Process of certification against the requirements of Annex C of ARP Roelof Viljoen Mining And Surface Certification CC

Transcription

1 Process of certification against the requirements of Annex C of ARP 0108 Roelof Viljoen Mining And Surface Certification CC 1

2 Scope of presentation: Process of certification against the requirements of Annex C of ARP 0108 Requirements, Complications and frequently asked questions / misconceptions / challenges. In practice 2

3 ARP 0108 Recommended practice / Aanbevole praktyk = ARP BUT Compulsory Published in March

4 ARP 0108:2007 Edition 1.1 Recommended practice Regulatory requirements for explosion protected apparatus 4

5 IMPORTANT DEFINITIONS approved test laboratory (ATL) test laboratory that is accredited by the government-endorsed South African accreditation body (SANAS) and appointed by the approving authority to carry out tests specified in the appropriate standards and to issue certificates (known as IA certificates) for explosion-protected apparatus indicating that such apparatus complies with safety requirements and any other requirements of the approving authority approving authority body legally responsible for the relevant national statutory legislation (see foreword) 5

6 IMPORTANT DEFINITIONS product certification scheme scheme that aims to ensure that a product covered under the scheme and that bears the certification mark of the scheme complies with the defined standard or standards, by using control elements such as surveillance audits and production sample assessments 6

7 7

8 8

9 9

10 10

11 IMPORTANT DEFINITIONS IA Certificate national certificate issued for EPA by an ATL endorsing conformance with the relevant national standards NOTE IA certificates apply to both surface (Group II) and mining (Group I) applications certificate holder organization identified on an IA certificate as the manufacturer or supplier of the certified equipment 11

12 IMPORTANT DEFINITIONS repair action to restore a faulty apparatus to its fully serviceable condition and in compliance with the relevant standard. NOTE 1 The relevant standard means the explosion protection standard to which the apparatus was originally designed or a more recent version. NOTE 2 Minor repairs carried out on the user s premises by maintenance staff are considered to be maintenance repairer Either a company that is certified under an approved product certification scheme to repair or overhaul specific EPA or a company that submits repaired products for batch testing NOTE An OEM may also be a repairer. 12

13 Annex A (normative) Approved standards, test laboratories and certification bodies for EPA 13

14 ARP 0108 :2007 Ed 1.1 Annex A Cont. A.1 From the date of publication of this recommended practice (plus a six month phase-in period), all new EPA requires a certificate issued by an ATL. Such certification will normally be based on approved national standards (refer to column 2 of table A.1). However, certification in terms of the standards listed in column 3 of table A.1 may be used as the basis for issuing such a certificate (IA certificate). No local testing will be required on equipment certified in terms of column 3, on condition that the ATL is provided with adequate evidence of recognized prior testing which demonstrates compliance with the applicable approved national standard. NOTE 1 The SANAS website can be consulted for a list of current ATLs and their respective scopes of accreditation. Some ATLs also have SANAS accreditation for testing to EN series standards. 14

15 ARP 0108 :2007 Ed 1.1 Annex A Cont. A.2 This requirement does not apply to equipment purchased prior to the date of publication of this recommended practice. (Refer to previous editions of this document and SANS for previous certification requirements). 15

16 ARP 0108 :2007 Ed 1.1 Annex A Cont. Table A.1 Approved standards, test laboratories and certification bodies for EPA Type of apparatus Approved Standards Other Standards Intrinsically safe electrical (Ex i) SANS IEC SANS (system) SABS 549 a -- IEC (system) SANS IEC EN EN UL FM CSA C22.2 No. 157 Double-protected electrical SANS (group II) EN

17 ARP 0108 :2007 Ed 1.1 Annex A Cont. Table A.1 Cont Type of apparatus Approved Standards Other Standards Flameproof electrical (Ex d) SANS IEC SABS a -- SABS a EN UL CSA C22.2 No AS Pressurized electrical (Ex p) SANS IEC SANS IEC SANS IEC EN NFPA 496 Encapsulated electrical (Ex m) SANS IEC EN

