AIA Technical Forum

Meeting # 4 - 2013
DATE:
TIME:
VENUE:

21-November-2013
10h30
SAIW, Main Reef Road, Johannesburg

CHAIR PERSON:
SECRETARY:
ATTENDEES:
DISTRIBUTION:

Paulo Pereira
Marlize Koekemoer
As per signed Attendance Register
As per attached Register

AGENDA TOPICS:
#:
Discussion:
1.

Welcome by the Chairman:

Paulo welcomed all present to the last AIA Technical Forum Meeting of 2013. There are four of these
meetings scheduled per annum; two of which focuses on Technical Issues within the Industry.

2.

Re-Certification Process of Pressure Equipment:

The most frequently asked questions when it comes to Re-Certifications are the following;
i.
When is it necessary?
ii.
What needs to be done exactly?
iii.
Which rules have to be followed?
iv.
What documents needs to be produced?
When referencing back to Annex C the old SABS 0227 document, the following is stipulated;
The inspection authority shall develop and maintain procedures for recertification of vessels under pressure.
These procedures shall, at least, ensure that there is a drawing, drawn by a draughtsman, that shows
a) The dimensions of the vessel,
b) The head shape with the crown and knuckle radii correctly indicated,
c) The flange positions,
d) The dimensions and orientation of the nozzles,
e) The minimum measured thicknesses of the pressure components, and
f) The gasket sizes and material.
Besides the mandatory recertification of vessels under pressure, such a vessel shall be recertified when
a) The vessel has to be rerated to operate at a higher or different duty,
b) The nameplate or permanent vessel data has been lost, or
c) The vessel has been imported and does not meet the requirements of either the Occupational Health
and Safety Act (see 3.1.2) or the Minerals Act (see 3.1.2).
The task assumes that no design information is available. If a certified-as-built drawing is available,
information can be taken from the drawing.

However, reference to the latest SANS 10227, reveals the following definition;
Re-Certification = Certification of previously certified equipment where the required traceability (to the
applicable statutory regulations and supporting documentation) is no longer available.
With regards to the PER Guidance Notes of March 2013 [ Revision 1], it is quite clear in note (c) as to when
the option of re-certification is available. Thus Vessels, which had initially been incorrectly certified as a nonPV, cannot now be reverse-engineered and recertified to become a PV.

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Meeting # 4 - 2013
What about Modifications? Refer to Guidance Notes (f) & (g) under Regulation 2 of the PER;
Pressure Equipment that were regulated under VUP may be repaired and modified under the rules of the
VUP.
Existing equipment that was not regulated under VUP but could now fall within the scope of the PER does not
need to comply to PER provided that a modification will not classify the vessel as a vessel under pressure ( as
defined in the VUP) according to the Vessel Under Pressure Regulations. If the vessel is now classified as a
vessel under pressure (as defined in the VUP) after the modification, the vessel needs to comply to the PER
requirements.
CONCENSUS: In reality, non-certified vessels are being re-certified even though in accordance with
legislation, this is NOT allowed. Furthermore, the Guidance Document is a legal requirement and all AIAs
shall abide by these rules.
Upon inquiry about this shall be communicated to the whole of industry to abide by, it was noted that the
minutes of these meetings shall be uploaded onto the AIA Technical Forum Webpage which will be
accessible to all of Public to see.
Coming back to the topic of Back-Engineering, the question was raised whether this is regarded as a safe
option, or whether it could cause unnecessary risk?
Luckily, the majority of equipment identified for re-certification are relatively small and it is found to be
more economical to replace these than to re-certify them.
Under the new regulations which should be released within the new year, Re-rates shall be addressed in the
same manner; irrelevant of whether the equipment is being Up- or Down-Rated. If the equipments wall
measurements are of the same thickness, this shall purely be a paper exercise. Should the wall thickness be
thinner, the pressure should also be decreased.
With reference to the Vessels Under Pressure Regulations, only Repairs and Modifications can be conducted
under the initial regulations; i.e. VUP.
Any new or additional testing shall be done in accordance with the PER Take Note of the reference to the
DESIGN PRESSURE, not MPOP.!
Example;
Existing equipment with the following parameters;
MPOP = 22 Bar & Pd = 30 Bar
Thus, the routine pressure test shall be done in accordance with the regulations, which stipulates 1.25x Pd.
The only exemptions on this rule, is listed in Regulations 2.2;
Regulations 3, 4, 5, 9(1), 9(2) and 9(3) shall not apply to pressure equipment in use or on order prior to the
publication of these Regulations, which equipment shall be designed and constructed according to the
requirements applicable at the time of order.
Regulation 2, Note (g) of the PER stipulates the following;
Existing equipment that was not regulated under the VUP, but could now fall within the scope of the PER
does not need to comply to the PER provided that a modification will not classify the vessel as a vessel under
pressure (as defined in the VUP) according to the Vessel Under Pressure Regulations. If the vessel is now
classified as a vessel under pressure (as defined in the VUP) after the modification, the vessel needs to comply
to the PER requirements.

