Session Fourteen: Hazardous Areas Auditing The Devils in the Details

Session Fourteen:
Hazardous Areas Auditing The Devils in the Details
Kayne Herriman
Hazardous Areas Specialist, Bluefield AMS

Abstract
To say a piece of equipment is compliant means that every detail has been
checked according to the applicable codes, certification and manufacture
specification. This is sometimes seen as dragging out the process but really we
are ensuring that every detail is correct, compliant and the equipment is safe
for operation. The devils in the detail, and the lack of detail is the risk that
many operations continue to expose themselves to. Kayne will share his
experiences of conducting audits on electrical equipment in hazardous areas,
the problems which were found, the details which were overlooked and the
learnings he has taken away to pass on to others.

Introduction
Any hazardous areas audit, is a systematic and critical examination of the
installation, equipment, its operation and safety systems.
To say a piece of equipment is compliant is to say that:
The installation has been correctly classified
The equipment selection is correct
The equipment has been installed as per the certificate of conformity
and/or manufactures specifications
Accessories and terminations comply, have been done correctly and,
where relevant to a correct torque
Equipment has been electrically tested and deemed safe
The inspector is trained, competent and authorised
Currently there are two states (Queensland & Victoria) in Australia which the
state government requires electrical installations in hazardous areas to be
inspected/audited.
In Queensland the Electrical Safety Regulations 2013, Section 221 requires
that an accredited auditor inspects electrical installations in hazardous areas
prior to connection or reconnection to a source of electricity if:

The installation is being connected for the first time

Electrical installation work has been performed on an electrical
installation within a hazardous area

In Victoria the state government regulations requires hazardous area

installations be inspected by a Class H Licensed Electrical Inspector.

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Although not legislated in other states, it is still good practice to have the
installation audited. This is not done to delay completion but to allow another
set of qualified and experienced eyes to ensure the finer details have not been
overlooked. These overlooked details can be common when the personnel
completing the project construction/ installation are also responsible for the
compliance audit process.
Another problem that can arise is when the person(s) in charge of the area do
not understand the risks, or their obligations when it comes to hazardous areas.
In these instances when auditors do get called in to audit the installation they
are usually faced with a barrage of questions and can be seen to be holding up
the process. This is usually because they feel they (the person(s) in charge)
have had competent people design, install and commission their equipment,
unfortunately this is not always the case.
Additionally, the installers and engineers are apprehensive and sometimes
defensive when details are found that should have been picked up well before
the final Audit. But this shouldnt surprise us when the volume of learning for
the hazardous areas course is ~780hrs and it is delivered in five days across
Coal, Dust & Gas, which suggests we are not getting the basics right.
This paper will highlight some of the finer details which have been found in
audits.

Keep It Simple
Auditing is the process involving systematic examination of a system.
Developing this process and following it is critical to ensuring the plant and
equipment is compliant, safe and no details are missed.
To simplify a complex process, the following solution has been developed to
audit hazardous areas and if followed gives the Auditor confidence that all
details have been confirmed.
Understanding
the legislation

Verify the
equipment &
inspect for
compliance

Review the
classification &
design report

Analyse the
equipment lists
and certificates

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Legislations & Standards

The legislations that are imposed by the state and federal governments is what
drives us to do what we do.
For hazardous areas, the relevant Acts and Regulations fit very definitely into
two areas:
1. Underground coal mining and
2. Other industries.
For both areas the Occupational Health and Safety Act of the various states
may be the overarching legislation.
Additionally, each Act may have a set of associated Regulations and provisions
for these Regulations are generally made in the Act. Regulations are generally
drawn up by the department administering the Act.
In Queensland the purpose of the Electrical Safety Act 2002 is:
Division 2 Purpose of Act
4 Purpose
(1) This Act is directed at eliminating the human cost to individuals,
families and the community of death, injury and destruction that can be
caused by electricity.
(2) Accordingly, the purpose of this Act is to establish a legislative
framework for
(a) preventing persons from being killed or injured by electricity;
and
(b) preventing property from being destroyed or damaged by
electricity.
The Act calls the Electrical Safety Regulations 2013 where the purpose of the
regulations is to ensure that the equipment is electrically safe. But depending
on the industry (Petroleum & Gas, Mining etc) they all have their own
legislations to which they need to comply. The responsibility may be spelt out in
the Act, or in associated Regulation, or in a document called up by the Act or
Regulations.

