Treating timber by-way-of opinion-based decision making rather than in accordance with the law will lead to the use of unsafe and non-compliant pressure treatment vessels – which puts not only your treatment plant at risk, but also the reputation of the industry.
Arijit Chandra – who is a professionally registered Mechanical Engineer and a member of the PER Technical Committee in South Africa, weighs in on the subject.
“Ignorance of the law is not an excuse. The Pressure Equipment Regulations were promulgated over 10 years ago, in October 2009, and not abiding by them will lead to fines or being shut down should an inspector from the Department of Labour find you guilty of non-compliance. You have to get yourself fully compliant,” says Chandra.
He adds that without strict compliance to the PER governing the manufacture and operation of pressure vessels, it is impossible to ensure the health and safety of individuals employed in the industry. “This is the reason why the regulations are so important and why they have been mandated by the Occupational Health and Safety Act,” emphasizes Chandra.
The design and certification of CCA pressure treatment vessels in South Africa is governed by the PER, the OHS Act and SANS 347. While some may disagree on this classification, Chandra states that the regulations are clear on the matter and that it is not for debate.
“Everything is based on the categories of pressure equipment that is being manufactured. The different categories of assessment within the PER are dependent on the type of pressure equipment, its design, pressure state of the fluid inside and the fluid group.
“Pressure equipment starts with a SEP (sound engineering practice) and then goes to category 1, 2, 3 and 4. Category 1 is the lowest level of intervention and requires no third-party involvement, except for pressure vessels manufactured to RSA/CI/OHSA, which will then require AIA involvement. The SANS 347 standard will determine the category and the equipment then needs to be manufactured as per the requirement set out by this standard. CCA pressure treatment vessels use the chemical pesticide chromate-copper-arsenate and therefore fall under the category ‘filled with a hazardous fluid or hot water mixed with a chemical,” explains Chandra.
To sell any pressure vessel (including Category 01 to 4) on the South African market, manufacturers must follow the steps below to ensure compliance.
- The pressure vessel must be designed to an acceptable health and safety standard incorporated in the government gazette R262 of 24March 2017.
- The design must be signed off by a professional engineer.
- The design must be submitted to the Inspection Authority for design verification.
- The manufacturer must follow all steps as required by SANS 347 to ensure compliance, under the supervision of the AIA.
- The AIA must counter-sign the manufacturer’s certificate.
- The nameplate must be stamped by the AIA (manufacturing) to meet the requirements of Regulation 9.2 of the PER.
Anyone purchasing a pressure treatment vessel must ensure that after installation, a pre-commissioning inspection is carried out by an approved inspection authority who will issue a pre-commissioning inspection certificate. Thereafter, every 36-months, the vessel must undergo an inspection by an in-service approved inspection authority. Furthermore, the maintenance of existing pressure vessels, which was regulated under previous regulations, requires full AIA involvement during repairs or modifications.
Sales Engineer at Lonza Wood Protection, Robert Fourie, emphasizes the importance of compliance when performing repairs and modifications: “CCA pressure vessels that are manufactured to a specific standard have to modified or repaired by a manufacturer whose welders are certified within that standard. Users must ensure that the pressure equipment has documentation certifying that modifications and /or repairs have been carried out in accordance with the relevant health and safety standard. This documentation must be issued by the repairer or modifier and must include a verification signature by an approved inspection authority when required.”
Senior Business Manager at Lonza Wood Protection, JJ du Plessis, concludes: “We should never become complacent about the health and safety risks associated with using non-compliant pressure vessels when treating wood. The legislation that is in place provides fundamental safeguards and best safety practice to maintain the good reputation of our industry and should, therefore, be fully adhered to. If you are unsure whether your CCA pressure treatment vessel is compliant, it would be in your best interests to seek advice from the AIA or contact Lonza to guide you through the process and place you in contact with the correct professional vessel inspection authority.”
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