Certification in South Africa
Hazardous locations (Ex) certification is controlled in South Africa by two Regulators:
- Department of Labour (DOL) regulates all surface industry installations under the auspices of the Occupational Health and Safety Act (OHS Act) no 85 of 1993, and
- Department of Mineral Resources (DMR) regulates all mining activities under the auspices of the Mine Health and Safety Act no 29 of 1996.
Together with the acts and their accompanying regulations, other regulatory documents exist to control the Ex Industry (the standards listed below are controlled in the “regulations in terms of the Mine Health And Safety Act 29 of 1996; Chapter 10 Hazardous locations (p.143)” :
- SANS 10086-1:2013 - The installation, inspection and maintenance of equipment used in explosive atmospheres Part 1: Installations including surface installation on mines.
- SANS 10086-2:2013 - The installation, inspection and maintenance of equipment used in explosive atmospheres Part 2: Electrical equipment installed underground in mines
- SANS 10086-3:2018 - The installation, inspection and maintenance of equipment used in explosive atmospheres Part 3: Repair and overhaul of equipment
- ARP 0108:2018 – Guide to the regulatory requirements for explosion-protected Apparatus.
- SANS 10108: 2017- The classification of hazardous locations and the selection of equipment for use in such locations.
Testing and certification in South Africa is accredited by the South African National Accreditation System (SANAS):
- Testing laboratories are accredited under SANS 17025:2018 - General requirements for the competence of testing and calibration laboratories, and
- Certification Bodies are accredited under SANS 17065: 2012 - Conformity assessment — Requirements for bodies certifying products, processes and services.
Lastly, the Ex industry in South Africa has set up the South African Flameproof Association (SAFA), a non-profit body, who is an association of companies involved in explosion prevention/protection techniques for equipment used in hazardous atmospheres in industry and mining. The group comprises of interested parties in the Ex industry, including OEM’s, Regulators, testing bodies, etc. This association is used to guide the Ex Industry in South Africa and to liaise with and provide feedback from the IECEx.
The article below will detail how certification is conducted in South Africa and how it is influenced by the interested parties mentioned above.
SANAS was officially recognized as the sole accreditation body in South Africa in 2007, after the promulgation of the Accreditation of Conformity Assessment, Calibration and Good Laboratory Practice Act 19 of 2006. SANAS is also a signatory of the Mutual Recognition Agreement (MRA) as laid out between the IAF (International Accreditation Forum) and ILAC (International Laboratory Accreditation Cooperation).
A prospective test laboratory seeking to conduct testing and certification in South Africa needs to be appointed as an Approved Inspection Authority (AIA) by the DMR and the DOL. However, approval is predicated on accreditation from SANAS.
Assessments done by the DMR and DOL are conducted to confirm the current status of the SANAS accreditation of the laboratory according to the laboratory’s schedule of accreditation issued by SANAS. This schedule is freely available on the SANAS website for independent verification.
Further to the requirements of SANAS accreditation, the Regulators also places additional requirements on SANS 17025 laboratories in the APR 0108:2018. Annex J, of the ARP 0108:2018, provides a list of required tests the laboratory must be able to perform before the Regulator will provide approval to a laboratory as an AIA.
The Regulators also places additional requirements on SANS 17065 certification bodies (Markscheme Providers) in the ARP 0108:2018. Clause 5.4 states “A product certification scheme shall be operated by an approved certification body and shall be of an acceptable type.”
Approval is only granted to “a certification body with accreditation recognized by the International Accreditation Forum (IAF)”, i.e. SANAS. Currently, only half of the Markscheme providers in South Africa complies with this requirement.
All Ex standards in the SANS 60079 series are regulated by the DMR and DOL in Table B.1 of the ARP 0108:2018. Included in the regulations are Ex standards specifically created for the South African industry.