AS/NZS 3000 wiring rules is called up in legislation or contractually in each

State/Territory of Australia and its requirements are therefore mandatory. From
the wiring rules Section 7.7 specifically deals with hazardous areas where
Section 7.7.2.1 Responsibility for classification states:
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The responsibility for classification of a hazardous area rests with the

persons or parties in control of the installation. The requirements are
contained in AS/NZS 60079.10.1 for gas or vapour and AS/NZS
60079.10.2 for combustible dust.
So if you have been asked to Audit an installation, before rushing out there and
getting your hands on the equipment ,ensure:
1. The equipment owner actually requires an audit to be performed
2. The equipment owner understands their responsibilities and obligations
Dont be fooled though that the legislation will change the outcomes of the
audit, it wont as the physics and chemistry behind explosive atmospheres do
not change.

Review Area Classification

The classification provides a concise description of the hazardous material that
may be present and the probability that an unsafe event could occur. This is to
allow an appropriate equipment selection so that safe installation practices may
be followed.
Understanding what has been classified and why, gives the Auditor a firm basis
upon to start the Audit. Knowing this critical information flows into the protection
method and installation techniques that need to be adopted.
As an Audit relies on the facts, dont just take peoples opinions or words.
An example; during a recent audit it was found the person responsible for
hazardous areas had been providing the incorrect information on the
classification of the plant which was that it was IIIB Non-Conductive dust.
Although in their Simtars report the classification stated
In the view of this information it is difficult to classify coal dust, covered
by this report, as being non-conductive without further information. In
view of the possible variation in moisture content of samples, testing to
the current standard 61241.1.1 for coal dust may not be conclusive
Apart from being the incorrect dust group if the engineer had been providing
this information to other hazardous areas installers and they had not challenged
it, then potentially the equipment they had installed is non-compliant.
In addition to this it is important for the person classifying the equipment to
have an understanding of how the system works in normal operation. A
physical sample collector was found to have classification as Zone 22, which is
based on this being a Secondary source of release.
By definition a secondary source of release is not expected to release in normal
operation and if it releases is likely to do so only infrequently and for short
periods. Now in normal operation this sampler would operate, therefore the

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classification appears to be incorrect, along with the fact the electric motor is in
a defined hazardous zone and doesnt have the appropriate markings.

Another recent example.

As more coal seam gas and
landfill gas sites come on line
Hazardous areas
there has been an increasing
interest in Type B appliances.
For those who dont know
what a Type B appliance is it
is a gas device that use
>10mj/hr of fuel gas and isnt
covered by a certification
scheme.
To a Type B specialist who
holds a Gas Work Authority
Type B Appliance
they will say because the
system is gas tight and
complies to the gas codes; AS/NZS 5601 / AS 3814 and AS 1375
then it is compliant. However, a hazardous areas specialist will say it must
comply with AS/NZS 60079 series. Understanding the differences and where
they crossover is important not only from a safety and cost perspective but also
for a successful and compliant audit.
Having correct designs and classifications is a legal requirement, poorly designed
hazardous areas installations with incorrect terminology can lead to potential safety,
operational and cost issues.

