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As you were on the paper chase

07 August 2009

Just after our last issue went to press, the European Commission had second thoughts on the presentation of documents such as Declarations of Conformity. Ron Sinclair explains the latest position on the commission’s paper only policy

Ron Sinclair: Electronic transmission will not become the norm
Ron Sinclair: Electronic transmission will not become the norm

One of the interesting challenges in writing a regular column like this is trying to keep up-to-date at the same time as meeting the editor’s deadlines. In the last issue, I went on at length about how the EU Commission was so insistent that instructions and all other information, such as Declarations of Conformity, which accompany a product, must be in paper form.
Low and behold, exactly one week after submitting my piece by the deadline, I found myself sitting in a meeting room in Brussels, listening to the representative of the European Commission saying that they are beginning to have second thoughts on the subject. Apparently there has been significant pressure in connection with some other directives, such that the Commission is being forced to rethink its policy and work out a solution to allow electronic transfer of the information. There was no decision promulgated in Brussels during the meeting at the end of June, but a clear indication that, after further consideration, there was a very strong probability that the paper only policy would be relaxed.
It would not be correct, however, to suggest that electronic transmission will become the norm. As far as I understand the thinking, the relaxation will only apply where it is agreed between manufacturer and purchaser as a specific condition of contract. Thus for most equipment bought from a catalogue, the paper chase will continue. However, for manufacturers of complicated one-off equipment, which typically has a complete bookshelf of information for installation and maintenance, the electronic solution will be a relief. Just don’t say that I said you can do it now, but I can understand why there might be pressure to pre-empt the formal decision.
The discussion about the instructions has related to ensuring that they get into the hands of the people that need to use them, whether installing, inspecting or maintaining the equipment. However, in terms of safety, this is only part of the story. Those people and their managers need to be competent to supervise and perform the necessary tasks.
By the time you are reading this, the IECEx Scheme for Certification of Personnel Competency should have been launched at the IECEx meetings in Melbourne during the first week in September. This is the first international scheme to attempt to give validated recognition to transportable knowledge and application of skills. Many large plant owners and contractors have their own competency schemes, but we will now have a qualification which can be recognised anywhere in the world.
As with the IECEx Product Certification Scheme, there will be a rigorous assessment of the individual certification bodies, to show that they have both the organisational capability and the technical capability to run the scheme. Once at least two certification bodies have been accepted, the scheme will be officially open for business.
The UK has been one of the leaders in training and assessment of operatives, with the CompEx scheme, but IECEx goes that bit further and also includes an assessment of the actual work being undertaken by the individual on a continuing basis, as well as an examination after training, which provides evidence of competence in practice. Also the scheme is aimed at individuals at all levels in an organisation, not just at the operative level.
There are 10 specific competency modules and it is expected that individuals will select just the appropriate ones for the work they do. Some of the modules are interlinked, and most individuals will require to show competency in between two and five of the modules.
In addition to a searchable on-line database, developed to parallel the existing IECEx databases for certified products and certified service facilities – and therefore capable of immediate updating should an applicant’s status change – successful applicants will be issued with a copy of their on-line certificate and additionally with a credit card size identification card so that they can prove they are the individual listed on the web site.
Historical evidence demonstrates it is the lack in the competence of individuals working on a hazardous area plant, rather than problems with product certification, which has led to most major incidents. Consider Flixborough, Piper Alpha and Buncefield, where failure to follow sensible procedures during maintenance was the prime cause of the disaster. This new scheme should, at the very least, help to plug that gap.

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