NEWS
The risk of opinion-based compliance
Treating timber by way of opinion-based decision making rather than in
accordance with the law will lead to the use of unsafe and non-compliant
pressure treatment vessels – which puts not only your treatment plant at risk,
but also the reputation of the industry.
According to Arijit Chandra, a professionally registered
mechanical engineer and a member of the Pressure
Equipment Regulations (PER) Technical Committee in
South Africa ignorance of the law is not an excuse. “The PER
were promulgated more than 10 years ago, in October 2009, and
not abiding by them will lead to fines or being shut down should
an inspector from the Department of Labour find you guilty of
non-compliance. You have to get yourself fully compliant,” says
Chandra.
He adds that without strict compliance to the PER governing the
manufacture and operation of pressure vessels, it is impossible to
ensure the health and safety of individuals employed in the industry.
“This is the reason why the regulations are so important and why
they have been mandated by the Occupational Health and Safety
Act,” says Chandra.
The design and certification of CCA pressure treatment vessels in
South Africa is governed by the PER, the Occupational Health and
Safety (OHS) Act and SANS 347. While some may disagree on this
classification, Chandra states that the regulations are clear on the
matter and that it is not for debate.
“Everything is based on the categories of the pressure equipment
that is being manufactured. The different categories of assessment
within the PER are dependent on the type of pressure equipment, its
design, pressure state of the fluid inside and the fluid group.
“Pressure equipment starts with a sound engineering practice and
then goes to category 1, 2, 3 and 4. Category 1 is the lowest level of
intervention and requires no third-party involvement, except for
pressure vessels manufactured to RSA/CI/OHSA, which will then
require AIA involvement. The SANS 347 standard will determine the
category and the equipment then needs to be manufactured as per
the requirement set out by this standard. CCA pressure treatment
vessels use the chemical pesticide chromate-copper-arsenate and
therefore fall under the category ‘filled with a hazardous fluid or hot
water mixed with a chemical,” explains Chandra.
To sell any pressure vessel (including Category 1 to 4) on the South
African market, manufacturers must follow the steps below to
ensure compliance.
• The pressure vessel must be designed to an acceptable health
and safety standard incorporated in the government gazette
R262 of 24 March 2017.
• The design must be signed off by a professional engineer.
• The design must be submitted to the Inspection Authority for
design verification.
• The manufacturer must follow all steps as required by SANS
347 to ensure compliance, under the supervision of the AIA.
PER
Without strict compliance to the PER governing the manufacture and
operation of pressure vessels, it is impossible to ensure the health
and safety of individuals employed in the industry.
• The AIA must counter-sign the manufacturer’s certificate.
• The name plate must be stamped by the AIA (manufacturing) to
meet the requirements of Regulation 9.2 of the PER.
Anyone purchasing a pressure treatment vessel must ensure that
after installation, a pre-commissioning inspection is carried out by
an approved inspection authority who will issue a precommissioning
inspection certificate. Thereafter, every 36 months,
the vessel must undergo an inspection by an in-service approved
inspection authority. Furthermore, the maintenance of existing
pressure vessels, which was regulated under previous regulations,
requires full AIA involvement during repairs or modifications.
According to Robert Fourie, sales engineer at Lonza Wood
Protection the CCA pressure vessels that are manufactured to a
specific standard has to be modified or repaired by a
manufacturer whose welders are certified within that standard.
“Users must ensure that the pressure equipment has
documentation certifying that modifications or repairs have been
carried out in accordance with the relevant health and safety
standard. This documentation must be issued by the repairer or
modifier and must include a verification signature by an approved
inspection authority when required.”
Senior Business manager at Lonza Wood Protection, JJ du
Plessis, says that we should never become complacent about the
health and safety risks associated with using non-compliant
pressure vessels when treating wood. “The legislation that is in
place provides fundamental safeguards and best safety practice
to maintain the good reputation of our industry and should
therefore be fully adhered to. If you are unsure whether your CCA
pressure treatment vessel is compliant, it would be in your best
interests to seek advice from the AIA or contact Lonza to guide
you through the process and place you in contact with the correct
professional vessel inspection authority,” says Du Plessis.
www.timberiq.co.za // OCTOBER / NOVEMBER 2020 3