NEWS 7 appeal which was adjudicated by the Lead Administrator of the SABS . This adjudication was clear on the way forward on addressing the review of SANS 10254 which was underpinned by two committee meetings to resolve the current committee impasse .
The second of the two committee meetings was held on 17 November 2021 , which now provides the basis for concluding the process of the review of SANS 10254 as per the adjudication by the SABS Lead Administrator on the appeal lodged by IOPSA . 7 . Was the SAQA Letter confirming that PIRB had not committed any wrong in the SAQA eyes not tabled ? If not , why not ? Based on your question , it is the understanding of the SABS that you have a copy of the letter from SAQA . We kindly encourage you to engage directly with SAQA on matters related to its policy mandate . The matter of whether PIRB has transgressed the SAQA Policy and criteria for Recognising a Professional Body and registering a Professional Designation is irrelevant and is of no importance to the deliberations of the committee .
The legal issues in this matter relate to the inalienable constitutional rights of freedom of association and freedom of trade , occupation , and profession and therefore any correspondence from SAQA is deemed irrelevant to the work of the committee . To place emphasis on this point , SAQA specifically distinguishes voluntary associations as non-statutory bodies . The crux of the foregoing is that SAQA does not confer any powers to non-statutory bodies except to register qualifications and professional designations .
Unless PIRB seeks to suggest that SAQA has conferred to it some regulatory authority , a position which has been established as incorrect , reference to SAQA remains irrelevant .
8 . The Technical Committee is formed by the SABS which includes members of industry / sector that would contribute to a meaningful and effective standard – that being so why was the PIRB COC ever introduced into relevant standards ? During the development of national standards , there may be instances where provisions / requirements that should not be included in the standard end up being inserted . National standards are publications that are subject to continuous review and this thereby presents the opportunity to address any matter in the standard , which may include an amendment or revision of the standard to ensure relevance and alignment to standardisation best practice .
9 . SABS ’ s decision to “ remove COCs in all standards ” comes as a knee jerk reaction out of the PIRB issue or has this been in the making for some time ? National standards are publications that are subject to continuous review which may include an amendment or revision of the standards to ensure relevance and alignment to standardisation best practice . The issue of PIRB has certainly highlighted the gravity of addressing COCs in national standards thereby initiating a process that entails the review of all publications that include COC requirements .
10 . Will SABS take responsibility for the PIRB COC in the standards mess as standards are their domain , fully under their control and command and written by them ? South African National Standards are developed by the SABS Technical committees and its diverse range of member representation that participate and contribute to the technical requirements of national standards . The process further includes the consultation with the broader stakeholder grouping as part of the public enquiry process .
As explained above , standards are living documents and can be reviewed at any given point in their lifecycle . Through this process the SABS ensures that national standards remain relevant and adhere to standardisation best practice .
11 . SABS may like to respond to the question , ‘ where does the withdrawing of the COC leave the consumer and indeed the plumber who had some quality protection from the abundance of unqualified people doing plumbing with dire consequences ?’ National standards published by the SABS are for voluntary application and therefore should not be misunderstood as mandatory requirements enforced by the SABS . The discussion by the committee which included the purpose of CoCs , requirement of accountability , consumer redress and traceability amplifies the requirement for a comprehensive regulatory framework for CoCs .
SANS 10254 as referenced in regulation including mandatory compliance and enforcement of quality assurance measures that are safety critical reside with the relevant regulatory authorities and a national standard should not usurp the regulatory powers of an authority .”
Editor ’ s comment : We have engaged with SAQA , who have recognised certain aspects of their processes are weak and commit to improving them , furthermore the issue of ‘ non-statutory ’ is being reconsidered by them to a more appropriate ‘ name .’ The SABS comment in Q7 is accepted nonetheless , and the question arose as to why it was not tabled .
With the best will in the world , and SABS ’ s skirting the direct answer it is inconceivable that SABS will not take responsibility for this issue . Their Norms are clear that a standard from beginning to end is the responsibility of the SABS through their various processes and procedures . Their chairperson , their writers and their processes and procedures . A multitude of processes that should pick up anomalies and not , “ that should not be included in the standards which end up being inserted .” ( Q8 )
Certainly , the Technical Committee , as mentioned is made up of qualified people in industry , hence the elevated level of input and intelligent discussion but they do not tell SABS to go against their own Norms .
Many will recall the disastrous SANS 721 debacle ( SABS ’ s first political standard I am told ) for which those who can least afford to replace that iniquitous ‘ not fit for purpose ’ piping , are still paying the price ! I said then never again must SABS put itself in that position and never should industry be put in that position .
Whilst the issue of COC in standards is done and dusted the fact that it appeared in a standard does not rest solely with the Technical Committee . PA
“ A multitude of processes that should pick up anomalies …..”
April 2022 Volume 28 I Number 2 www . plumbingafrica . co . za