By Barney Richardson
Last issue we touched on the responsibility of the user.
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Barney Richardson is the 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.
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Who is the user of refrigeration? This applies to the building owner where an air conditioning or refrigeration plant is installed. There are building owners who lease out their buildings or sections of the building, therefore there is now a new responsibility on both the owner and the tenant – who is the user.
In the Pressure Equipment Regulations, Regulation 6 details the duties of users. The user is required ensure that the equipment subject to the Regulations is operated and maintained within its design and operating specification. The identified equipment is the refrigeration portion of the installation, whether it is a room air-conditioning unit, water chiller or cold store plant where they are all operating at above 50kPa in terms of Regulation 2 (1). This places a responsibility on the engineer employed to carry out the design and supervision of the installation on behalf of a client, owner or user. Where the installation is based on a design and supply contract like most room unit installations are, the contractor and his registered practitioners have that responsibility.
The user/owner has to provide the manufacturer, contractor, repairer or maintenance mechanic with technical information of the operating conditions of the refrigeration or air-conditioning installation. In terms of the OH&S Act, the ‘employer’ who is in fact the owner/user of the plant is subject to the relevant health and safety standard incorporated into the Regulations under sections 43 and 44 of the Act.
The plant or installation size does not really matter until one looks at SANS 10147 and SANS 347. The size of the pressure vessels and piping are governed by the categorisation and conformity assessment in SANS 347. The responsibility for issuing a certificate of conformity (CoC) is dictated by the category the plant or equipment falls into. The tables in SANS 347 that are applicable are graph figures 1 and 3 for vessels, and graph figures 6 and 8 for piping with either a dangerous gas or dangerous liquid.
Sound engineering practice is equipment that is not subject to a conformity assessment but shall be designed and manufactured to best engineering practice to ensure safe use. As with all room air conditioning units and small refrigeration equipment, user and operation instruction information must be given to the owner.
Equipment with vessels and piping that falls into category 1 requires a CoC from the manufacturer confirming that the equipment is designed and manufactured to an applicable design, and health and safety codes.
In both the above cases the user must receive a CoC issued by the registered refrigeration gas practitioner after installation and after any maintenance or repair.
Air-conditioning and refrigeration equipment and plant that is categorised in category II and above needs to be approved by an appropriately registered professional to a health and safety standard and verified by an approved inspection authority. The manufacturers of equipment sourced from outside South Africa are required to provide approved certification also verified by an approved inspection authority.
The requirements of piping design for refrigeration are also given in SANS 347 annexure B. The user is required to keep records of the design and manufacture for the life of the installation. Water piping below its boiling point is excluded from the pressure equipment.
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