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Meeting # 4 - 2013
DATE:
TIME:
VENUE:
21-November-2013
10h30
SAIW, Main Reef Road, Johannesburg
CHAIR PERSON:
SECRETARY:
ATTENDEES:
DISTRIBUTION:
Paulo Pereira
Marlize Koekemoer
As per signed Attendance Register
As per attached Register
AGENDA TOPICS:
#:
Discussion:
1.
2.
However, reference to the latest SANS 10227, reveals the following definition;
Re-Certification = Certification of previously certified equipment where the required traceability (to the
applicable statutory regulations and supporting documentation) is no longer available.
With regards to the PER Guidance Notes of March 2013 [ Revision 1], it is quite clear in note (c) as to when
the option of re-certification is available. Thus Vessels, which had initially been incorrectly certified as a nonPV, cannot now be reverse-engineered and recertified to become a PV.
3.
rd
Materials cannot be recertified by a 2 or 3 party. When a material is moved from Iscor to a forge shop for
example, wholl be classified as the Manufacturer? Will it be the initial fabricator of the material or the forge
shop?
nd
The raw materials are supplied with a 3.1 certification which is only product analysis. The 2 party, in this
case scenario the forge shop, who reworks and recertifies the material shall be the responsible
manufacturer for the 3.2 certified items.
Reference was made to SANS 31, paragraph 4.2 definition of a Manufacturer. Here, it is stipulated that the
manufacturer of the product in accordance to the requirements to order is the responsible party. Thus, the
manufacturer of the forging is responsible for the material with 3.2 certification.
Robyn referred to a recent SANAS Audit finding with regards to a material mill certificate form RUKKI.
Beware when there is no stipulation with regards to mechanical or chemical requirements.
Based on the above, the following scenario was sketched; if we have a whole batch of billets of which the 3.1
certification is available, is it allowed to destroy and test one of the billets in order to recertify the material
to 3.2 certified material? The answer; YES.
SUGGESTION: Write an internal procedure with the maximum verification requirements.
5.
7.
7.1
Incident:
Equipment was released to Site without the AIAs stamp, which was withheld because of
commercial issues. In this particular incident, the AIA was appointed by the End-User and not the
Manufacturer.
SANAS should verify the licence of the company. Also take note that IPEs are bound by a Code of
Ethics which should be adhered to at all times. This means that an IPE should not let Commercial
issues interfere with the Certification of Equipment.
2.
Query:
If a Laboratory is ISO 17025 Accredited, why does the AIA need to be present during mechanical /
tensile testing.?
SANS 347, paragraph 6.7.1.2.5; To carry out these approvals the third party shall perform
examinations and tests as set out in the appropriate health and safety standard(s).
In South Africa however, the AIA do not perform the tests themselves, but needs to witness them.
Thus, they have to be present.
Guidance Note (b) of Regulation 11 in the Act stipulates; witnessed inspections and tests, means
that the person performing the inspection is present during the pressure test required by subregulation and performs the internal and external inspections.
Questions:
What value is added to have the IPE present during the test? The inspector is there in a verifying
capacity.
But, Why are the Labs accredited then? It all comes down to independent verification and quality.
Take note that this is also a PED Requirement, and was adopted directly. Furthermore, it is normally
also a Client requirement, which means that the costs shall be allocate towards the Client and not
the Lab.
Linda suggested that we investigate the actual circumstances. As stipulated in SANS 347, para.
6.7.1.2.5, refer back to the Health and Safety standard. [Or also PED Guideline 6.1]
ACTION: Clarify the actual requirements for various inspection activities based on the Certification
to a Quality System. Sort out the whole system; including lab tests, material IDs, etc.
Welding procedures which have been accepted by one AIA, cannot be rejected by another AIA
unless there is a blatant stuff-up.
3.
Incident:
This incident has to do with NDT Company Validations and the question was asked where
Manufacturers can report NDT Companied to have their licenses reviewed / revoked. The answer to
this is the Department of Labor.
NDT Management needs to do regular surveillance on their workers. The ultimate responsibility
remains with the Manufacturer sub-contracting the NDT company.
7.2
Query:
What are the official Hard Stamping requirements for locally manufactured equipment under the
supervision of an AIA?
PER xxx, no more DOL xxx.
ISO 3834:
STATEMENT:
No Manufacturer certified by the SAIW can be classified as an ISO 3834 Certified Manufacturer.
Refer to SANS 347, Paragraph 3.1.5; quality system for production, final inspection and testing, that is
certified by an approved certification body
The SAIW is not a Certified Body. They are not accredited as a Certified Body; they only have personnel
accreditation in accordance with ISO 17024.
The question was raised with regards to Temporary Certification granted to the SAIW by SANAS. Linda
mentioned that SANAS will not issue temporary certification, but shall confirm.
With reference to Annex C in SANS 347, no Manufacturer in South Africa can really operate to ASME.
Any equipment manufactured in South Africa shall be assessed to the left side of table 2 in SANS 347 for
Manufacturers without a certified quality system;
Currently the SAIW is ready to be certified, but should still be audited by SANAS.
ACTION: Follow up with the SAIW, as well as the D.O.L on the Temporary Accreditation status of the SAIW.
QUESTION: What about ISO 9000; does that apply?
Refer to SANS 347, paragraph 7.1.9 for a list of Acceptable Quality Standards. Mandatory requirements are
set out in paragraph 7.1.
CONCLUSION:
AIAs certifying pressure equipment without a Manufacturers Quality System in place, is breaking the Law.
What about Importers taking on the liability of the Manufacturer? The regulations / standards are
not clear on this regarding the quality system.
7.4
7.5
7.6
7.7
8.2
General:
SANS 347 Sub-Committee Meeting:
9.
8.3
Treasurers Feedback:
As of end of October 2013, there was a total balance of R 70 076-97 in the bank. From the 41 AIAs
subscribed to the AIA Technical Forum, only 35 have paid their annual subscription fee for 2013. The
following six AIAs annual fees are still outstanding;
Guild, Moore & Hilder cc
Petro SA [x2]
Sapref
TV Africa (Pty) Ltd.
Innermost Inspection cc
Tue & MI (Pty) Ltd.
Discussions followed and Petro SA requested a valid SARS letter in order to make payment.
ACTION: Gideon will be redistributing the invoices of the outstanding payments as a reminder to the relative
parties involved.
8.4
Industry Opportunity:
Herman mentioned that Stein-Muller will be doing some Explosive Welding in January. Anyone that is
interested in learning more about this or having a look at how it is done, can contact Herman.
Summary & Close-Out:
Next Meeting is scheduled for 31 January 2014 @ 10h30 in CT Venue TBC
13h30
Paulo Pereira