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Equipment and Certification

The equipment selected for hazardous areas should have the correct marking
to satisfy the classification report. The equipment has been designed with a
safety factor to minimise the risk of it being a potential source of ignition.
Accompanying the equipment will be a Certificate of Conformity (CoC) from a
relevant certifying body.
In Australia the equipment selected needs to have acceptable certification. In
AS/NZS 60079.14 Section 4.3.1 Equipment with certificates according to IEC
standards or AS/NZS Standards states:
Equipment certified under the IECEx Scheme and registered on the
IECEx database (www.iecex.com) or the ANZEx Scheme registered on
the ANZEx database (www.anzex.com.au) meets these criteria.
Equipment certified under the AUSEx Scheme is acceptable when
manufactured within the certificate validity period
A CoC attests that a sample of the explosion proof product, described on the
Certificate, has been
1. Independently tested and found to comply with the Australian /
International Standards listed in the Certificate
2. Has initial and on-going quality surveillance of the manufacturer's quality
system and manufacturing capability
3. A description of the equipment certified
Now time and time again the only reason the certificate gets looked at is
because it has an X in the certificate number, therefore there could be
conditions of certification. Just because it doesnt have a X doesnt mean there
is no conditions. The certificate certifies that the equipment has been tested
and although there may not be an X it could tell the installer further
information relating to how the equipment needs to be installed to ensure that
the integrity of the protection technique is maintained.
What installers / inspectors dont see are the finer details which include
the applicant and additional manufacturing site which should be on the
marking
The standards to which the electrical apparatus was found to comply to
The Test and Quality Assessment reports
What the equipment is

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A snippet of certificate IECEx SIM 09.0001X is shown below. Listed in the

appendix is a range of certified terminals.

Now if the installer didnt look at the certificate they will never know that for the
certified terminal under IECEx SIR 05.0035U there are specific torque setting
which used and unused terminals SHALL be tightened to.

Additionally, anomalies on the marking and certificate can be found which need
to be addressed and feed back to the relevant certifying body, for example

The markings on the equipment states Ex d e IIC T4 Gb. Cross referencing

this to the certificate (IECEx PTB 13.0003) does show that the marking are Ex
d but there is no mention of IEC 60079-1 Explosion atmospheres Part 1:
Equipment protection by flameproof enclosure d under the standards the
equipment was tested to.

This level of detail is required otherwise how do you say the piece of equipment
is compliant?

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Verify whats installed

The first key to an hazardous areas installation is that the installer should have
in their possession copies of the area classification, installation standards,
certification documents and other information relevant to the installation. It is
obvious that the Audit is not going to go well if the installer cannot produce
these documents.
If the installers are qualified electricians then they have a responsibility to
ensure that the electrical apparatus is electrically safe. This means verifying the
entire circuit supplying the equipment.
Every electrician knows that fuses are in the circuit to protect the cables and
prevent them from overheating in a fault or overload situation. In the next
example the cables and equipment would have let the smoke out well before
the fuse popped.
The circuit diagram below was from the vendor with recommended fuse sizes
of 16A, these served two purposes:
1. Protect the cable
2. Protect the equipment.
As the installation was in a dust environment the fuses were there to protect the
motor and cable from a rise in temperature sufficient to ignite a dust cloud if it
was to appear.
It was verified that the installed fuses were 50A HRC fuses protecting 6mm2 3
core and earth.

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Just a quick diversion to AS/NZS

3008 Electrical installation
cable selection Table 13 shows
that a 6mm2 is 45A, without a
derating factor.
Taking in to consideration that it
was bunched with 10 other
circuits from Table 22 the
derating factor was found to be
0.48.
So the current carry capacity of
the circuit was 21A.
Test sheets are a legal document and the attention to detail is not given when
taking the readings and filling them in. As electricians we are required by the
legislation to make sure electrical equipment is safe, in the test sheet below the
electrician is putting himself and others at risk by not understanding the results
they are recording. There is no point in just writing down numbers if you dont
know what they mean.

A simple check of AS / NZS 3017 Table 3.2 which has been stated on the
electrical test sheet show that the values appear to be outside of the
MAXIMUM RESISTANCE for RE/RPH.

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Poor workmanship plays a large part in why equipment is found to be noncompliant usually due to the installation, glanding and terminations. Not only
does this reflect poorly on the installer but these simple problems do not
comply with AS/NZS 3000.

When equipment is installed in damp or wet areas the concern is water ingress
into the equipment. The installer cannot take it upon themselves to compromise
flamepaths. In AS/NZS 60079.14 Section 10.3 Protection of flameproof joints,
both concerns have options provided which need to be followed.

In some cases there are times when equipment is installed in hard to reach
places. In this example the junction box was located on a beam without any
access. The auditor felt comfortable enough to sign off the equipment without
verifying whats installed and simply compared it to a spare junction box making
the following comments.

