Safety Compliance – CoC misinformation could be costly

By John Ackermann

Why is there so much legislation governing the design, installation, maintenance and repair of refrigeration and air conditioning systems?

The Pressure Equipment Regulation (PER), SANS10147, OSH Act and SANS 347 are just some of the regulations relevant to the pressurised circuit of R & A/C plant and systems. The regulations all have a common goal – to protect people and property where refrigeration facilities are located.

Personal injury and property damage could result from a sudden release of a toxic refrigerant or freeze injury to human tissue, explosion, fire from vapour on hot surface or flying debris from fractured piping or vessels. Each plant, depending on its location and/or refrigerant charge, irrespective of size, has potential hazards. Unfortunately, accidents have no boundaries and limits to time.

CoC001Certification of compliance with SANS 10147 is often thought to be only applicable to industrial plants charged with ammonia. All photos by John Ackermann

Adhering to good operating procedures and compliance with safety standards, which only comes from proper training, dilutes the hazards associated with R & A/C systems. It is well known, that most recorded personal injuries and damage to property from R & A/C systems could have been prevented by personnel following safety standards and a stricter enforcement of regulations.

Without enforcement, the untrained are able to operate alongside the trained, to create unfair trading conditions and run the risk of personal injury. The legal requirement of the PER is clear. All persons that perform any task associated with the pressured circuit of a R & A/C plant must be registered by SAQCC Gas for the task which they perform. The skills needed for such tasks are clearly set out in annexure D of SANS10147 edition 5.

A further requirement is the issue of a Certificate of Conformity (CoC) by those that perform any task on the pressurised circuit. The CoC is a declaration that the tasks were done by a registered person and done in accordance with the requirements of the PER. A copy is handed to the owner of the plant and the original held by the issuer.

It is of importance to note that a CoC is also required after any service work is done or just the replacement of a component if it involves opening of the pressurised circuit.

The PER also requires that each plant be certified as being compliant with the technical requirements of SANS10147. As to the level of certification and the parties involved in the certification is defined in SANS 347. The determining factor can in some installations be summarised briefly as the largest diameter of piping in the system. As an example, it could be the size of the discharge header in a packaged unit that will determine whether an AIA is required to issue the certificate of conformity or not.

CoC002Reference to SANS 0347 will define the required level of compliance certification of packaged equipment charged with synthetic refrigerants, for example R507.

The problem that causes total confusion in the field is that the certificate of technical compliance relating to the construction and makeup of the plant is also referred to as a CoC. The certificate of compliance in accordance with SANS 347 in most instances does not consist of a single document but has several sections such as piping certificates, pressure vessel certificates, weld X-ray certificates, design calculations for piping, selection of safety pressure relief valves.
The final certificate is to certify that all the mentioned certificates and other items including operating manuals and recommended safety procedures have been completed and in the possession of the contractor or service provider. The owner of the plant may also require a complete set of documents. Companies that provide risk cover for installations will require the certificate of (technical) compliance as a minimum and may even have further requirements.
As to the level of competency required of the person that issues the certificate of compliance with the statutory technical requirement is often seen to be a practitioner registered in category B.

The registration in category B authorises the holder to issue a Certificate of Conformity for installation maintenance and/or repairs. For a category B to issue a certificate to certify that an installation is compliant with the technical requirements of SANS10147 and SANS 347, such a person will require further expertise and a much higher level of training.

Many plants that should have a certificate of compliance with the technical are operating without due to the cost involved in compiling such a certificate and the lack of person available to issue such certificate.

Sadly, if any accident or injury should occur as a result of any failure of the plant or improper use, heavy penalties will be imposed during any subsequent investigation by the Department of Labour, which always occurs after such incidences.

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