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Impact of the PER on SAQCC Competent Persons and a reminder of certification requirements, continuing professional development and ethical responsibilities. CT Branch February 2011. Changes in responsibilities for periodic inspection from VUP to PER. VUP Responsibility for periodic inspections.
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Impact of the PER on SAQCC Competent Persons and a reminder of certification requirements, continuing professional development and ethical responsibilities CT Branch February 2011
Changes in responsibilities for periodic inspection from VUP to PER
VUP 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 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 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 approval Requirements for appointment as an AIA-IS by Dept. of Labour 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 10227:2007 Criteria for the operation of inspection authorities performing inspection in terms of the Pressure Equipment Regulations
SANS 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!
SANS 10227 Requirements for an AIA-In Service 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
SANS 10227 Requirements for an AIA-In Service The AIA In-Service Personnel will need to comply with Table 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? SUMMARY SANS 10227 requirements are not ‘over the top’ and are 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 competencies associated with ‘traditional AIAs’ including a design evaluation
SANS 17020:1998 General criteria for the operation of various types of bodies performing inspection
SANS 17020 • Has been incorporated into SANS 10227 since 2007 • Until recently SANAS did not audit compliance with ISO 17020 as PER was not enacted
SANS 17020 Content • 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 Content (cont.) • Facilities and equipment • Inspection methods and procedures • Handling inspection samples and items • Records • Inspection reports and inspection certificates
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
SANS 17020 Content (cont.) • Complaints and Appeals • Co-operation (inspection body expected to share experiences with other inspection bodies)
ISO 17020 Requirements for AIA-IS approval? SUMMARY Compliance with ISO 17020 would be extremely demanding for an individual
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
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 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
SAQCC CP Certification Criteria Successful completion of approved training course • SAIW course and examination is approved by SAQCC CP
SAQCC CP Certification Criteria Supervised practical training • Minimum periods are applicable • Minimum number of vessels is applicable • Credits for educational and trade qualifications reduce training period
Changes to the SAQCC CP Certification scheme? 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
Changes to the SAQCC CP Certification scheme? Training course requirements have been changed significantly 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
Changes to the SAQCC CP Certification scheme? 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
New 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? • New course requirements came into effect from January • 2011 • 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? • All existing certifications will be retained • Renewals and recertification will be treated as they are currently
SAQCC 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
SAQCC CP Certification Rules Requirements for 3 year and 6 year renewals are the 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-certification As above plus there is also a requirement to pass an examination which will assess awareness of changes to regulations and codes
SAQCC CP Certification Rules 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
SAQCC CP Certification Rules 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
SAQCC CP Certification Rules 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
SAQCC CP Certification Rules Examples of semi-structured CPD activities • Further education studies not necessarily directly related to CP activities • Private study of relevant publications and journals
SAQCC CP Certification Rules 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
SAQCC CP Certification Rules 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
SAQCC CP Certification Rules • 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