All type tested equipment used in the Ex industry must have an Inspection Authority Certificate (IA Certificate). This is typically issued by the Accredited Testing Laboratory (ATL) according to clause 5.2.c of the ARP 0108:2018.
The content of the certificate typically complies with clause 7.8 of SANS 17025: Reporting of results.
Certification in South Africa has certain key differences from international certification, e.g. IECEx or ATEX:
a) The first big difference between IECEx and local certification is, who issues the certification. Internationally, the Body that conducts the testing work and the Body that provides the product certificate, does not need to be the same Body.
In South Africa however, the ATL who does the testing is the same ATL who issues the IA Certificate.
b) Secondly; IA certificates issued in South Africa has a validity period of 10 years (Annex A.2 of ARP 0108:2018) after which, if the equipment is still in production, it will need to be re-certified.
Typically, ATEX and IECEx certificates does not have an expiry date as there is built-in mechanisms which requires the manufacturer of the equipment to regularly review certified equipment to ensure that they still comply to the current certification.
c) After a unit has been type tested, it must either be covered by a valid Markscheme permit or covered by a batch test report. Batch testing in South Africa is conducted according to SANS 96:2018 - Batch sampling and acceptance criteria for explosion-protected apparatus (EPA). This standard, which is regulated in the ARP 0108:2018, clause 5.3, allows for an ATL to draw samples from the batch to perform testing on.
Each time a new batch of equipment / product is manufactured, it is sent for batch testing. Once the equipment / product passes the batch test, the Type Test IA certificate number can be used on that batch of equipment. The Markscheme is optional for the continued manufacturing of the equipment.
This differs significantly from ATEX or IECEx where it is required to have a QAR (IECEx) or QAN (ATEX) for production units. (The QAR / QAN is equivalent to the Markscheme).
Batch testing can be conducted under the IECEx under strict requirements. Batch testing is known as unit verification. An IECEx Unit verification certificate can be issued for a defined number of items under a single production run. IECEx Unit Verification Certificates do not cover “future’ production runs.
d) Intrinsically safe systems (loops) shall be type approved according to SANS 60079-25 by an ATL. Typical loops may be installed under cover of the original type approval without recertification by an ATL.
FISCO systems complying with SANS 60079-11 and SANS 60079-25 also require ATL approval. (Clause 5.8 of ARP 0108:2018).
e) According to the Occupational Health and Safety Act 1993, Electrical Installation Regulations clause 9 paragraph 1: “No person other than a registered person may issue a certificate of compliance.” The registered person refers to a Master Installation Electrician (MIE). This is true for all surface installations, including Ex installations. This includes electrical installations in hazardous locations. Wiring is covered under the SANS 10142 series of standards for the wiring of premises.
f) If it is an enclosure which is certified, it can be certified either as unpopulated or populated. If it was certified as unpopulated, a separate population certificate shall be required. Should the population inside an already certified enclosure change, re-certification of the population shall be required.
g) Equipment repairs / re-certification is covered under IECEx OD 314-5, IECEx OD 315-5 and SANS 60079-19. Additionally, all repairs / re-certification shall comply to Annex A and Annex H of the ARP 0108:2018.
Depending on where the Ex equipment comes from, it is possible for imported equipment to be accepted in South Africa without re-testing, HOWEVER, this does not mean the equipment can be used as is. Imported equipment still needs to obtain an IA certificate from an ATL. This is typically referred to as a conversion.
Ex equipment certified by IECEx or ANZEx is accepted in South Africa without re-testing. The equipment documentation, with the original certificate and QAR / QAN, must be submitted to the ATL for review. Once the IA Certificate is issued, the applicant is required to mark the equipment with the IA number. The IA Certificate will be valid for three years.
For ATEX, all but Zone 2 equipment will be accepted without certification. Zone 2 ATEX equipment is not accepted and will have to be re-tested. This is due to the fact that under the ATEX Directive, Zone 2 equipment can be self-certified (clause 7.1.2. of the ARP 0108:2018).
