Responsible Refrigeration Article 34

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Article authored by our Director, Barney Richardson:

The legal requirement to provide a Certificate of Conformity after completing a refrigeration and /or air conditioning installation is being ignored by many contractors and their installers. This is because many practitioners are not registered as Authorised Refrigeration Gas Practitioners and the contractors who employ them opt to ignore the requirements of the Pressure Equipment Regulations. Many installer are now finding clients requesting this Certificate of Conformity.
The Pressure Equipment Regulations specifically specify:-
“An authorised person shall issue a certificate of conformity after completion of a gas installation, modification, alteration and on change of user or ownership.”

The latest Guide note discussed by the PER committee states;
“A Certificate of Conformity (CoC) shall be issued by the SAQCC Gas registered Refrigeration Gas Practitioner for the installation, repair or modification and/or maintenance of a refrigeration system in terms of the PER, SANS 347 and SANS 10147. When the refrigeration system size causes it to be in category II or higher, as defined by SANS 347, an Approved Inspection Authority (AIA) is required examine and to countersign the certificate of conformity issued by the gas practitioner”
The card issued by SAQCC Gas on behalf of the Department of Labour looks like this;

In the interests of refining the Certificate of Conformity the form has been modified to have a line where the “type of plant” can be inserted by the registered practitioner in preference to a tick box. The latest book of Certificates of Conformity printed offers on the inside of the cover a guide to “type of plant” the practitioner may encounter. The guide is not definitive but a guide as to what should be filled in. if a practitioner encounters a specific plant this must be indicated in the line. 

The new Certificate of Conformity books are available from SARACCA at R450.00 per book of 50 certificates including VAT and courier cost.  

The industry through SARACCA has in place a further requirement on those semi-skilled installers of air conditioning units up to a cooling capacity of 18kW that may sign a Certificate of conformity on installation up to this capacity. These can be the split type air conditioners being very popular at present. The signing of a CoC by a semi-skilled category ‘A’ installer has been confirmed by the Department of Labour as by the clause quoted above from Regulation 17 of the Pressure Equipment Regulations. 

Regulation 6 of the Pressure Equipment Regulations titled ‘Duties of users’ states in clause 2(e) “… ensure that a gas system has a valid certificate issued by an authorised person.” It is a legal obligation of the Authorised Refrigeration Gas Practitioner to issue a CoC to the client/user when an installation is completed and where any maintenance or repair is done. It is the client’s obligation to request sight of the practitioner’s registration card and the Certificate of Conformity.

Also to be considered is, what happens when a whole team is involved in the installation? The responsibility falls on the senior registered person on site who may be a foreman, supervisor commissioning engineer or even the design/contract engineer to have the final signing authority. There may be a case for a number of CoC’s be issued and kept on record for the project. An Approved Inspection Authority in terms of SANS 347 also has a responsibility. Also of importance and must not be forgotten is that where the refrigeration or air conditioning  plant input power exceeds 20kW in terms of SANS10147 clause 7.4,  the user or employer shall provide a log book in which amongst other information log and record all maintenance activity performed on the equipment including the Certificates of Conformity issued by authorised persons.

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