Since the Yelland appeal in January 2003 which overturned the previously mandatory surge protection requirements of SABS 0142-1: 2001, a review of SANS 10142-1: 2003, by Dr. Clif Johnston, director of standards at the SABS, has revealed further serious irregularities.
SANS 10142-1: 2003 is the new South African National Standard that replaced SABS 0142-1: 2001 after a number of changes were required as a result of the outcome of the above appeal, other feedback from the industry, and a new standards numbering system introduced by the SABS.
SANS 10142-1, also known as the Code of Practice for the Wiring of Premises, Part 1: Low Voltage Installations, is listed in the Electrical Installation Regulations of the Occupational Health and Safety Act (OHS Act) as a mandatory safety standard. Like the previous SABS 0142-1, the requirements of SANS 10142-1 therefore have the force of law through the OHS Act.
The review by the director of standards at the SABS was prompted by comments and objections from the affected industry and members of the relevant SABS subcommittee responsible for low voltage electrical installations (SC 67F). The further irregularities identified by Dr. Johnston are "sufficiently serious to warrant immediate withdrawal of the standard".
Dr. Johnston also made it clear that the list of irregularities identified in his "brief review" was not exhaustive, and that persons with more intimate knowledge of SANS 10142-1 may well identify further or similar irregularities that would also need rectification.
Some of the irregularities and findings identified in the review by Dr. Johnston include:
* Chapter 3 defines new categories of skilled persons, namely distribution board/assembly assessors and evaluators, without indicating the required level of competence.
* Chapter 4 deals with authorization and proof of compliance of components and assemblies, and contains regulatory requirements that have no place in a standard, and most if not all of Chapter 4 should be removed from the standard.
* The wording of Clauses 18.104.22.168 and 6.7.6 is ambiguous and could create the impression that the installation of surge arrestors is a requirement, whereas the installation of surge arrestors is not a mandatory safety requirement.
* Clauses 22.214.171.124, 126.96.36.199, 188.8.131.52, 184.108.40.206, 220.127.116.11 and 18.104.22.168 relate to assessment, type testing and certification of distribution boards, and contain regulatory matters that have no place in a standard.
* Clauses 8.1 and 8.2 relate to Certificates of Compliance (CoC) for verification and certification, and should be removed in their entirety as they deal with regulatory matters.
* Annex S deals with switchgear assemblies with a short circuit rating greater than or equal to 10 kA, and contains requirements which differ from those given in a valid South African National Standard (SANS 1473-1). The opening statement of Annex S that "In the absence of the availability of a revised edition of SANS 1473-1, this annex provides requirements for low voltage switchgear and controlgear assemblies", is unacceptable, and Annex S should be removed forthwith.
The implications of the review and findings by Dr. Johnston are particularly serious in that the industry is currently engaging in significant expenditure to meet the mandatory regulatory requirements of SANS 10142-1, and in particular the type testing of low voltage distribution boards and motor control centres, which have now been declared irregular. In addition low voltage switchgear manufacturers who do not yet have certified type tested switchgear assemblies are losing business as consultants and end-clients begin to insist on proof of compliance as per the current requirements of SANS 10142-1.
Objections have been made to the minister of labour and/or the SABS by various industry associations such Electrical Engineering an Allied Industries Association (EEAIA), the Electrical Switchgear Association of South Africa, and the Electrical Contractors Association of South Africa (ECA) on various regulatory aspects of SANS10142-1 relating to distribution board/assembly assessors and evaluators, and the proof of compliance, assessment, type testing and certification requirements for distribution boards and motor control centres. Now demands are being made for a moratorium on these regulatory aspects.
The review and findings by the director of standards of the SABS that SANS 10142-1 contains serious regulatory flaws seems likely to strengthen the demands for an immediate moratorium. And if this is not granted, significant potential legal liabilities could arise.
Chris Yelland (CEng)
EE Publishers (Pty) Ltd, P O Box 458, Muldersdrift, 1747, South Africa
Tel: (011) 659-0504 Fax: (011) 659-0501 Cell: 083 290 0442
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