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Martin#1  
#1 Posted : 31 May 2012 10:49:52(UTC)
Rank: Forum user
Martin#1

Our company has some air pressure equipment that needs to be inspected (every 26 months). I'm looking to find an example of a written scheme of examination that I can use as a benchmark for what we should have in place. The equipment is maintained and serviced internally with records kept of this but I just want to make sure that we are capturing the correct information and recording it properly.

Thanks

Martin
Jane Blunt  
#2 Posted : 31 May 2012 10:57:30(UTC)
Rank: Super forum user
Jane Blunt

The company that carries out the inspections usually provides these. They may impose a charge if you have lost one and need a duplicate issuing.

Who inspects your equipment according to the written scheme? In many premises this will be the engineering inspection arm of an insurance company.

Maintenance and service do not cover the same ground.
Martin#1  
#3 Posted : 31 May 2012 11:10:31(UTC)
Rank: Forum user
Martin#1

quote=Jane Blunt]The company that carries out the inspections usually provides these. They may impose a charge if you have lost one and need a duplicate issuing.

Who inspects your equipment according to the written scheme? In many premises this will be the engineering inspection arm of an insurance company.

Maintenance and service do not cover the same ground.


all inspections of equipment are carried out by our own staff, there is a scheduled program in place, does this constitute a written scheme?
Jane Blunt  
#4 Posted : 31 May 2012 11:20:27(UTC)
Rank: Super forum user
Jane Blunt

Martin#1 wrote:

all inspections of equipment are carried out by our own staff, there is a scheduled program in place, does this constitute a written scheme?


Not in my book.

Do you have any lifting equipment? Who inspects that?
JJ Prendergast  
#5 Posted : 31 May 2012 11:22:11(UTC)
Rank: Super forum user
JJ Prendergast

PSSR HSE ACOP has a section on the recommended qualifications/qualifications for engineers to write WSEs. Depends on the size of your pressure system if it is called as Minor or Major.

Usually inspection and routine servicing is carried out by separate organisation / engineers.

This is so there is sufficient independence / lack of bias when completing the Statutory Inspections.
JJ Prendergast  
#6 Posted : 31 May 2012 11:24:06(UTC)
Rank: Super forum user
JJ Prendergast

Sounds like at best poor engineering practice. Without knowing more, can't really say if you have a sufficient WSE, but on the evidence so far, it doesn't sound like it
Jane Blunt  
#7 Posted : 31 May 2012 11:25:59(UTC)
Rank: Super forum user
Jane Blunt

Looking at the ACOP to the Pressure Systems Safety Regs 2000, referring to the section ib Reg 8 we have the following:

Competent persons for minor systems (not greater than 20 bar and not greater than 100 000 bar litres)

At least one member of staff at incorporated engineer level with adequate relevant experience and knowledge of the law, codes of practice, examination and inspection techniques and understanding of the effects of operation for the system concerned.

Access to basic design and plant operation advice, materials engineering and non-destructive testing facilities.

It can be done in-house.
Jane Blunt  
#8 Posted : 31 May 2012 11:27:21(UTC)
Rank: Super forum user
Jane Blunt

Sorry, PV product less than 200 000 bar litres.
Martin#1  
#9 Posted : 31 May 2012 11:32:54(UTC)
Rank: Forum user
Martin#1

quote=JJ Prendergast]PSSR HSE ACOP has a section on the recommended qualifications/qualifications for engineers to write WSEs. Depends on the size of your pressure system if it is called as Minor or Major.

Usually inspection and routine servicing is carried out by separate organisation / engineers.

This is so there is sufficient independence / lack of bias when completing the Statutory Inspections.


maybe I'm over simplifying this but I looked at it like Portable Appliance Testing, if you have a qualified electrician employed they can carry out PAT for the organisation. In this case we have an engineering department who are working with pressure equipment (pumps up 20,000 psi) and they are suitably qualified to carry out the written scheme of examination
Jane Blunt  
#10 Posted : 31 May 2012 11:39:06(UTC)
Rank: Super forum user
Jane Blunt

Martin#1 wrote:


maybe I'm over simplifying this but I looked at it like Portable Appliance Testing, if you have a qualified electrician employed they can carry out PAT for the organisation. In this case we have an engineering department who are working with pressure equipment (pumps up 20,000 psi) and they are suitably qualified to carry out the written scheme of examination


In my experience, employers with their own engineering department, NDT facilities etc usually have the insurance company do this inspection. It needs to be unbiased and independent.

