How can you be sure your Ex Inspections are being carried out correctly?
26 March 2019
Companies cannot afford to take chances with explosion safety. More than ever industry is seeing enforcement and claims for non-compliant inspections with entire teams being replaced on sites for not being competent. In this article, Paul Hague of ExVeritas takes a look at the requirements for inspection teams and the individuals who lead them.
The Ex Industry has come to rely on the individual competence of Ex inspectors on a project rather than the collective competence requirements of the inspection team and management. All too often, someone with little or no experience can be found employed as an expert inspector or may even be leading a team of inspectors.
Competent inspection team members may require many different specialist skills covering the technical knowledge for the range of protection techniques available for equipment explicitly designed for use in explosive atmospheres. The inspection team leader or responsible person will need the management skills to be able to manage the team and to conduct, analyse and thus action the results of an inspection.
Accredited Inspection companies (for example to ISO/IEC 17020 ‘Inspection Body’) have to be able to demonstrate not just a level of training and assessment for team members, but they should also have suitable experience, specialist skills and levels of supervision and data recording analysis.
The ‘Technical Person with Executive Function’ and ‘Responsible Person’
IEC 60079-17 defines the Technical Person with Executive Function (TPEF) as having adequate knowledge in the field of explosion protection. They should be familiar with the installation and local conditions, and have overall responsibility and control of the inspection activities associated with electrical equipment within hazardous areas.
Although from the standard this role is assigned to the ‘continuous supervision’ type of inspection, it is clear that it also applies to the role of the Responsible Person (RP) and all types of inspections covered by this standard.
The RP/TPEF is responsible for the maintenance and inspection documentation. Known as ‘the verification dossier’, it shall include as a minimum the following:
a) Zone classification of areas and, and if included, the equipment protection level (EPL) required for each location.
b) Gas and Dust equipment group (IIA, IIB or IIC and/or IIIA, IIIB or IIIC), temperature class requirements and maximum surface temperature as required.
c) Equipment characteristics e.g. temperature ratings, type of protection, IP rating, corrosion resistance, vibration resistance etc.
d) Sufficient records to enable the explosion protected equipment to be maintained in accordance with its type of protection for example, the list and location of equipment, spares, certificates, technical information.
e) Copy of the initial and periodic inspection records and details of any repairs or maintenance.
In order to retain and review the required information, an ‘Ex register’ is required. This will normally be some form of electronic database that records all Ex equipment whether in the hazardous area or performing some form of safety function outside of the hazardous area, e.g. associated apparatus (Ex i barriers) and overload tripping devices used on some increased safety motors, etc. It should also include protective systems, e.g. mitigation devices, and non-electrical equipment that is certified or risk assessed.
The Inspection Team
The RP/TPEF shall ensure that an inspection team is in place to undertake the inspections. This team should have the breadth of knowledge available to encompass the range of the Ex protection techniques or concepts covered by the installation. To get an inspector with the correct knowledge and skill set is not easy, as they are not readily available.
Specialist companies that provide this service to industry must invest in their staff ensuring that the inspection team members have the range of skills, knowledge and experience necessary to undertake the inspection activity in a meaningful and safe manner.
Most training and/or assessments schemes aimed at the practitioner level can never really cover every aspect of information required for inspection, therefore without experience and additional knowledge this may not be sufficient to cover every aspect required of the ‘inspection team’. It is therefore clear that competent ‘inspectors’ need on-going mentoring and study additional to the level offered by the various assessment schemes.
The inspection team shall be able to gather the evidence during the inspection activity and then the RP/TPEF should be able to use this information to derive meaningful decisions in accordance with their documented inspection and maintenance strategy.
Sources of evidence could include:
• Risk assessment studies;
• Equipment certificates and manuals;
• Maintenance procedures;
• Maintenance records;
• Test and inspection records;
• Competence records of the installer;
• Compliance against safety management system procedures;
• Field observations.
Competence for Ex Inspection Bodies over the individual competence requirements
Specialist companies that provide these inspections services should, like the RP/TPEF and inspection team members, have a proven level of competency. It is not just about getting the right people in place to control or undertake the inspections, it is important to ensure that policies, procedures and methodology are in place to meet the benchmark level expected by industry.
To assist with this process a range of International and National documents are available.
1) ISO/IEC 17020 Conformity assessment- Requirements for the operation of various bodies performing inspections.
2) UKAS RG101: Accreditation for the inspection of electrical equipment and installations in potentially explosive atmospheres.
3) HSE: COMAH Competent Authority. Inspection of Electrical, Control and Instrumentation Systems at COMAH Establishments (Operational Delivery Guide)
4) Energy Institute Publication - Guidelines for managing inspection of Ex electrical equipment ignition risk in support of IEC 60079-17
Accreditation to standards such as ISO/IEC 17020 should be considered a minimum.
It is not enough just to conduct Ex Inspections – there must be policies, strategies and programmes in place that identify a clear and concise route, not only for the inspection, but also for any corrective actions identified, including on-going maintenance.
The RP/TPEF must be able to demonstrate that any strategy and programmes are effective and that they maintain (or ideally reduce) the level of risk which has been deemed acceptable for the people, environment and assets. The RP/TPEF therefore has a key role in the explosion safety of a site or facility/plant.
The competency of people in these key safety roles must be verified and attributed, at intervals not exceeding five years, on the basis of sufficient evidence that the person is competent across the specified range of activities and has the relevant knowledge and understanding underpinning the competency.
To assist with competency assessment, CompEx have developed the CompEx module EX14 - Responsible Person Module. This aims to assist responsible persons in meeting their legal obligations including maintaining an Ex asset and inspection register and implementing a practical approach to the inspection and maintenance of equipment in explosive atmospheres using IEC 60079 Parts 14 & 17.
To assist with selecting a competent Ex Inspection Body to undertake and manage all of the requirements discussed in this article, companies should look for UKAS accreditation, which is Government recognised accreditation. In certain industries, such as high risk or public sector sites, using UKAS accredited suppliers for critical services will be standard practice, but for smaller sites or sites with a lower risk, this option should also be considered, as who can afford to get explosion safety wrong?
About the author
Paul Hague is the Site Operations Manager at ExVeritas. Having started his professional career at ICI Runcorn, Paul has over 25 years’ experience working in potentially explosive atmospheres including DSEAR/ATEX compliance, hazardous area classification, installation and inspection. Paul’s experience includes oil and gas, heavy and speciality chemicals, pharmaceuticals and the food industry.
Contact Details and Archive...