18 ARP 0108 :2007 Ed 1.1 Annex A Cont. Table A.1 Cont Type of apparatus Approved Standards Other Standards Sand-filled electrical or powder-filled electrical (Ex q) Specially protected electrical (Ex s) SANS IEC EN Any approved standard (see 3.1.3) Increased safety electrical (Ex e) SANS IEC Any approved standard (see 3.1.3) SABS 1031 a EN Oil immersed electrical (Ex o) b SANS IEC Type n electrical (Ex na, Ex nr, Ex nl, Ex nc) -- EN SANS IEC SANS 970 a EN FM 3611 a This standard might have been withdrawn, but it has been included because equipment may still be manufactured to this standard during the validity period of the equipment certification (see annex C). b Ex o apparatus is not permitted in Group I locations. 18

19 ARP 0108 :2007 Ed 1.1 Annex A Cont. Table A.1 Cont Type of apparatus Approved Standards Other Standards Protected by enclosure td (previously dust ignition- protected or proof (DIP)) SANS a IEC a SANS IEC SABS 969 a -- EN UL 1203 CSA C22.2 No. 25 Intrinsically safe electrical (Ex id) SANS IEC EN Pressurized electrical (Ex pd) SANS IEC EN Encapsulated electrical (Ex md) SANS IEC EN

20 ARP 0108 :2007 Ed 1.1 Annex A Cont. Table A.1 Cont Type of apparatus Approved Standards Other Standards Specialized: Machines powered by compression-ignition engines SANS , SANS , SANS (all for Group I machines) SANS , SANS , SANS (all for Group II machines) SANS (vehicles for use in nonhazardous locations in underground mines) -- AS 3584 (Group I machines) SANS a, SANS a (all for Group I machines) SANS 1142 a (Group II machines) -- D.C. mining machines SANS Mains-powered electrical mining machines SANS (applicable sections)

21 ARP 0108 :2007 Ed 1.1 Annex A Cont. Table A.1 Cont Type of apparatus Approved Standards Other Standards Cable glands SANS (Ex e) IEC (Ex e) Plugs and sockets, couplers and adaptors Helmet light assemblies Gas measuring equipment for mines -- EN (Ex e) SANS (Ex d) IEC (Ex d) -- EN (Ex d) SANS a, SANS IEC SANS 808 (Ex d) -- SANS 1213 (only the section on Ex e glands) SANS 1489 (Group I, 200 A, 300 A, 425 A ) BS 5620 a (Group I, 200 A) -- AS 1299 (Group I, 200 A, 300 A) SANS 1438 (Group I) -- SANS , SANS

22 ARP 0108 :2007 Ed 1.1 Annex A Cont. Table A.1 Cont Type of apparatus Approved Standards Other Standards Fuel dispensers and metering pumps Ingress protected (IP) enclosures SANS UL 87 SANS IEC EN NOTE 1 NOTE 2 NOTE 3 a More information with regard to Group II double-protected explosion-protected apparatus is given in IEC , and IEC TC 31 is preparing work on a standard for Group I double-protected explosionprotected apparatus, which will be considered for approval and inclusion in this annex once available. Owing to rapid developments in the field of explosion-protected apparatus, the information in this table is subject to change. The reader should be in possession of the latest edition of this recommended practice. The relevant test laboratories should be approached for approval of apparatus not covered by this table. Although this table is applicable to all explosion-protected apparatus, it is often acceptable to repair apparatus already in service to its original standard, even if such a standard is no longer valid, as long as safety is not jeopardized. In cases of doubt, the relevant approving authority should be consulted (also see annex C). This standard might have been withdrawn, but it has been included because equipment may still be manufactured to this standard during the validity period of the equipment certification (see annex C). 22

23 Annex B (informative) Marking of electrical apparatus for use in hazardous locations 23

24 ARP 0108 :2007 Ed 1.1 Annex B Cont. B.6 Approved certification bodies and their certification marks Most approved certification bodies use a certification mark that indicates unambiguously, or in conjunction with other symbols, that the apparatus is certified as explosion protected. The following certification marks are commonly found on apparatus used in South Africa. B.6.1 South African certification marks a) CERTEX b) SABS Certification (Pty) Ltd c) SAEx d) Mining And Surface Certification CC 24

