Impact of the PER on SAQCC Competent Persons and a reminder of certification requirements,...

Impact of the PER on SAQCC Competent Persons and a reminder of certification requirements, continuing professional development and ethical responsibilitiesCT BranchFebruary 2011

Changes in responsibilities for periodic inspection from VUP to PER

VUP Responsibility for periodic inspectionsVUP Responsibility for periodic inspections

Responsibility squarely on the shoulders of the User.Constraints applying to User were

Had to use a SAQCC CP certified inspector

Obligated to ensure inspector had appropriate knowledge and experience for the specific job of inspection

PER Responsibility for periodic inspectionsPER Responsibility for periodic inspections

Regulation 11 User may inspect Category 1 Equipment (SANS 347

categorisation) – Are you familiar with SANS 347? Higher categories must be inspected by an AIA In-

Service (AIA-IS) – From April 2011 Inspection task has to be performed by an authorised

person

AIA-IS has to ensure the authorised person Is certified by SAQCC CP Has appropriate experience and knowledge for the

specific task

PER Responsibility for periodic inspectionsPER Responsibility for periodic inspections

Notes of caution

There is a shift of responsibility (and accountability) to the AIA-IS as a body specialising in periodic inspections

Not permissible for an AIA-IS to use a ‘non-certified’ inspector to perform work which is ‘signed-off’ by a certified CP

Requirements for AIA-IS approvalRequirements for AIA-IS approval

Requirements for appointment as an AIA-IS by Dept. ofLabour have recently been clarified and include

SANAS assessment will be required prior to DoL approval

SANAS will use SANS 10227 and ISO 17020 as the standards applicable for AIA-IS assessments

First let’s deal with the issue of whether an individual become an AIA-In Service?

SANS 10227 requirements

SANS 10227:2007

Criteria for the operation of inspection

authorities performing inspection

in terms of the

Pressure Equipment Regulations

SANS 10227 Requirements for an AIA-In ServiceSANS 10227 Requirements for an AIA-In Service

Permanent staff will need to include:

Technical Manager (degree, T4, Cert. Eng. or B Tech)

At least 1 Certified CP (PV/SG certified depending on scope of activities)

Can be the same person!Can be the same person!


The AIA In-Service management system will need to include documented procedures for the following:

Step by step activities of an in-service inspection and how each step is carried out.

Re-certification and re-rating equipment. Dispensation of internal inspections or hydro tests. Storage and filing of records. Stamping the nameplate, if necessary Stamp control


The AIA In-Service Personnel will need to comply withTable 1 requirements for:

Design Verifier (Pr Eng, Pr Tech, Pr Cert Eng + 4 years experience)

Technical Manager (Degree, T4, Cert Eng, B Tech + 4 years experience)

Inspector (SAQCC CP)

SANS 10227 Requirements for AIA-IS approval?SANS 10227 Requirements for AIA-IS approval?

SUMMARY

SANS 10227 requirements are not ‘over the top’ andare appropriate to an AIA-IS because:

An AIA-IS deals with complex in-service issues including down-rating and re-certifying equipment.

The AIA-IS will need to have most of the competenciesassociated with ‘traditional AIAs’ including a designevaluation

ISO 17020 requirements

SANS 17020:1998

General criteria for the operation

of various types of bodies

performing inspection

Has been incorporated into SANS 10227 since 2007

Until recently SANAS did not audit compliance with ISO 17020 as PER

was not enacted

SANS 17020SANS 17020

Administrative requirements e.g. legally identifiable body

(SAN10227 specifically excludes sole proprietor)

Independence, impartiality and integrity e.g. commercial influence

cannot influence inspection results

Confidentiality

Organisation and management

Quality system

Personnel e.g. appropriate qualifications

SANS 17020 ContentSANS 17020 Content

Facilities and equipment

Inspection methods and procedures

Handling inspection samples and items

Records

Inspection reports and inspection certificates

SANS 17020 Content (cont.)SANS 17020 Content (cont.)

