Back to basics
ANDREW PERKS
Andrew Perks is a subject expert in ammonia refrigeration. Since undertaking his apprenticeship in Glasgow in
the 1960s he has held positions of contracts engineer, project engineer, refrigeration design engineer, company
director for a refrigeration contracting company and eventually owning his own contracting company and low
temperature cold store. He is now involved in adding skills to the ammonia industry, is merSETA accredited and
has written a variety of unit standards for SAQA that define the levels to be achieved in training in our industry.
HOW DO NEW LAWS AFFECT ME?
By Andrew Perks
I suppose like everyone else you are getting sick and tired with all the new
legislative requirements that just seem to keep coming and you need to
conform to. Not so long ago we just got on with the job, now you have to be
registered to do this and that.
W
ell, let’s face it, things have changed. The level of skills in
the industry should have been improving but not at the rate
of growth in the industry. Something had to be done to safeguard
both the client and the contractor. Back in the day, our level of
skills was mostly imported, but currently we seem to be suffering
from attrition where the skilled artisans are retiring/emigrating or
changing direction. So, we need to upgrade our home grown skills
level. There is a lot going on behind the scenes with the Setas and
QCTO setting new learnership material.
SAQCCGas has rearranged their different categories for A, B
and C accreditation to a more specific list. We are waiting on the
new Seta initiative. SANS 10147 is currently being reviewed (as it is
every 5 years). Lots of things are in the mix and all are designed to
quantify the skills levels and safety requirements for the industry.
Now that’s all well and good, but what about the clients
themselves – what are they doing to ensure their plants are safe
for their people to operate and by extension, the safety of their
neighbours and site visitors? The general consensus is that any
plant that has hazardous material on site is an MHI. Don’t give me
that argument that it’s only after 20 000kg that an Ammonia plant
becomes an MHI, read the OHS Act properly – that’s the level where
you have to notify the Department of Labour that you have that
quantity on site in a fixed vessel.
There are many large refrigeration plants in South Africa but
none that I know of that meets that quantity in one vessel. Normally
it’s spread all over the site. Let’s face it, if we were in a 12m² room
and we open up a 63kg bottle of ammonia, we would all die. So, it’s
not about quantity - it’s about the level of risk.
Statistically the majority of releases are caused while plant
operators and technicians are working on a plant. An incident
develops that for a variety of reasons escalates from an incidental
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RACA Journal I January 2020
release to a hazardous situation. Employing proper skilled artisans
or contractors and undertaking a risk assessment for every
procedure mitigates the risk, but if the plant is not compliant the
level of risk escalates.
All refrigeration plants should have Certificates of Conformity
for the complete installation with subsequent CoCs being issued for
all modifications and upgrades that transpire during the life of the
system. It is also a legal requirement that if a facility is sold it must
be sold with all the compliance paperwork and that includes a CoC
for the refrigeration system.
The question of course is how many plants are compliant
with the legal requirements of SANS 10147. I have done many
compliance audits and need to let you know there are not many
plants that meet the criteria. While the majority of contractors
may accept that that’s the way it is and get on with the job,
it’s not right and they are putting their staff at risk. But just
wait till there is an incident and the powers at be get involved
– especially if there has been a fatality. Insurance companies
are now starting to want to know their level of risk and the only
way they can do that is to compare the site against the legal
requirements which is SANS 10147.
Another requirement of the MHI regulations is that each site
must have an Emergency Plan to SAN 1514:2018. It’s really all about
systematically laying out the procedures that will kick in for all the
possible site incidents.
In conclusion, all refrigeration plants must have a CoC to SANS
10147. If the refrigerant is hazardous, the site is an MHI and must
have a site emergency plan. Legislation is there for a reason – to
keep the plant compliant; to keep it safe.
Next month we’ll have a look at what an emergency plan to
SANS 1514 entails. RACA
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