Mandatory Training & Competence for ‘Ex’ Designers
There have been many significant changes in the last 18 months that are relevant to manufacturers of skids and assemblies. This includes a new Installation Standard, new or revised protection concepts, new equipment selection methodologies and new equipment groupings to name but a few. One of the ‘new’ requirements is specified and mandatory training and competence verification for people involved in the design of ATEX and IEC equipment for hazardous areas.
Competence in the field of IEC and ATEX Design is a requirement for those involved in such projects, however, it is also ‘good business’, Knowledge of the requirements will lead to equipment being built faster, for less cost and to specification.
The need for verifiable training and competence for staff involved in the design of ATEX and IEC equipment is a relatively new requirement. The defined competence level of people involved in ATEX and IEC design is in the new edition of the Installation Standard (EN60079-14 Edition 4) for IEC/EN and ATEX. The new Standard specifies in some detail the training and skill requirements for people involved in the manufacture of assemblies, installation of equipment or plant design for use in hazardous (potentially explosive) atmospheres.
For the purpose of this paper, a manufacturer is considered to be someone involved in building rigs, skids or assemblies using certified (or self certified) electrical equipment and largely uncertified non-electrical parts. This ‘assembly’ of parts ‘is’ covered by the ATEX Directive, and although it will probably not need Notified Body involvement, it will always need to be designed, assessed, installed and documented correctly. Ultimately, the competence levels of the people involved in this activity will determine the safety and compliance of the final assembly, and many parts (for example contained or potted) will not be verifiable by 3rd party review.
When a manufacturer or installer claims ATEX or IEC compliance (or is working to such a specification), the Installation Standard (amongst others) is mandated. For that reason, the manufacturer is claiming verifiable training and competence of the designers and installers (assemblers).
Purchasing and assembling ATEX or IEC equipment does not alone produce an ATEX assembly (a rig or skid containing electrical and non electrical equipment is normally referred to as an assembly under the ATEX Directive).
In addition to the use of certified equipment, further assessments must be made and documented in the Technical File or Technical Dossier to demonstrate compliance with ATEX. This may include (for example) risk assessments, other CE Marking issues, material verifications and perhaps most importantly, evidence that the design and installation were carried out by suitably qualified and experienced staff.
The ATEX & IEC Installation Standard for Manufacturers
The installation standard is necessary and applicable as soon as a manufacturer comes to select cable, glanding, materials of construction (any metal or plastic), electrical parts, non-electrical parts such as valves, pumps and warning signs. Even if you do something as simple as mount a flameproof (explosion proof) motor in a box for weather protection, you will need to apply the Installation Standard and conduct and document a risk assessment.
Why? The answer is simple, the installation standard and other relevant design standards (such as the non-electrical standards and general explosion protection methodology standards such as EN/IEC1127) give specific constructional requirements for explosion protected equipment that must be complied with (or you must produce evidence such as test reports as to why the deviation is safe).
This is the purpose of a ‘Standard’, it is a design guide; if you design to the Standard(s), you will be in compliance with ATEX and you will also have ‘state of the art’ explosion protection.
If you do not design to the Standard you risk being unsafe in a potentially explosive atmosphere, where several recent explosions have resulted in significant loss of life and costs to the companies involved exceeding billions of Dollars. As most ATEX and IEC equipment will be inspected against the requirements of the Standards involved prior to being commissioned, deviating from the Standards runs the risk of significant re-work. This is particularly true when supplying to Europe where an inspection against the installation standard by a qualified person is normally required before commissioning (it is referred to as an ‘initial inspection’)
Evidence of competence (and/or training) can be requested by an end client (or regulatory authorities) for the designers of assemblies, the people who built the assembly and the people involved in the management process. This is becoming a required deliverable for a new complex assembly where it would be difficult to re-check every aspect of the safety case and reliance is put on the competence of the staff involved in the initial design and specification.
Controlling the Mandated Competence & Training Levels for ATEX and IEC
Competencies apply to each of the explosion protection concepts for which the person is involved. For example, it is possible for a person to be competent in intrinsically safe equipment only and not be competent flameproof or increased safety. It is because of the complexities and range of engineering disciplines within explosion protection (ranging from heavy current to micro-electronics and mechanical design to process engineering) that we very rarely have an expert in ‘ATEX’ or ‘explosion protection’ in general (unless they have done this exclusively for many years). Most engineering staff will only need to be competent in the range of activities required for their job function within an organisation.
Each manufacturing organisation should define both the levels of competence required and Quality System requirements for ensuring that the staff involved in work have the correct competencies and training, with timescales set for re-assessment and/or re-training (regular re-training is a defined requirement of the Installation Standard, generally re-training is required within 5 years due to the dynamic nature of the requirements).
The Standard defines the three basic types of training required for ATEX and IEC. It should be noted, however, that this should be viewed as a minimum; there are many cases where manufacturers would require additional competences. If, for example, you manufacture equipment that holds, processes or generates a flammable atmosphere, knowledge of ‘area classification’ and process safety may also be required.
