RACA Journal January 2019 | Page 67

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 www.hvacronline.co.za 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