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Meeting # 4 - 2013
CONCLUSION: The question was raised whether we now accept the any vessel in accordance with Annex C
of SABS 0227 and whether this is acceptable in accordance with the current Health & Safety standard?
With reference to the previous legislation, it was acceptable to follow the process in SABS 0227, Annex C,
st
paragraph 3.1. The current 21 century methods have advanced significantly, which makes it much easier to
determine the exact materials used to construct the vessel without damaging / destroying the vessel.
QUESTION: What about Serial Production.? Do we go the route of Type-Approval?
There was a consensus within the room that this is an easy escape route and needs to be addressed clearly
in the notes.
SUGGESTION: Refer to API 510, paragraph 7, which could be used as a good guide to re-certify equipment.
Based on the outcome of the above the Guidelines might be updated / adjusted if the API 510 method is
found acceptable.
The question was raised; Who is ultimately responsible for the Re-Certification of Pressure Equipment?
SANS 10227:2007 lists the AIA as the responsible entity; however SANS 10227 is not the Regulations. We
have to reference the Law; what does the Law say?
The law allows procedures to be followed, but wholl ultimately take the liability for this equipment? Should
it be the AIA?
Regulation 9(6) stipulates;
The user shall ensure that a data plate is affixed to any steam generator or pressure vessel that has been recertified; Provided that where the manufacturer is unknown, the user responsible for the re-certification shall
be deemed to be the manufacturer.
CONCLUSION:
1. Vessels which have not been originally certified cannot be re-certified.
2. Equipment that are in use, but without any traceability can be re-certified.
3. New equipment which have not met minimum legal requirements and have never been in use,
CANNOT be corrected by means of re-certification.
ACTIONS:
1. Evaluated additional definitions to include in Rev. 02.
2. Look into the following;
a. What about superseded design codes? Recertify in accordance with new codes and PER.
b. Certified equipment Hard-stamp detail / key data on the nameplate directly onto
equipment as well.
c. What about Code requirements regarding the affixing of nameplates onto pressure
equipment?

3.

RSA Conformity Assessments Review Process for Pressure Accessories:

i. Everyone around the room gave general feedback with regards to the previous discussion on pressure
equipment specifically. The main concern seems to be the materials. What about pressure accessories?
SANS 347, Paragraph 4.3.2 governs and stipulates full compliance with Code requirements;
Pressure Accessories
Figures 1 to 4 for vessels or figures 6 to 9 for piping are applicable depending on whether the volume (V)
or the nominal size (DN) is appropriate for classification of the pressure accessory. Where both the
volume and the nominal size are appropriate, the pressure accessory shall be classified in the higher
category.
Piping components need not be defined as pressure accessories when purchased and certified in

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Meeting # 4 - 2013
accordance with a referenced standard listed in the applicable health and safety standard(s). The
manufacturer of the equipment that uses the piping components shall remain liable for their integrity.
Examples would include standard valves that comply with ASME B16.34 or API 600 when used in piping
in accordance with ASME B31.3.
CONCLUSION:
a. Piping Components from Europe does not need to undergo a Conformity Assessment
b. Standard / Off-the-shelf items which are fully compliant and certified without any deviation from
the referenced standard do not have to be assessed.
c. If there is any deviation, it results in the item no longer being a standard item it has been
customised. Thus, this equipment shall undergo an RSA Conformity Assessment.
ii. The main reason for including this topic into the agenda is the ignorance of the importers. We, as the
AIAs, need to ensure that our clients and the local guys are aware of the requirements. In the recent
past, there have been several instances. Well touch on only two here;
a. U-stamp equipment with AI signature; however the AI were not a registered / certified
Authorized Inspector.
b. CE-marked equipment with Notified Body involvement from the Czechoslovakian country. The
NoBo was not accredited for the services rendered.
CONCLUSION:
Ultimately, the Importer is responsible to verify the Accreditation of the independent bodies involved
during fabrication. The local AIA shall review the importers assessment and ensure that the
accreditation is valid.
There are AIAs locally operating outside their own scope of accreditation. This is not acceptable.
Revision 1 of the Guidelines lists the 9 steps of the importer.
4.

