By Barney Richardson
We are regularly asked, “why do I have to be registered?” The easy answer is: it is entrenched in the Law!
Barney Richardson is the ex-director of South African Refrigeration and Air Conditioning Contractors Association (SARACCA) and sits on various other boards within the HVAC industry, including the South African Qualifications and Certifications Committee for Gas (SAQCC) Gas. |
The extremely comprehensive Occupational Health and Safety ACT number 85 and Regulations originally published in 1993. The regulations, in particular, have been updated and changed over the years. The regulation that we are dealing with here is Regulation 17 of the Pressure Equipment Regulations which used to be called Vessels Under Pressure Regulation, prior to July 2009.
Regulation 17
- No person shall –
- Handle, store or distribute any gas in any manner, which includes the filling of a container, other than in accordance with the relevant health and safety standard incorporated into these Regulations under section 44 of the Act;
- Install or remove an appliance, pressure equipment or system for gas in any manner other than in accordance with the relevant safety standard incorporated into these Regulations under section 44 of the Act:
- Install or remove a gas appliance, or a gas system or a gas reticulation system, unless such person is an authorised person; or
- Use pressure equipment or systems for gas in any manner other than in accordance with the relevant safety standard incorporated into these Regulations under section 44 of the Act.
2. After installation or re-installation, and before commissioning a gas system, the user shall ensure that an external inspection and a leak test are performed by an authorised person or an approved inspection authority as applicable in terms of sub regulations (1) (c).
3. An authorised person or an approved inspection authority shall issue a certificate of conformity after completion of a gas installation, modification, alteration or change of user or ownership in the form of Annexure 1.
In 1(a) above, the interpretation for air conditioning and refrigeration systems is that a mechanic must be competent to safely recover and store refrigerant, and then to safely pressure test and recharge a system with refrigerant. Then in (b) (c) the person doing an installation, removal and for that matter repair or maintenance, must be deemed to be competent as an authorised person. An “authorised person” is defined as a person who is registered as competent within the scope of work for which an organisation – approved by the chief inspector – has registered that person. That organisation is SAQCC (Gas), and the registered gas practitioner is in the field of handling refrigeration gas.
The other question that is asked is, why clients and end users are asking for a CoC? Clause 3 of Regulation 17 clearly requires that a Certificate of Conformity be issued. For small installations that fall into the category of Sound Engineering Practice (SEP) or Category 1 in terms of SANS 347 for dangerous gas or liquid, the CoC can be signed by the installer or mechanic. Only a person registered as an Authorised Refrigerant gas Practitioner can sign a CoC. Systems with larger pressure vessels and piping that can be categorised as Category 2 and above in SANS 347 an Approved Inspection Authority must be involved in the issue of a certificate.
In the interpretation of the regulations, it is easy to see and understand why the Department of Labour Chief Inspector is adamant that compliance with the regulations is met. A person working on an air-conditioning or refrigeration system must be registered with SAQCC Gas in the appropriate category in which that person is qualified and assessed as competent to handle refrigerant gases.