25 Annex C (normative) Upgrading and maintenance of EPA certificates for mines and factories 25

26 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.1 In South Africa, all EPA used in underground mines (Group I) and on surface (Group II) shall be covered by an IA certificate. The requirements in C.2 to C.15 cover the validity of IA certificates. Historic IA certificates required for mining / New for surface industry. C.2 All IA certificates issued shall have a validity period of 10 years. Where a product is in service and its certificate has expired it will not be affected. IA certificates based on overseas certification will be valid for a period of one year. Once bought / installed by the end user, its certification remains valid. Is not required to re-certify existing equipment. Requirement for manufacturer / agent of equipment. Requirement for certification should be the manufacturer s / agent and not the end user. Overseas certification...type tested and certified not by an ATL, but certificate used to obtain local certification. Annual review process required to keep on selling the equipment. End user to ensure he buys within the validity period on the certificate. Review process should be simple... Changes w.r.t. Quality system etc. 26

27 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.3 If, during a validity period or if the product is in service after its certificate has expired, the product is modified or changed to an extent that it requires re-evaluation, this shall be done by an ATL and recertified. This re-evaluation or re-certification (or both) shall take into account the current edition of the national standard used for certification and the complete product shall meet the requirements of that standard. Modification?? Definition / Examples Affecting the Ex characteristics, e.g. Drilling additional entry holes, new type of gasket on luminaires, changing a component on intrinsic safety etc. Current edition of the standard...??????? (still possible) Complete product...????? This can be problematic, e.g. Changing a type of fuse (modification) on intrinsically safe equipment, requires re-evaluation of the whole circuit? Adding an additional entry hole in Ex e or Ex d enclosure requires the whole unit to be evaluated against the latest standard? Abuse by end users / manufacturers also possible if not applied... E.g. A unit approved in 1980 s to very old standard can change under the old standard (Starting as a tree and ending an ostrich) Solution? 27

28 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.4 During the validity period of IA certificates the product can be manufactured or supplied either under the batch test method or under an approved product certification scheme irrespective of changes to the national standard, provided that the product does not change from the original certified design and that no unsafe condition that affects the products is identified in the original edition of the standard used for certification (see also B.7). Equipment can be sold as long as all is well with the certificate and standards used. A quality system must be in place for the equipment. NB. A certificate does not mean the quality system requirements have been met. Batch test report. Permit for the manufacturer. 28

29 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.5 Repairs and overhauls shall be carried out in such a way that they will not invalidate the IA certificate. Repairs and overhauls carried out by a party other than the certificate holder, where the repairer or over hauler is not in possession of the certification documents, shall be carried out in such a manner that the product meets the requirements of the applicable national standards to which the product was originally certified, or any more recent edition. Principles: Repair...Definition / example Not changing the original certification, e.g. Using a fuse of identical type as per original certification, Drilling a hole by a permit holder (to control the quality) if there was provision for additional holes in the original certification Skimming the face of a flameproof enclosure Changing bearings on a motor (or is this maintenance??) etc. No Certification documents... Difficulties Is it a modification or a repair... E.g. What was the original flamepaths that were tested... (0.2mm gap may have been tested, while 0.4mm gap is allowed by the standard... Risk?) Can modifications be slipped in without complying to the latest standard? 29

30 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.6 Should a product be modified or changed in such a way that it no longer complies with the certified design, it shall be re-submitted to anatl for re-evaluation. This re-evaluation shall take into account the current national standard and the product shall comply with that standard. This applies to newly manufactured as well as in-service products. C.7 Current IA certificates and GME certificates (previously known as V or VM numbers) a) issued before 1998 shall have a validity period of 5 years after the publication of ARP0108:2005 Edition 1 (i.e. valid until October 2010), and b) issued after 1998 shall have a validity period of 10 years after the publication of ARP0108:2005 Edition 1 (i.e. valid until October 2015). NewIA certificates shall have a validity period of 10 years from the date of issue. The date of issue and the date of expiry shall be stated on new certificates. 30

31 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.8 A product still in production shall be submitted for re-certification to an ATL before the IA certificate expires so as to achieve re-certification before the expiry date. The product will be re-assessed or tested (or both) and will be re-certified to the current edition of the national standard. Where the current edition of the national standard dictates that a product shall be upgraded or changed, the onus is on the manufacturer or supplier of the product to institute such upgrades or changes as to ensure that the product is compliant to the current national standard, as required for re-certification. C.9 Where a product with a valid IA certificate is found to be unsafe for use, the certificate holder shall take appropriate steps to rectify the design of such a product and re-certify such rectified products. Unsafe products already supplied shall be recalled and both the regulatory body and the ATL (and approved certification body for mark holders) that issued the certificate shall be notified. 31