If you have no-one in your department who has experience of drafting written schemes of examination I would suggest that you are not ready to do this for yourselves. Borrowing someone else's is not a good idea.

These inspections are a statutory requirement, PAT isn't.
JJ Prendergast  
#11 Posted : 31 May 2012 12:16:24(UTC)
Rank: Super forum user
JJ Prendergast

A little simplistic to look at PSSR Statutory Inspections as per PAT thinking.

Its entirely up to you to justify in-house engineers writing WSEs (as per the ACOP requirements) and having sufficient independence to undertake Statutory Inspections separate from routine servicing of pressure systems.

Not saying you are right or wrong, from the information given.

Its not the pressure alone that dictates who can write a WSE.

As Jane says its the PV calculation - hence the energy potential of a pressure system, if it were to fail which is important.

simon_gb  
#12 Posted : 31 May 2012 12:25:19(UTC)
Rank: New forum user
simon_gb

Surely, as well as the independent and un-biased factors of the thorough examination, are there not also insurance considerations? Would your insurer require that an approved agent of theirs undertook the 26-monthly examination? Might conducting the examination or writing the WSE yourself negate any insurance in the event of a system failure? Would the insurer lower their premium once the good condition of the system is verified?

Personally, I'd be contacting my insurer, and asking the hard questions first before contemplating a work-around.
JJ Prendergast  
#13 Posted : 31 May 2012 12:30:16(UTC)
Rank: Super forum user
JJ Prendergast

Guess that would be in the details of the insurance policy.

As it stands, it is permissable to write internal WSEs, provided the ACOP is complied with.

By the fact the question is being asked, raises an eybrow as to the validity/independence of WSEs and associated Statutory Inspections IMHO.
Garfield Esq  
#14 Posted : 01 June 2012 13:31:10(UTC)
Rank: Super forum user
Garfield Esq

Surprised your IC has not stipulated a WSE by a competent person/organisation in the first place, indeed they usually offer to provide this (at a cost). The issue of being unbiased is irrelevant, it is the competence that is key.

JJ Prendergast  
#15 Posted : 01 June 2012 13:36:13(UTC)
Rank: Super forum user
JJ Prendergast

The issue of being unbiased is irrelevant, it is the competence that is key.



Totally disagree - being unbiased/independent when undertaking Statutory Inspections is recognised good engineering practice.

Andrew W Walker  
#16 Posted : 01 June 2012 13:43:08(UTC)
Rank: Super forum user
Andrew W Walker

JJ Prendergast wrote:
The issue of being unbiased is irrelevant, it is the competence that is key.



Totally disagree - being unbiased/independent when undertaking Statutory Inspections is recognised good engineering practice.



I agree with JJP.

The LOLER ACoP mentions "the competent person is sufficiently independent" when undertaking an inspection. I can't se why it would be different for pressure systems.

Andy
Andrew W Walker  
#17 Posted : 01 June 2012 13:46:36(UTC)
Rank: Super forum user
Andrew W Walker

Taken from the Pressure ACoP

40 Where the competent person is a direct employee of the user’s/owner’s organisation, there should be a suitable degree of independence from the operating functions of the company. In particular, where the staff are provided from an in-house inspection department and carry out functions in addition to their competent person duties, they should be separately accountable under their job descriptions for their activities as competent persons. They should act in an objective and professional manner with no conflict of interests and should give an impartial assessment of the nature and condition of the system.