EN 10204 3.2 and Re-Certification of Metallic Products on EN 10204 3.2:

This is with reference to existing materials. When a raw billet is reworked and tested it is seen as recertified
from 3.1 to 3.2 certification.
nd

rd

Materials cannot be recertified by a 2 or 3 party. When a material is moved from Iscor to a forge shop for
example, wholl be classified as the Manufacturer? Will it be the initial fabricator of the material or the forge
shop?
nd

The raw materials are supplied with a 3.1 certification which is only product analysis. The 2 party, in this
case scenario the forge shop, who reworks and recertifies the material shall be the responsible
manufacturer for the 3.2 certified items.
Reference was made to SANS 31, paragraph 4.2 definition of a Manufacturer. Here, it is stipulated that the
manufacturer of the product in accordance to the requirements to order is the responsible party. Thus, the
manufacturer of the forging is responsible for the material with 3.2 certification.
Robyn referred to a recent SANAS Audit finding with regards to a material mill certificate form RUKKI.
Beware when there is no stipulation with regards to mechanical or chemical requirements.
Based on the above, the following scenario was sketched; if we have a whole batch of billets of which the 3.1
certification is available, is it allowed to destroy and test one of the billets in order to recertify the material
to 3.2 certified material? The answer; YES.
SUGGESTION: Write an internal procedure with the maximum verification requirements.

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Meeting # 4 - 2013
ACTION: Circulate warnings against questionable equipment and material to the rest of industry when you
come across it.
QUESTION: Who is responsible for making out the 3.2 Certification.??
When material has been tested with a WIKA guage, it is acceptable that a 3.1 certificate is issued. However,
when no additional manufacturing took place, or no manufacturer was involved in the process, 3.2certification cannot be completed.
BS EN ISO 10474 creates more confusion in this regard. It is suggested that we refer to the EN 10204
accountability description; the Manufacturing company cannot issue 3.2 certification, the AIA should. Even
though EN 10204 is not a legal regulation, it is a referenced standard.
With regards to imported equipment, please note that 3.2 certification is not an AIA function when it comes
to materials used abroad.
In a lot of cases it comes down to word-playing, for example;
1. Only the D.O.L can issue exemptions [when the deviations are outside the Code boundaries]. The
AIA are only allowed to issue dispensations [when the deviations are still within the boundaries of
the Code].
2. Only the Manufacturers Design Engineer can APPROVE a design; the AIA design verification
engineer only REVIEWS, PERUSE or VERIFIES the design.
SANS 10227 is quoted in the accreditation schedule and sets out typical procedures to be followed.
ACTION: Assess this in the next SANS 347 Technical Committee meeting; work should be done in accordance
with SANS 347Assessment Modules.

5.

Delay in Inspection Intervals:

The question was raised whether it is acceptable to delay the statutory inspection intervals of pressure
equipment to beyond 36 months. The answer;
1. NO, it is not permitted.
2. It should rather be done sooner than 36 months if at all possible.
3. If the 36 months are extended, the maximum time which shall be allowed to lapse after the 36
month cut-off, is 3 months. When an additional 3 months have expired, all work shall be stopped
and the equipment inspected. Take note that this 3 month grace period shall only be granted ONCE,
provided the User have the relevant provisions in place.
Refer to PER 11(1)(d) Note (f);
The intent of sub-regulation 11(1)(d) is to provide two routes for extension of in-service inspections for
equipment not subject to deterioration processes: For deterioration mechanisms resulting in predictable
material loss only, the extension may be granted based on proven history to maximum of 9 years (the
corrosion allowance may not be consumed within 20 years); and for all other deterioration mechanisms
Regulation 12 applies. This extension may not be granted by the in-service inspection authority.
For Category I vessels, the User can do their own statutory inspections, but it shall still be done on a 3-yearly
interval. This 36 month interval cannot be altered.
What about RBI; some Users have this in place.? In these cases, the old frequency lapses. Refer to the
Guidance Notes.

