Relationship between the OEM and the repair facility

Kagiso Malibe

9 May 2019

Introduction
There are numerous incidence reported frequently around the world and in South Africa regarding
fatalities lost due to explosion in hazardous area. For instance, in July 2018 there was fire and
explosion disaster that happen in Palabora Mining Company’s Copper mine in which six employees
lost their lives (Gov, 2019). One of the key factors to prevent explosions in hazardous areas is the
installation of Explosion-Protected Equipment (Ex equipment) effectively and maintaining the
equipment. Ex equipment are equipments designed and approved by an accredited laboratory for use
in explosive atmosphere in accordance with a suitable protection method (ARP0108, 2018).

However, it was noticed that during the maintenance of certified Ex equipment that protection method
of the equipment is invalidated. Although, there are regulation regarding such as the Occupational
Health and Safety Act 1993 and the Mine Health and Safety Act 1996 which requires that equipment
be certified and that the certification not be invalidated by repair operations. However, ensuring that
the regulations are implemented effectively is somewhat difficult to follow. At the moment most
repairs facilities that are not the original manufacturer will repair the equipment using the relevant
Standards SANS 60079 series as a reference alone and considers the repaired equipment to have
maintained the type of protection as per the Inspection Authority (IA) certificate.

The I.A certificate in most cases does not reveal valuable design applied on the equipment to ensure
that it complied with the requirements of the relevant Standard. It mostly consists of the general
description of the equipment, followed by the rating of the equipment and the equipment “condition of
use”. Where the special condition of use, are guides to ensure that the equipment is used in a
manner such that the protection method is maintained. Eventhough SANS 60079-0 forces the
manufacturer to prepare documentation in which it should include the following instructions, putting
the equipment into service, assembling and dismantling, maintenance, overhaul and repair,
installation and us amongst other documents (SANS60079-19, 2007). Such documentation are never
received by the end user of the equipment or the repair facility.

It will be noted that in the contest of this paper the word ‘maintenance’ describes any repair,
overhauling or reclamation done on equipments. This paper will look at the current process of
ensuring that the repaired equipment is still covered by the I.A certificate. Also noting conflict between
repair facilities that is not the original equipment manufacturer does repairs on equipment.

Repair process Overview

There are two types of repair facility, namely Original Equipment Manufacturer and certified repair
facilities capable of conducting repairs on equipments. The certified repair facilities operates a quality
system that meets the requirements of ISO 9000 series of standards (SANS60079-19, 2007).
Additionally, the repair facility needs to be certified under an approved product certification (Mark)
Scheme or should submit the repaired products for batch testing to a laboratory that is accredited for
that particular method (ARP0108, 2018).
Ideally, an Ex equipment that is subjected for any repair should be accompanied by documents such
as technical specification, drawings, explosion protection performance and conditions of use,
dismantling and assembly instructions, certificate limitations, recommended methods of repair or
overhaul for the equipment (SANS60079-19, 2007). However, in South Africa, during the purchasing
process of an Ex equipment the certificate holder or seller provides the end-user with the IA certificate
and rarely an installation manual. The purchasing process does not take into account when the
equipment would need to be repaired.

Depending on the documents that the repair facility managed to gather on the equipment intended to
repaired. The steps as detailed in Figure 2 will be followed by the responsible personnel assuming in
this case it is a flameproof enclosure.

CASE 1: Certified repair` facility

Then the responsible person i.e. the personnel elected to take responsibility for the repair and is
supported by Operatives, will be responsible in gathering the documentation and repair the
equipment to its original form (SANS60079-19, 2007). The responsible person will submit a report to
the user that will detail the fault detected details of repair and overhaul, list of replaced or reclaimed
parts, results of all the checks and tests, summary of previous history of the repaired product and
copy of the user contract (SANS60079-19, 2007). The responsible person will also issue a certificate
of conformity to the user (APR0108, 2018). Also, the equipment will be embedded with a repaired
nameplate as per the figure 1 below.

CASE 2: Repair facility

The repairer will gather the documentation necessary to restore the default equipment to the certified
equipment. Upon repairing the equipment, the repair will submit the equipment to an Approved test
laboratory that is accredited to that type protection to get it batch tested (APR0108, 2018). The ATL
will provide the will provide the repair with a batch report when the equipment has prove that is was
certified. See the image of the batch report.

Case 3: Before IA certificate

Some second-hand equipment was sold before IA certificate became compulsory in South Africa.
Others, such as a standard motor was converted under a certified Ex N or DIP repair mark scheme or
only issued with a test report (APR0108, 2018). The regulation states that the certified repair facility
should be issued with a special IA certificate covering that type of equipment issued after it was
assessed by an ATL.