Subcontracting (obligations on the inspection body)

AIA shall itself normally perform work it contracts to undertake

Advise the client of its intention to subcontract and the

subcontractor has to be acceptable to the client

Demonstrate subcontractors competence for service performed

Maintain a register of all subcontracted work

Record and retain details of investigation of competence and

compliance of subcontractors

When subcontracting specialised activities must have access to

alternative resource able to independently assess results of

subcontracted activities and retains responsibility for

determination of conformity


Complaints and Appeals

Co-operation (inspection body expected to share experiences with other inspection bodies)


ISO 17020 Requirements for AIA-IS approval?ISO 17020 Requirements for AIA-IS approval?

SUMMARY

Compliance with ISO 17020 would be extremelydemanding for an individual

Can an individual become an AIA-IS?

Can an individual CP become an AIA-IS?Can an individual CP become an AIA-IS?

Theoretically yes but in reality it is just about impossible

The reality is that the vast majority of CPs will need to find employment with an AIA-IS from April this year

What changes to the SAQCC CP system have the PER prompted?

Changes to the SAQCC CP Certification scheme?Changes to the SAQCC CP Certification scheme?

Certification criteria remain the same

Physical capability

Successful completion of approved training course

Supervised practical training

SAQCC CP Certification CriteriaSAQCC CP Certification Criteria

Physical capability

Satisfactory vision in at least one eye

Ability to access vessels through manholes

Any other deficiency which prevents the applicant from performing inspection duties


Successful completion of approved training course

SAIW course and examination is approved by SAQCC CP


Supervised practical training

Minimum periods are applicable

Minimum number of vessels is applicable

Credits for educational and trade qualifications reduce training period


Education qualifications or industrial certifications

Minimum training period Practical experience requirement

N2/ Std 8 /Gr 10 or lower 5 years (10 vessels) Minimum of 10 boilers and 10 pressure vessels for each category of certification

N3 / Matric / Gr 12

N4

N5

3 years (10 vessels) As above

Technikon S4

N6 / S3

G.C.C.

IPE

BSc or B.Tech

1 year (10 vessels) As above

Note (1) Post schooling qualifications such N4, N5, N6, S3, S4, BSc degree should be in mechanical engineering, metallurgy or other relevant engineering or engineering science discipline. Qualifications are subject to review by the certification body.

Note (2) Applicants who have successfully completed a trade test or apprenticeship contract as a boilermaker, welder, blacksmith, fitter, millwright and fitter & turner are given a 1 year credit with the proviso the minimum training period is not less than one year.


Certification categories remain the same

Pressure vessels Unlimited scope Limited scope – air receivers with and without

physical access, accumulators, medical or other small autoclaves

Boilers (renamed Steam Generators) Unlimited scope


Training course requirements have been changedsignificantly to address

longstanding concerns about the inadequacy of the scope and depth of training

the clear allocation of responsibilities of the AIA-IS and the CP in job of work


There is one change to supervised practical training requirement

When a certification candidate is already certified in one of the unlimited categories of equipment the duration of supervised experience required for certification in the other unlimited category is reduced to 1 year irrespective of the educational qualification level

What are the new SAQCC CP training requirements?

New SAQCC CP PV and SG training requirementsNew SAQCC CP PV and SG training requirements

CP PV CP PV

Existing Syllabus New SyllabusProcess Plant

1 Week 4 Weeks

for limited for unlimited PV PV certification Plus Certification

Foundation CourseWelding and NDT

New Syllabus1 Week

CP Steam Generator CP Steam GeneratorExisting Syllabus Mandatory New Syllabus

additional Additional Theory1 Week 1 Week

New CP training scheme requirementsNew CP training scheme requirements

Persons intending to apply for limited PV certification will need to attend only weeks 1 and 2 of the PV stream. Those intending to apply for Unlimited will need to attend all 6 weeks

Persons intending to apply for Steam Generator certification will need to attend all three weeks of the Steam Generator stream

When and how were the new courses introduced?When and how were the new courses introduced?

New course requirements came into effect from January2011

Industry experts worked with SAIW to develop new course material

SAIW lecturers have been trained by industry experts and have undertaken bridging exams covering the new material

Will changes to the SAQCC CP system impact on existing certified persons?