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Meeting # 4 - 2013
6.

AIA Website Content:

The Design and Layout of the Web-page is now complete and only needs to be populated. Typical
information which shall be available on the page shall include Minutes of Meetings, Forum [members will
gain access via a login code and password] and distribution channels.
Netwise have been paid in full and the webpage should go Live before the end of 2013. Please make relevant
contributions and participate in building the webpage as soon as it goes Live.
SUGGESTION: Make this an interactive space where members can contribute and list typical topics which
needs to be discussed in meetings, etc.
ACTION: Paulo to issue the web-address to all parties on this Forum.

7.
7.1

Other Technical Issues:

PEMA:
The following Incidents, Queries and Questions were discussed;
1.

Incident:
Equipment was released to Site without the AIAs stamp, which was withheld because of
commercial issues. In this particular incident, the AIA was appointed by the End-User and not the
Manufacturer.
SANAS should verify the licence of the company. Also take note that IPEs are bound by a Code of
Ethics which should be adhered to at all times. This means that an IPE should not let Commercial
issues interfere with the Certification of Equipment.

2.

Query:
If a Laboratory is ISO 17025 Accredited, why does the AIA need to be present during mechanical /
tensile testing.?
SANS 347, paragraph 6.7.1.2.5; To carry out these approvals the third party shall perform
examinations and tests as set out in the appropriate health and safety standard(s).
In South Africa however, the AIA do not perform the tests themselves, but needs to witness them.
Thus, they have to be present.
Guidance Note (b) of Regulation 11 in the Act stipulates; witnessed inspections and tests, means
that the person performing the inspection is present during the pressure test required by subregulation and performs the internal and external inspections.
Questions:
What value is added to have the IPE present during the test? The inspector is there in a verifying
capacity.
But, Why are the Labs accredited then? It all comes down to independent verification and quality.
Take note that this is also a PED Requirement, and was adopted directly. Furthermore, it is normally
also a Client requirement, which means that the costs shall be allocate towards the Client and not
the Lab.
Linda suggested that we investigate the actual circumstances. As stipulated in SANS 347, para.
6.7.1.2.5, refer back to the Health and Safety standard. [Or also PED Guideline 6.1]
ACTION: Clarify the actual requirements for various inspection activities based on the Certification
to a Quality System. Sort out the whole system; including lab tests, material IDs, etc.
Welding procedures which have been accepted by one AIA, cannot be rejected by another AIA
unless there is a blatant stuff-up.

3.

Incident:
This incident has to do with NDT Company Validations and the question was asked where
Manufacturers can report NDT Companied to have their licenses reviewed / revoked. The answer to
this is the Department of Labor.
NDT Management needs to do regular surveillance on their workers. The ultimate responsibility
remains with the Manufacturer sub-contracting the NDT company.

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Meeting # 4 - 2013
4.

7.2

Query:
What are the official Hard Stamping requirements for locally manufactured equipment under the
supervision of an AIA?
PER xxx, no more DOL xxx.

ISO 3834:
STATEMENT:
No Manufacturer certified by the SAIW can be classified as an ISO 3834 Certified Manufacturer.
Refer to SANS 347, Paragraph 3.1.5; quality system for production, final inspection and testing, that is
certified by an approved certification body
The SAIW is not a Certified Body. They are not accredited as a Certified Body; they only have personnel
accreditation in accordance with ISO 17024.
The question was raised with regards to Temporary Certification granted to the SAIW by SANAS. Linda
mentioned that SANAS will not issue temporary certification, but shall confirm.
With reference to Annex C in SANS 347, no Manufacturer in South Africa can really operate to ASME.
Any equipment manufactured in South Africa shall be assessed to the left side of table 2 in SANS 347 for
Manufacturers without a certified quality system;

Currently the SAIW is ready to be certified, but should still be audited by SANAS.
ACTION: Follow up with the SAIW, as well as the D.O.L on the Temporary Accreditation status of the SAIW.
QUESTION: What about ISO 9000; does that apply?
Refer to SANS 347, paragraph 7.1.9 for a list of Acceptable Quality Standards. Mandatory requirements are
set out in paragraph 7.1.
CONCLUSION:
AIAs certifying pressure equipment without a Manufacturers Quality System in place, is breaking the Law.

