The Department of Labour called for comment on the draft Explosives Regulations Amendment 2017, including some changes in the required skills.
At a consultation workshop in late August 2016 at Unisa Florida campus, the DOL, SAPS, relevant Approved Inspection Authorities (AIAs), and the explosives industry forum, National Institute for Explosives Technology (Nixt), announced that;
- Consultation is open, and a formal period of 90 days would follow soon.
- Employers would have to inform and “thoroughly train employees in safe work procedures, and risks of shock, friction, fire, static electricity, and the Explosives Regulations”.
- Explosives safety training providers would be accredited against SAQA standards.
- Explosives handlers would re-apply on a new form, already available on the Internet, in terms of Reg4(4)(f).
- Explosives Managers would be certificated by the chief inspector, and appointed by employers. The DOL would appoint SAQA-accredited trainers, and examiners to test their skills.
- Employers would have to appoint one or more trained and experienced people.
Explosives risk assessments standard
Explosives risk assessments (Ex-RAs) and reports, would be standardised by SANAS TR 71-05, to include:
- descriptions, hazard identifications, mitigation or treatment measures, and recommendations;
- regarding buildings, processes, equipment, personnel;
- and any of these elements that may be planned, or foreseen;
- integrating radiation data;
- taking account of research into past incidents on other sites;
- in a written report;
- available on site.
Ex-RAs would have to be signed off by and AIA (in terms of Regulation 18), or by a foreign AIA if recognised by the DOL. Emergency plans would have to provide for evacuation, and be tested yearly.
Ex-radio frequency exposure management
Radio frequency (RF) exposure of explosives would be managed by new standards. The risk of detonation by two-way radios, cellphones, scanners, vehicles, PCs, laptops, trackers, cameras, wifi, and other devices, had grown.
The safe distance for two-way radios is 12.2m; and for cellphones is 7.7m. Employers would have to set up exclusion zones. The inspector may approve of certain exemptions.
Explosives are immune to radio frequency fields of 1V/m2. Background radio fields in buildings is typically about 0.3V/m2. Some operators will have to test their plant for resistance against UHF signals
Transport of explosives would remain under SAPS enforcement, which would amend its regulation in 2017. Some aspects of explosives law would remain under the Department of Mineral Resources (DMR). The amendment would be followed by a DOL guideline in 2017, which would be legally binding.
Explosives industry to set guidelines
Nixt chairperson Dr John Cummins said the guide would include ammonium nitrate, PPAN, PGAN, TGAN, as well as pumpable emulsions, supply chain, and manufacturing waste disposal, thus a cradle to grave approach.
In the hierarchy of management (of policy, standards, guidelines, and procedures), guidelines are general and generic, but important in translating principles into practice.
Nixt would start drafting guidelines at its conference in October 2016, in Stellenbosch, themed on explosives testing and analytical methods.
The industry body shares incident investigation results, and Sheq issues, on a non-collusive basis between the six south African explosives manufacturers; BME, Sasol, AELMS, Maxam, Safex, RDM, and PMP. The African manufacturer Arica had joined as an associate.
Nixt offers awareness training, and guides universities on relevant process safety modules. It is involved in the international Chief Inspectors of Explosives conference in 2018 (contact email@example.com).
Explosives industry better governed than construction
DOL CEM director Pumi Maphaha thanked the industry for their co-operation in self-governance. The amendment took six years to reach draft stage. He complained that the construction industry was not as co-operative.
Despite industry agreement on professionalising construction health and safety some time ago, “Construction Health and Safety Agents are still nowhere to be found, and some construction sites do not have an engineer on site.”
DOL chief inspector Tibor Szana also criticised the legislative process: “Too often regulations come out with flaws that have to be corrected later.”
He may have been referring to the Construction Regulations Amendment, also long in the making. The C-Regs remain under public criticism for some impracticalities, such as the construction health and safety registration scheme, versus the legacy of poor OHS training, and low level appointments.
Long route to better health and safety laws
The regulation amendment had proceeded from an industry request, due to new technology, and procedural changes; to the DOL chief inspector; to the minister of Labour’s Advisory Council on Occupational Health and Safety (ACOHS); to the National Explosives Council; to a technical committee; to the state law advisor; to the national language services; to the minister of Labour. The same route would be repeated after public comments may be accounted for.
Unisa is the leading trainer of explosives managers, and offer CPD courses.
Among the delegates at the amendment consultation workshop were:
DOL explosives specialist Rudzani Ramabulana
DOL OHS chief inspector Tibor Szana
DOL construction and CEM director Pumi Maphaha
DOL major hazardous installation specialist ms R Aphane
SAPS col Jurie van Staden
Nixt chairperson Daniel Mynhardt
Nixt Ernest Hudson
SANDF gen Mandane
SANDF col Corrie Ferreira
Mining Roger de Villiers
DMR Willem Welding
DMR Hannes Jooses
DMR Anthiony Coutinno
DMR Kevin Hweston
Unisa CEMS quality and management sciences exec dean prof Thomas Mogale
Unisa prof H Schenk
Sanas Eben Smit
RDM ms M van Emmenis
ITC Callie Fouche
Ishecon AIA D Rademeyer
Railway Safety Regulator (RSR) Links Mudale
Fedusa Alwyn van Heerden
Cosatu Lenox Mekuto
Fire and emergency bodies were invited to comment, and to join Nixt.
Comment contact details
DOL Explosives specialist: firstname.lastname@example.org
DOL explosives secretary: email@example.com
Explosives industry body Nixt: firstname.lastname@example.org
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