DE Comments to ExMC/866/CD
Draft OD XXX
September 2013
This document is submitted to the 2013 ExMC Fortaleza Meeting contains German Comments relating to Draft Operational Document, ExMC/866/CD and is tabled as a meeting Document for the ExMC Fortaleza meeting.
IECEx Secretariat
This document, prepared by the IECEx Executive is a proposed new Operational Document to assist with the implementation of the new IEC Standard IEC 60079-33 (Ex s)
The information given in this draft OD and the requirement given in IEC 60079-33 does not real fit together.
The OD should be corrected to align with IEC 60079-33.
Following some examples to highlight the differences and to demonstrate that work is required on the OD
1.independent verifier
Requirement given in IEC 60079-33
a) an assessment should be performed by independent certification bodies (as the
independent verifier) according to the requirements in this standard before issuing a
certificate of conformity;
b independent verifier
person or organization, with the appropriate competency in the applied explosion protection
methodology, responsible for the verification of design calculations, assessment and testing
who are separate and distinct by management and other resources including financial, from
the person or organizations responsible for all the activities associated with the design,
manufacture or sales of the equipment
c ). It is anticipated that considerable dialogue is required between the
manufacturer and an independent verifier. Additional tests may be required by an independent
verifier to ensure the relevant level of safety is achieved.
Requirements given in ExMC 866 CD
ExCBs shall maintain a current list of Verifiers as Verifier 1, 2, 3 within their own Training records as part of a Competency or Task Matrix Table. This matrix shall be reviewed as part of the IECEx peer assessment process
Accordingly the project shall be allocated for certification management purposes to an individual who has standards development experience in the most applicable concept for the equipment.
The appointed ExCB project manager shall ensure that the work of any engineer is closely monitored in line with knowledge of developments in standards and related discussions.
Where a second or third verifier is required, the appointed ExCB project manager shall select an individual who is independent but also has standards development experience
Open issues and questions.
The procedure is different from the requirements given in IEC 60079-33. With the project manager who selects the verifiers no independents is given.
IEC 60079-33 requires that the manufacturer will be involved in the process. This is not given.
IEC 60079-33 requires that verifier 1, 2, and 3 are independent. In the OD ALL verifiers can be in ONE CB and the process will be handled by ONE project manager
2. Competence……………..
Requirement given in IEC 60079-33
The process of verification is critical to the correct application of special protection “s” and
this requires that the independent verifier shall be able to demonstrate the following
knowledge and skills:
.
.
.
in-depth specific knowledge of the technique or method being assessed;
The independent verifier shall
a) obtain a detailed knowledge of the technique or method being proposed,
Requirements given in ExMC 866 CD
ExCBs shall maintain a current list of Verifiers as Verifier 1, 2, 3 within their own Training records
Accordingly the project shall be allocated for certification management purposes to an individual who has standards development experience in the most applicable concept for the equipment.
The appointed ExCB project manager shall ensure that the work of any engineer is closely monitored in line with knowledge of developments in standards and related discussions.
Where a second or third verifier is required, the appointed ExCB project manager shall select an individual who is independent but also has standards development experience
Open issues and questions.
The procedure is different from the requirements given in IEC 60079-33.
With fixed verifiers not knowing the technique of a product it cannot be ensured that the required competence is given.
Draft 2013_09_06
Gerhard Schwarz