All other imported equipment not certified by IECEx, ATEX or ANZEx, must be submitted to the ATL for certification.
Typically SANAS certification is accepted in neighbouring countries, e.g. Namibia and Botswana. This is due to the fact that standardization in Africa is limited, and often relies on the Entity seeking certification. In the Democratic Republic of Congo (DRC), certification depends on the country owning the facility. Countries, like Angola, accepts IECEx or ATEX as most companies operating out of Angola is European.
This creates a vast amount of certifications used in Africa and creates significant barriers to development between the counties. AFSEC (The African Electrotechnical Standardizations Commission) was created in 2008 to establish a forum to harmonize standardization in Africa, however, attendance is often poor and very few countries participates.
Under the Southern African Development Community, a program has also been developed to harmonize standardizations.
The Southern African Development Community Cooperation in Accreditation (SADCA), is a Regional Cooperation whose objective it is to coordinate accreditation activities in the region and facilitate the national, regional and international recognition and acceptance of SADC accreditation infrastructure. They also aim to provide member States with accreditation as a tool for facilitating trade and the protection of health and safety of the public and the environment, in both the voluntary and regulatory areas. SADCA comprises of three accreditation body members, namely the Mauritius Accreditation Service (MAURITAS), Southern African Development Community Accreditation Service (SADCAS) and the South African National Accreditation System (SANAS), with SADCAS being a multi economy accreditation body servicing thirteen out of the fifteen SADC Member States, whilst MAURITAS and SANAS service Mauritius and South Africa respectively. (ILAC Newsletter Issue 52 | October 2017)
Currently, only SANAS is a signatory to the ILAC MRA.
Countries affiliated with SADCAS are South Africa, Lesotho, Eswatini, Botswana, Namibia, Zimbabwe, Zambia, Malawi, Mozambique, Tanzania, Angola, DR Congo, Mauritius, Seychelles and Madagascar.
The Department of Labour requires the following for electrical machinery operated on surface:
(Clause 9.1 - Electrical Machinery Regulations of the OSH Act). Every employer or user shall identify all hazardous locations and classify them in accordance with the relevant Health and Safety standard incorporated into these Regulations under section 44 of the Act.
(Clause 9.3 - Electrical Machinery Regulations of the OSH Act). Every employer or user referred to in sub regulation (1) shall be in possession of a certificate in a form acceptable to the chief inspector, which has been issued by an Approved Inspection Authority and in which it is certified that the electrical machinery referred to in sub regulation (2) has been manufactured and tested for the groups of dangerous articles in accordance with the relevant Health and Safety standard incorporated into these Regulations under section 44 of the Act: Provided that in lieu of such certificate an inspector may approve permanent labelling on such machinery, which label shall contain all the relevant information.
According to the DMR all equipment used in explosive atmospheres shall be tested by an ATL (clause 5.6 of ARP 0108:2018), this includes electrical and diesel mining machines. All mining machines are issued with an IA Certificate (clause 5.2.c of the ARP 0108:2018). The IA Certificate issued for a mine machine assembly must include a list of installed equipment and their IA Certificate numbers (clause K.2 of the ARP 0108:2018). All Ex aspects are covered, including the certification of any Intrinsic Safety loops.
Diesel mining machines are certified according to SANS 868-1 series of standards (clause L.1 of the ARP 0108:2018). This is additional to the Ex certification (clause L.3 of the ARP 0108:2018). The Diesel system used on the machine is separately certified by the DMR, who issues a D certificate for the diesel system (clause L.3 of the ARP 0108:2018)
In addition to the certification of mining machines as stated above, all mining machines must be provided with proximity detection system (PDS) as per clause 8.10.1 of the Mine, Health and Safety Regulations. This PDS system must be able to either warn the machine operator when a pedestrian is walking close by, or must be able to switch off the mining machine operation. This PDS must be separately certified from the rest of the mining machines.
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