What will happen to existing certified persons?What will happen to existing certified persons?

All existing certifications will be retained

Renewals and recertification will be treated as they are currently

How long is certification valid?

SAQCC CP Certification RulesSAQCC CP Certification Rules

Validity of certification

Certification is valid for 9 years

But

Certification must be renewed after 3 years then again after 6 years else it lapses

After 9 years in total certification expires and an application for recertification must be submitted


Requirements for 3 year and 6 year renewals arethe same Evidence of continued satisfactory eye sight Evidence that you have inspected at least ten vessels

(CP-PV) or six boilers (CP-B) in three years Evidence of at least 24 hours CPD in the three year

period of certification

Additional Requirements for re-certificationAdditional Requirements for re-certificationAs above plus there is also a requirement to pass anAs above plus there is also a requirement to pass anexamination which will assess awareness of changes to examination which will assess awareness of changes to regulations and codesregulations and codes


Re-newal and recertification applications

Apply using SAQCC CP form for periodic renewal or recertification

Apply at least 3 months before certification lapses Any inspections carried out after the expiry date stated on

the certificate are not valid and you are acting fraudulently

If you apply late usually no penalty will be applied for up to three months after expiry date on your certificate

After three months you may be asked to attend a professional interview and penalties will apply

Continuing professional development


CPD requirements Structured or developmental activities where each

hour is recognised as a CPD hour (minimum 25% of the total CPD credits must be this type)

Semi-structured activities where two hours are recognised as a CPD hour (maximum 50% of total CPD credits shall be of this type)

Unstructured activities where each four hours are recognised as a CPD hour (maximum 25% of total CPD credits shall be of this type


Examples of structured CPD activities Attendance at approved conferences, seminars, technical

meetings presented by professional institutions Presentations at approved technical events Preparation of technical articles for publication Approved teaching or lecturing In-house training on a formal recorded and auditable

programme Further education studies relevant to field of certification Approved relevant short courses


Examples of semi-structured CPD activities

Further education studies not necessarily directly related to CP activities

Private study of relevant publications and journals


Examples of unstructured CPD activities

Private study involving distance learning

Attendance at technical meetings within an employer organisation (excludes progress, planning and production meetings)

Competent person ethical responsibilities


Code of Ethics is aimed at

Protecting the public and users and workers operating pressurised equipment

Reinforcing the professional standards expected of Competent Persons

Enhancing the professional standing of Competent Persons


Examples of requirements of the Code of Ethics Do not undertake work for which you do not have the necessary experience and don’t go beyond your scope of learning and capability e.g. don’t de- rate equipment and return to service – this is the job of expert engineers

Do not sign an equipment inspection and test report if you have not personally performed the work e.g. don’t allow anyone else to perform work and then sign off a report – protect your signature jealously


Examples of requirements of the Code of Ethics Where warranted make use of specialists e.g. it is your responsibility to identify and report corrosion damage but not to decide on useful remaining service life

Indicate to your employer adverse consequences if your advice is overruled by a non-technical authority or supervisor e.g. don’t be bullied for commercial convenience


Failure to comply with the Codeof Ethics can have very serious consequences.

Maintain your integrity.

SUMMARY

SUMMARYSUMMARY

From April the individual CP will disappear Many AIAs have included in-service inspection in their

scope of activities informally in the past. Now they are

required to demonstrate their capabilities for these

activities by assessment PER enhances the status of AIAs significantly and there is

an expectation of professionalism by the regulatory

authorities AIA-IS will take on the legal responsibility for inspections

so they should be extremely careful about their

relationship with contracting CPs

SUMMARYSUMMARY

The changes made by SAQCC CP are intended to improve the competence of CP inspectors and support AIA-IS companies in meeting their responsibilities

Existing CPs are unaffected by changes to the certification training requirements

CPs must enhance their standing through professionalism and ethical responsibility

Impact of the PER on SAQCC Competent Persons and a reminder of certification requirements,...

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