32 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.10 In cases where any system safety parameter of an intrinsically safe apparatus is changed, consideration shall be given to the safety of the loops in which the apparatus is used, and such loops shall be re-certified. Significant concern raised by industry w.r.t. Recertification of i.s. Loops. There are easy ways of getting this done... Speak with your ATL. Certification vs. Approval of i.s. Loops. C.11 Where a standard is superseded during the validity period of a certificate, then such standard shall still be deemed to apply to the product for the validity period of the certificate. In terms of batch tested products, ATLs shall still be able to test to such standards while the certificates remain valid. The product sold within the certificate s validity period is not affected by later standard changes (unless unsafe) Product installed / bought by the end user are not affected unless modified. Batch testing is a quality assurance issue and therefore the original certification documents are used during this evaluation. 32

33 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.12 Certification that covers variations in product design, or covers a range of similar products, shall show, in the test report or IA certificate, that each variation or design has been considered and tested where deemed necessary, and each variation or design shall be clearly stated in the test report and IA certificate. Certification is not by inference. All types / models and design differences / options must be clearly stated. E.g. Using earpieces with intrinsic safety radios. Model Y flameproof enclosure (not in the certificate) is not automatically covered because it falls between X and Z (on the certificate). Model 1584BX is not automatically covered because 1584B is and there is just this small change but it is identical... 33

34 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.13 Any repairer shall attach to the product a durable, legible and noticeable label that gives at least the following information: a) the repairer s certificate number (when operating under an approved product certification mark scheme for Ex certified equipment), b) the IA certificate number, c) the name of the repairer, and d) the month and year of repair or overhaul. NOTE It is not intended that the need for a repair label be applicable to routine maintenance or replacement of identical parts. Method of label attachment should not invalidate Ex... Part of repair Mark scheme or evaluation by ATL. C.14 The label fitted by the original equipment manufacturer shall not be removed, but labels fitted by previous repairers shall be removed, except in cases where the repairer submits the finished product to an ATL and has the product fully tested to the national standards and a new IA certificate is issued in his name. In this case, only the repairer s plate shall be fitted. The repairer becomes the certificate holder and much more information than in C.13 may be required. 34

35 ARP 0108 :2007 Ed 1.1 Annex C Cont. C.15 All records related to manufacture, repair or overhaul of Ex certified apparatus shall be kept for a minimum period of 10 years by the product certificate holder. The repairer/atl must also maintain the records (Part of quality systems) End user?? NOTE The relevant responsible parties for the above are as follows: 1 2 Responsible Party Relevant Clause Manufacturer or Supplier C.1, C.2, C.4, C.6, C.7, C.8, C.9, C.10, C.15 Repairer C.3, C.5, C.6, C.9, C.10, C.13, C.14, C.15 User C.1, C.2, C.3, C.4, C.5, C.6, C.7, C.10 ATL C.1, C.2, C.11, C.12 35

36 Specific challenges Certification processes 36

37 Specific challenges SANAS Use of logos (Use on IA certificates / Traceability..overseas, recertification etc / SANAS rules / Regulators requirements) Annual re-certification (overseas certified product) Agent / supplier perspective: One year frequency?? Tedious / expensive / capacity of ATL s Competence of labs Content of certificates Submission requirements for process Rubber stamping? Multiple IA numbers for a single type of equipment E.g. Not only the OEM may submit a certificate for certification. Therefore, Barrier ABC may have an IA certificate from different ATL s on different sites / single sites. Who is the owner of the certf? (ATL or the certf holder? Or the OEM?) Who is responsible if something goes wrong? In service...definition...implications for certification. Importer carrying stock? In stores? 37

38 Specific challenges Package units, e.g. A skid or increased safety enclosure / flameproof enclosure with multiple separately certified components, e.g. Glands, switches, terminal blocks etc. Separate certification required? Can components (e.g. Glands) then be used on other products? Marking of units with the new IA number. Challenges. Advantages (SANS meeting 2011): Local accountability Sets yardstick for industry (set standard) consistency Poor quality and unsafe (uncertified) product Defendable by Regulator from risk point of view Reasonable cost to achieve affordable safety Improved quality supply/support certification documentation Local interpretation of international standards 38

39 Roelof Viljoen Mining And Surface Certification CC