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Session Fourteen: Hazardous Areas Auditing The Devils in the Details

After scaffolding was erected it was found that the factory glands were loose
and the equipotential bond was missing.
Another
example
where
verification was important was
a spray booth which has been
in use for the past eight years.
The owner was under the
impression it was compliant as
all the paper work was
available. But, the auditor
identified a limitation in their
final signoff of booth construction was not complete
The findings after the verification was completed was that the lights do not
comply with the state standards AS/NZS 4114 Part 1 & 2 nor to AS/NZS 60079,
and probably havent since the vendors original design.

The role of an Accredited Hazardous Areas Auditor

As previously mentioned, in Queensland a person must not connect or
reconnect an electrical installation located in a Hazardous Area, to a source of
electricity after electrical installation work has been performed on the electrical
installation unless
(a) the electrical work has been inspected by an accredited auditor; and
(b) the accredited auditor has confirmed that the electrical installation, to the
extent it is affected by the electrical work, has been tested to ensure it is
electrically safe and complies with the requirements of the wiring rules and any
other standard applying under this regulation to the electrical installation.

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Session Fourteen: Hazardous Areas Auditing The Devils in the Details

This reference is from the Electrical Safety Regulation 2013 Section 221. You
will notice there are key words which are bolded. People (including Auditors)
seem to think that we can wave a magic wand and the installation is compliant.
Hopefully this paper demonstrates a few examples of a very common issue to
emphasise the importance of why we must INSPECT and CONFIRM the
installation before it is energised.

Conclusion
When it comes to hazardous areas auditing the devil is in the detail and the
lack of detail is the risk. There are no shades of grey with compliance, it is
either compliant or it is not. Although the company / people want to be
compliant after issues are found and presented, there is no way around the
requirements that need to be met. One of the biggest risks we see is when a
company truly believes they are compliant yet they are clearly not after if the
audit findings are presented.
The auditor cannot just wave his wand and magically make the installation
compliant. They didnt design, classify, select, install or commission the
equipment, yet they are the ones seen to be holding up the process. If anything
the owners should be happy that the non-compliant issues were found now, not
when there has been an incident or accident.
More focus needs to be placed on getting back to the basics. Just because the
equipment has a certificate of conformity doesnt mean its compliant after its
been installed. So remember whether the issues are from installation,
equipment or administrative everything needs to be fed back through to the
correct channels so that continuous improvement occurs, and always
remember to follow up.
It is important that the people understand their limitations when working in
hazardous areas, as when non-compliances are found and re-work is required
the project soon becomes very costly. There are some of us who have been
fortunate enough to have been taken under the wing of very experience
industry mentors and as the industry moves forward its our responsibility to pay
it forward to lift the standard, as the standard we walk past is the standard we
accept.

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References
Australian Goverment. (n.d.). Training.gov.au. Retrieved 07 09, 2016, from
https://training.gov.au/Home/Tga
Parliamentary Counsel. (n.d.). Queensland Electrical Safety Act 2002.
Parliamentary Counsel. (n.d.). Queensland Electrical Safety Regulation 2013.
Standards Australia Limited/Standards New Zealand. (2009). AS /NZS
60079.17 - Explosive atmospheres Part 17: Electrical installations
inspection and maintenance. Sydney: SAI Global Limited.
Standards Australia Limited/Standards New Zealand. (2009). AS/NZS
60079.14 - Explosive atmospheres Part 14: Electrical installations
design, selection and erection. Sydney: SAI Global Limited.
Standards Australia/Standards New Zealand. (2003). AS/NZS 4114.1 - Spray
painting booths, designated spray painting areas and paint mixing rooms
Part 1: Design, construction and testing. Sydney: Standards Australia
International Ltd.
Standards Australia/Standards New Zealand. (2003). AS/NZS 4114.2 - Spray
painting booths, designated spray painting areas and paint mixing rooms
Part 2: Installation and maintenance. Sydney: Standards Australia
International Ltd,.
Standards Australia/Standards New Zealand. (2007). AS/NZS 3000 Wiring
Rules. Sydney: SAI Global Limited.
Standards Australia/Standards New Zealand. (2007). AS/NZS 3017 - Electrical
installation - Verfication guidelines. Sydney: Standards Australia.

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