Andy
Rob M  
#18 Posted : 01 June 2012 14:21:54(UTC)
Rank: Forum user
Rob M

What i would have done is get a firm in to give you a quote and a schedule of works. That way you get it done for you for free
Jane Blunt  
#19 Posted : 01 June 2012 14:33:08(UTC)
Rank: Super forum user
Jane Blunt

Rob M wrote:
What i would have done is get a firm in to give you a quote and a schedule of works. That way you get it done for you for free


I think it unlikely that a company will prepare a written scheme of examination for you before you have agreed to pay them.
Jim Tassell  
#20 Posted : 01 June 2012 15:55:06(UTC)
Rank: Forum user
Jim Tassell

Martin

I'm still troubled as to why you, or any of your engineers, would really want to take on this responsibility for yourselves. All points above about competency, independence and terms of insurance policies are valid. Even so, where would you rather be after an incident? Option one is producing an independent inspection report and your records to confirm resulting actions on any points raised then getting on dealing with the aftermath. Option two is this plus putting your staff under a lot (and after a major incident I mean a lot) of pressure from investigations by both HSE and your insurers that will divert them from dealing with the aftermath. It's not a legal point per se but it is a vital business continuity and stress one. Leave it to the guys who really are competent, do this sort of work daily and who have the back-up of the engineering inspection bodies so that your engineers can get on with their day jobs.
JJ Prendergast  
#21 Posted : 01 June 2012 18:17:08(UTC)
Rank: Super forum user
JJ Prendergast

A modern, well maintained pressure vessel has a typical catestrophic failure rate estimated to be in the region of 1:100000/yr

However, there are more likely failure modes to consider



Garfield Esq  
#22 Posted : 01 June 2012 19:00:11(UTC)
Rank: Super forum user
Garfield Esq

Totally disagree.

It is entirely reasonable and legal for users to work up their own WSE. There is HSE guidance widely available on how to do this.

Being 'unbiased' in this regard is irrelevant. Being competent to do so is relevant.

I am referring to the actual question and not providing a 'general commentary' on the matter of carrying out the requirements of the WSE, which others appear to being doing quite a good job!



JJ Prendergast  
#23 Posted : 02 June 2012 00:30:01(UTC)
Rank: Super forum user
JJ Prendergast

See my earlier post, I said that it is/can be acceptable to write your own internal WSEs - provided you follow the PSSR Acop and have suitably qualified and experienced engineers.

The recognised good engineering practice is to have an independent engineer to actually carry out the physical inspections/carry out the NDT/NDE so that any results are then presented and reported in an unbiased way.

Ie writing the WSEs and the actual statutory inspections are separate and distinct tasks.

In my 20+yrs of being involved in mechanical engineering, I have yet to see a company write their own WSEs and/or carry out their own statutory inspections. I'm not sure why this is, probably a combination of following good engineering practice to have an independent engineer do it, 'too hard' to do, commercially not worth it, lack of qualified engineers, it's easier to let the insurance company do it.
Garfield Esq  
#24 Posted : 02 June 2012 11:26:01(UTC)
Rank: Super forum user
Garfield Esq

jj prendergast wrote:
See my earlier post, I said that it is/can be acceptable to write your own internal WSEs - provided you follow the PSSR Acop and have suitably qualified and experienced engineers.

The recognised good engineering practice is to have an independent engineer to actually carry out the physical inspections/carry out the NDT/NDE so that any results are then presented and reported in an unbiased way.

Ie writing the WSEs and the actual statutory inspections are separate and distinct tasks.

In my 20+yrs of being involved in mechanical engineering, I have yet to see a company write their own WSEs and/or carry out their own statutory inspections. I'm not sure why this is, probably a combination of following good engineering practice to have an independent engineer do it, 'too hard' to do, commercially not worth it, lack of qualified engineers, it's easier to let the insurance company do it.



I have seen the odd WSE done by in-house enginneers, however most appear to be completed and implemented by insurance companies...It really depends on the complexity of the system and the competence of the engineer.
JJ Prendergast  
#25 Posted : 02 June 2012 13:05:18(UTC)
Rank: Super forum user
JJ Prendergast

Thats ok then, just reporting that I have never seen it done.

But the fact that they still get the insurance company to actually do the statutory inspections, maintains the key good practice of independent oinion.
JJ Prendergast  
#26 Posted : 02 June 2012 13:06:20(UTC)
Rank: Super forum user
JJ Prendergast

opinion, even!!

Garfield Esq  
#27 Posted : 02 June 2012 13:09:14(UTC)
Rank: Super forum user
Garfield Esq

JJ Prendergast wrote:
opinion, even!!



Have a good weekend!
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