Responsible Refrigeration
BARNEY RICHARDSON
Barney Richardson is the director of South African Refrigeration and Air
Conditioning Contractors Association (SARACCA) and sits on various other
boards within the HVAC industry, including the South African Qualifications
and Certifications Committee for Gas (SAQCC) Gas.
CoCs AND THE LAW
By Barney Richardson
We often get asked where the requirement for a certificate of conformity
(CoC) comes from.
T
he straight answer is the Pressure Equipment Regulations
(PER), which was first published in July 2009 and reissued
with guide notes in February 2015. The regulations were updated
in November 2017.
Regulation 17(3) states: “An authorised person or an
approved inspection authority shall issue a certificate of
conformity after completion of a gas installation, modification,
alteration, or change of user or ownership.” This requires of the
contractor, installer, or mechanic to be registered and to be in a
position to issue a CoC for the new installation or maintenance/
repair work done.
In addition to the PER, there is a requirement of the
Occupational Health and Safety Act, 1993 (Act No. 85 of 1993)
(OHS Act), in Section 10: General duties of manufacturers and
others regarding articles and substances for use at work:
1.
2.
3.
Any person who designs, manufactures, imports, sells or supplies
any article for use at work shall ensure, as far as is reasonably
practicable, that the article is safe and without risks to health
when properly used and that it complies with all prescribed
requirements.
Any person who erects or installs any article for use at work on or in
any premises shall ensure, as far as is reasonably practicable, that
nothing about the manner in which it is erected or installed makes it
unsafe or creates a risk to health when properly used.
Any person who manufactures, imports, sells or supplies any
substance for use at work shall:
a. ensure, as far as is reasonably practicable, that the substance is
safe and without risks to health when properly used; and
b. take such steps as may be necessary to ensure that information
is available with regard to the use of the substance at work,
the risks to health and safety associated with such substance,
the conditions necessary to ensure that the substance will be
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4.
safe and without risks to health when properly used and the
procedures to be followed in the case of an accident involving
such substance.
Where a person designs, manufactures, imports, sells or supplies
an article or substance for or to another person and that other
person undertakes in writing to take specified steps sufficient
to ensure, as far as is reasonably practicable, that the article
or substance will comply with all prescribed requirements and
will be safe and without risks to health when properly used, the
undertaking shall have the effect of relieving the first mentioned
person from the duty imposed upon him by this section to such
an extent as may be reasonable having regard to the terms of the
undertaking.
Anyone installing refrigeration or air-conditioning equipment
must at all times be aware of their responsibility to ensure a safe
installation and that the user is aware of the correct operation of
the equipment. As HCFCs are phased out and new refrigerants
are introduced, the emphasis on valid registration, together with
safety and the practitioner’s awareness of the safe handling of the
refrigerant, becomes even more important. The current trend is
towards A3, A2, and A2L refrigerants, which have varying degrees
of flammability.
Practitioners must be aware that only an authorised person
who is registered with the South African Qualification and
Certification Committee for Gas (SAQCC Gas) may sign a CoC.
This authorised person is the one who has the training and the
competency assessment in the safe handling of refrigerant
gases and carries a valid registration card. The registration is
valid for a period of three years, after which a reminder is sent
for the practitioner to attend a refresher course and to renew the
registration for a further three years. RACA
RACA Journal I January 2019
65