For repair facility that is not a member of a Mark Scheme, a special IA certificate covering that
particular equipment will be issued in the name of the user after assessment by an ATL (APR0108,
2018). The special IA certificate number will suffix “S’.
Figure 1: The nameplate that Transvaal Electric Motors (Certified Repair facility) will put on the repaired
equipment. The nameplate will be noticeable and have the following information, the Name of the repair
facility, Mark Scheme No, IA certificate and month and year of the repair.
Figure 2: The diagram taken from SANS 60079-19 in which a certified repair facility should follow to determine
the maximum gap of reclaimed parts
Challenges and issues
There are numerous challenges when repairing Ex equipment, especially when the repair work is not
done by the OEM such as;

Case 1
When a repair facility does not have access to any certification documents the following is an
example of repairs which could invalidate certification. Special conditions of use can be identified on
the equipment when there is a suffix “X” added to the IA Number. These conditions in many cases
includes Flamepaths values that differs from those listed in Table 1 of SANS 60079-1. Table 1 of
SANS 60079-1is often considered as a “recipe” for flamepaths when this is only guidance to the
minimum flamepath length and gap configurations proven to be safe under laboratory conditions.
Normally repair facilities will use table 1 of SANS 60079-1 as the guide for repairing flamepath
lengths e.g. an enclosure with a volume that is greater than 2 ℓ for Group I, it will be assumed to have
a 25 mm flamepath length. These do not take into consideration the actual equipment design or the
special condition of use.

Another that is example very common is when a motor endshield and casing has a declared
flamepath width of 20.0 max and 19.5 min. When this motor be supplied to any repair facility other
than the manufacturer the following is most likely to happen. The facility will note that the internal
volume is greater than 2 ℓ and repair the endshield to 12.5 mm as specified in Table 1 of SANS
60079-1: 2015 Edition 4. This will violate the certificate of the motor as the minimum test flamepath
was greater than 19.5 mm.

Case 2
One of the commercial challenges however, is the availability of technical and certification
documentation. Most manufacturers will refrain from issuing any kind of supporting documentation
pertaining to the design of equipment to third parties in order to protect their Intellectual Property.
This causes repair facilities other than the OEM’s to not have access to critical information such as
the example given above.

In these cases the repair procedure would typically be done in accordance with SANS 60079-1: 2015
Edition 4 which is considered to give an acceptable degree of safety, however it is a pre-requisite that
no unauthorized modifications are made. In the absence of information and documentation the
repairer cannot identify these types of modification by cross checking the dimensional & other
properties of the equipment on similar units, back engineering.

It is also found that in some cases end-users see the repair process as an opportunity to modify the
equipment to suit their current needs. It is important to note that if these modifications weren’t part of
the initial certification and design that the equipment is no longer certified. Some of the modification
will include additional entries added to an enclosure, adding or removing compartment or using lower
grade bolts than those specified by the manufacture and certification documents.

Conclusion
Although the SANS 60079-19 suggests that the end-user needs to request certain documentation
from the OEM in the initial stages of the purchasing process and safe guard these documents not
only for correct use of the equipment but also for when the equipment requires repairing. The correct
documentation will enable the repair facility to conduct their work accurately without jeopardizing the
explosion protection of the product, and thus maintaining the product’s certification status.

It is important to remember that when a product is repaired to an extend where it no longer meets the
approved design of the manufacturer, the manufacturer can also no longer be held responsible for the
product. Ideally, basic approval flameproof drawings and technical specification will be ideal
documentation that the OEM should provide to the end-user.

Alternative procedure needs to be implemented to ensure that the EPA rating is maintained during
the repair procedure. Through the success of making the IA certificates mandatory in South Africa.
The information regarding the purchasing process of EPA equipments and the documentation that the
user should gather is not readily available. One would have hoped that the ARP 0108 would provide
some guidance to the user in the type of documentation that should be requested from the
manufacture.

It will be worth taken a good look at making it mandatory that the operation, installation and repair
manual as per the requirements of SANS 60079-0:2015 for the equipment that is subjected to
prototype testing become property of that testing laboratory. As through the IA certificate number, the
ATL that issued the IA certified can be easily identified. Then repairer will have necessary
documentation to repair the equipment to maintain the certificate.

Reference
1. Gov.za. (2019). Mineral Resources releases 2018 Mine Health and Safety Statistics | South
African Government. [online] Available at: https://www.gov.za/speeches/mineral-resources-
releases-2018-mine-health-and-safety-statistics-1-mar-2019-0000 [Accessed 2 May 2019].
2. Department: mineral resources (2018). ARP 0108: Guide to the regulatory requirements for
Explosion-protected apparatus. (1st ed.). South Africa: Department: Mineral Resources.
3. SABS (2007), SANS 60079-19: Explosive Atmospheres: Part: Equipment repair, overhaul and
nd
reclamation. (2 ed). South Africa: Standard South Africa