If you are involved in the manufacturer of rigs, skids or modular plant where process safety is necessary, knowledge of ‘Safety Integrity Levels’ (SIL) and protective devices may also be required. Any device that protects against the affect of an explosion such as a flame arrestor will need to be ATEX certified on ATEX equipment. It is not, however, as simple as buying a certified part and installing it, to determine if you need a flame arrestor, deflagration arrestor or a detonation arrestor, you would need to know what flame speed you would expect in a pipeline or vessel. Similar examples could be given for many types of procured equipment, again emphasising the need for training.
For the purpose of this paper, we will concentrate on the requirements for ‘Designers’. It should, however, be noted that ‘Responsible Persons’ (who are responsible for the ‘processes’ involved in the design, selection and manufacture of the assemblies) and ‘Installers’ (the people who actually put the equipment together) all have their own specific training requirements, and in the case of ‘Installers’ these requirements including assessing their practical skills and ability.
ATEX and IEC Design Competence Requirements
The requirements for personnel involved in the process of designing plant or equipment for use in potentially explosive atmospheres (including equipment that may be located in the safe area but have functionality involved in the safe explosion prevention or mitigation) should be given serious consideration. Reviewing case studies of many recent explosions will demonstrate that it was the fundamental design that was unsafe, even when correctly built and installed (such as an incorrectly specified level switch or an impractical maintenance procedure post installation)
The requirements will obviously be applicable to companies who design plant but are equally applicable to project engineering companies or manufacturers who may provide rigs, skids or assemblies that may or may not utilise certified hazardous area equipment.
According to the Installation Standard, Designers must possess, to the extent necessary to perform their tasks, the following skills:
- Detailed knowledge of the general principles of explosion protection; this would include knowledge of terms such as LEL, MESG, Flashpoint and factors that affect dust and gas explosion properties (pressure, temperature, oxygen etc).
- Detailed knowledge of the general principles of types of protection and marking; this would include all of the electrical concepts such as i.c., m.a. etc., group markings such as IIB+H2 (Gas) or IIIC (dust) and EPL’s.
- Detailed knowledge of those aspects of equipment design which affect the protection concept; this may include SIL if safety systems or protective systems are used and in depth design knowledge if concepts such as constructional safety (c) or IEC special safety (s) are used.
- Detailed knowledge of content of certificates, such as use of the ‘X’ or ‘U’ and the many different certificate types and issuing bodies.
- An understanding of practical skills for the preparation and installation of relevant concepts of protection (full knowledge of the installation requirements).
- Detailed knowledge of the additional importance of ‘Permit to Work systems’ and safe isolation in relation to Explosion Protection; Process and procedure documentation – most explosions occur during start up/shut down or maintenance!
- Detailed knowledge of the particular techniques to be employed in the selection and installation of equipment referred to in IEC/EN 60079-14 and a general understanding of Inspection and Maintenance requirements of IEC/EN60079-17.
Designers must be able to demonstrate their competency and provide evidence of attaining the knowledge and skill requirements specified above, relevant to the types of protection and/or types of equipment involved. They must also be able to demonstrate their competency with documentary evidence such as ‘Designers training Certificates’ to the user and suitable documented safe operating procedures and list of required checks and maintenance (including intervals).
Assessment of training and competence for UKCA ‘Ex’, ATEX and IEC
The new Installation Standard states that the competency of Designers shall be ‘verified and attributed’, at intervals relevant to national regulations or standards or user requirements, on the basis of sufficient evidence that the person has the necessary skills for their job function/task.
Verified and attributed competence translates to having training and experience records for all staff that demonstrate that the training provided covers the scope specified by the standard and was provided by a competent training authority.
Internal company training and competence records may be used to demonstrate compliance if the internal training provider and competence assessor can be demonstrated as competent and suitable expertise and knowledge. The mechanism for ensuring that the training provided is in line with current Standards and practices should also be recorded.
The frequency of re-training (updating) is not currently specified. Individual companies should be aware of the changes to legislation and Standards that are applicable to them and should determine if additional training is required. This type of review should be addressed by the company’s management system (for example, ISO9000)
Both Training Providers and Competence Verifiers (they can be the same or separate people/organisations) should be selected carefully. It is vital that the training provider and assessor be verifiable and that they have very significant and relevant experience and their knowledge is ‘current’.
The ‘state-of-the-art’ nature of UKCA and ATEX (Standards changing with technology and new knowledge) requires a new approach for both gaining and maintaining competence. Building equipment or plant to an ATEX or IEC specification is a complex multi-skilled task. Whilst in North America Engineers may be familiar with the requirements of NEC for explosion protection, ATEX and IEC are vastly different and have substantial documentation and quality control requirements. It is vital for both safety and project risk that the people involved with the design and specification of the equipment are technically compliant and aware of both the specification (legal compliance) and safety issues involved.
ExVeritas provides a full range of specialist and Nationally Recognised (CompEx) Qualifications for Designers and Installers: View our courses