ? The review of ARP 013 : “ Rules for structure and drafting of national standards ” was initiated in February 2021 through internal review processes of continuous improvement of quality management system documentation and concluded in July 2021 . The document was subsequently subjected to the public enquiry process which included the distribution to all SABS committee members for comment .
3 . At this point can SABS accept that they have ‘ secretly ’ changed the playing field , where COCs are applicable ? The question assumes that there was no consultation . The public enquiry process for ARP 013 : “ Rules for structure and drafting of national standards ” was conducted from 08 July 2021 to 07 September 2021 . As illustrated above the SABS further extended the enquiry stage to all SABS committee members for comment to ensure inclusive committee stakeholder participation and consultation . In summary , consultation at both the SABS committee level and public enquiry was conducted which led to concluding the review of ARP 013 in November 2021 .
4 . Either way , why was a statement not made on a topical issue such as this ? The SABS maintains a portfolio of more than 7400 national standards and follows the current due process of consultation with stakeholders and the issuing of public statements in whatever form is not part of the current SABS process of consultation on publications .
5 . Now to the PIRB case . If the ARP is a forward document , the PIRB issue remains just that . My understanding was that public comment closed on the 24th of November 2021 . Therefore :
6 . Why has the PIRB matter taken so long to reach some point of finality as ARP indicates ? As you are aware , SANS 10254 is currently undergoing a process of review . During the review process IOPSA had submitted an
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