Speaking at a Mining Electrical Safety conference in Brisbane last week, Jim Birch, from the Department of Natural Resources and Mines and SIMTARS manager, engineering, testing and certification centre, explained some of the problems faced by the testing authority given the current situation.
He said the new Act and Regulations for Coal Mining Safety and Health, introduced in March 2001, changed the way equipment was approved for use in mines. As a result of the new legislation old approvals are now considered to be certificates. The old approvals were issued based on test reports of New South Wales MDAs. Supplementary approvals and exemptions were issued, based on reports or assessment by a coal mining electrical inspector.
“The process for the issue of an approval did not follow the process requirements for certification. While the QMD approvals are considered to be certificates by the inspectorate, they are not considered to be certificates by certification bodies. This means that a certification body will not issue a supplementary certificate to a QMD approval,” Birch said.
A problem arises when a modification is made to certified equipment. Previously modifications to QMDs were submitted to the inspectorate for approval but under the new legislation this is no longer possible.
Modifications made to equipment covered by a QMD approval must be submitted to a testing station/certification body for issue of a certificate.
The inspectorate have agreed that for minor modifications an engineering statement, rather than certification, is satisfactory.
“For this to be done the testing stations must see all drawings to ensure that the changes specified are the only ones made to the approved equipment. Showing traceability is essential to support decisions regarding the acceptability of the modifications made.”
This issue remains the major sticking point between mines and testing stations. But, as Birch rightly points out: “Unless the drawings listed in the approval for the equipment can be provided, i.e. correct issue and date, there is no basis for conducting an assessment of the changes.”
In some instances even with all drawings supplied, there may not be enough detail to permit assessment of changes.
For mines with equipment like DCB enclosures this represents a problem. Some operators feel that equipment is being held up to more rigorous standards than it was ever designed to. The question is what do mines do with equipment which is ageing and may need repairs. Unless engineering records for this equipment exists, mines may have to consider replacement as the only option.
Electrical operators from Queensland mines have formed a discussion group to further the issue but it looks so far as if the testing stations hold the moral high ground. No testing authority in their right mind would be prepared to certify modified equipment if the design of the original equipment was questionable.