What about Importers taking on the liability of the Manufacturer? The regulations / standards are
not clear on this regarding the quality system.

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Meeting # 4 - 2013
7.3

Safety Relief Valves:

The question was raised regarding the official requirements when it comes to Relief Valves. What data
should be checked by the AIA?
The AIA do not need to see anything or see any additional Data. The only thing that should be verified by the
AIA is that there is a RV present and that the set pressure is correct and makes sense with regards to the
equipments design pressure.
Any other checks are the responsibility of the User. The IPE also do not need to witness the popping of the
valve.

7.4

PER / D.o.L. Letters:

Six AIAs have not yet received their DOL Certificates even though they have applied for it. A suggestion was
made that when you apply, request that the DOL email you a copy as well in addition to the hardcopy being
posted.
If you keep the DOL Application aligned with your SANAS Application, it is a once off exercise.

7.5

Minerals Act vs. SANS 347:

An enquiry with regards to whether the PER is applicable to the Minerals Act and which procedures should
be followed for Pressure / Routine tests for mining equipment was raised.
Currently the Mining guys are doing their own thing and incorporate the PER requirements as and when they
wish to do so. A mail has been sent to Anthony, with no feedback to date. JP suggested that hell contact
Anthony via his secretary and set up an official meeting to discuss the above.
Based on the current Minerals Act, it is the responsibility of the Mine Engineer to decide whether they wish
to incorporate / follow the PER requirements for both New Fabrications, as well as Imported Equipment.

7.6

Materials / Material Traceability:

Material traceability remains the responsibility of the AIA / Manufacturer. See SANS 347, para. 6.7.1.4;
Suitable procedures shall be established and maintained for identifying the material making up the
components of the equipment which contribute to pressure resistance by suitable means from receipt,
through production, up to the final test of the manufactured pressure equipment.
Certification has to be done by the IPE Refer SANS 347, para. 5.13.4 (b);
The AIA shall examine the design and construction of each item of pressure equipment and during
manufacture and perform appropriate tests, to ensure its compliance with the requirements of the applicable
code of construction.
In particular the AIA shall
(b) assess the materials used where these are not in conformity with the applicable health and safety
standards, and check the certificate issued by the material manufacturer in accordance with the applicable
code of construction;
TAKE NOTE of the differences between Legal Requirements and Client Requirements.

7.7

Valve Manufacturers and PED Certification:

If valves are being exported, they should comply with PED requirements. Valves fabricated locally for local
industry, shall conform to PER requirements. Refer back to the June Meeting Minutes, as well as the
applicable Health and Safety standard for the applicable requirements.
ACTION: Discuss at the next PER Meeting and set up a meeting with the Valve Manufacturers.

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Meeting # 4 - 2013
8.
8.1

8.2

General:
SANS 347 Sub-Committee Meeting:

AIA Technical Forum Meeting Dates for 2014:

Proposed dates for the 2014 meetings are as followed;
Friday, 31 January 2014 @ 10h30 in Cape Town
Wednesday, 21 May 2014 @ 10h30 in JHB [Followed by the PER Meeting]
Friday, 08 August 2014 @ 10h30 in KZN
Wednesday, 26 November 2014 @ 10h30 in JHB [Followed by the PER Meeting]
Please note that the above dates are still subject to change. Venues shall be confirmed. JHB venues shall
probably be moved closer to OR Thambo.

9.

8.3

Treasurers Feedback:
As of end of October 2013, there was a total balance of R 70 076-97 in the bank. From the 41 AIAs
subscribed to the AIA Technical Forum, only 35 have paid their annual subscription fee for 2013. The
following six AIAs annual fees are still outstanding;
Guild, Moore & Hilder cc
Petro SA [x2]
Sapref
TV Africa (Pty) Ltd.
Innermost Inspection cc
Tue & MI (Pty) Ltd.
Discussions followed and Petro SA requested a valid SARS letter in order to make payment.
ACTION: Gideon will be redistributing the invoices of the outstanding payments as a reminder to the relative
parties involved.

8.4

Industry Opportunity:
Herman mentioned that Stein-Muller will be doing some Explosive Welding in January. Anyone that is
interested in learning more about this or having a look at how it is done, can contact Herman.
Summary & Close-Out:
Next Meeting is scheduled for 31 January 2014 @ 10h30 in CT Venue TBC
13h30

Minutes Approved by:

Paulo Pereira