Is A Short Australian Hazardous Area Course Really Enough to Ensure Overseas Staff Can Build Compliant Hazardous Area Packages to Australian Standards?
The purpose of this article is to provide insight into some of the issues commonly faced when importing hazardous area vendor packages. It is no secret that overseas vendors have faced significant hurdles when importing equipment into Australia for use in the Oil and Gas sector. The cause of these issues is multi-faceted, this article seeks to exam one of the common issues in the vendors quality management chain ‘Competency of Staff’.
Competency of Personnel
Anyone involved in the design, selection, erection and initial inspection of electrical installations for use in a hazardous area in Australia must be competent. The requirements for competency of these personnel are listed in AS/NZS 60079.14:2017 Clause 4.5. In summary this clause gives a number of ways to establish the competency of staff, it requires that the design of the installation, the selection of equipment, the erection and inspections of electrical equipment should only be carried out only by persons whose training has included instruction on the various types of protection and installation practices, relevant rules and regulations and on the general principles of area classification.
The level and competence and instruction must be relevant to the role of the operative concerned and the operative must have continuing education and training to ensure competency is maintained.
This competency can be proven or managed in a few ways such as:
• Basic work may be carried out under the supervision of a senior person with a higher level of competence, or
• Training and certification to the IECEx CoPC scheme with ANZ endorsement, or
Note: The ANZ endorsement is to ensure workers understand local installation rules, regulations and industry quality benchmarks.
• Training and assessment to the AS/NZS 4761.1 standard, or
• Competency may also be obtained or demonstrated without formal training or assessment, e.g. through ‘on the job training and by completion of compliant installations.
All of the methods for establishing competency listed above have merit provided they are implemented correctly, and their limitations understood. However, when the determination of competency of staff is viewed as an administrative, or box ticking exercise and not as a critical first step in the quality and compliance management chain things begin to unravel.
So Why Do We Still Have Issues?
The answer to the question is not a simple one and cannot be covered entirely in this article but nevertheless we will try and cover the main issues.
The first issue to raise is that the competency of the person must be relevant to the type of work to be undertaken. This is the first issue in establishing competency, the role of the personnel must be understood to ensure an appropriate level of training and assessment is delivered. Establishing the competency of a factory worker undertaking a single, supervised task repeatedly is an entirely different prospect to establishing the competency of the engineering and design team and as such requires different training and assessment strategies.
The other issue that is often overlooked is that training packages developed for the Australian market in almost all cases assume prior electrical knowledge working to Australian standards. When these packages are delivered overseas some issues start to immerge. These packages are usually focused entirely on hazardous area specific compliance leaving a huge gap in knowledge relating to other critical Australian standards such as AS/NZS 3000, AS/NZS 3008 and AS/NZS 3100. This lack of underpinning knowledge of other Australian standards can undermine the overall competency of staff even if they been assessed under the IECEx CoPC or AS/NZS 4761.1 framework.
The issues already mentioned can be compounded by underestimating the time required to establish competency. Under the Australian training framework, we refer to this as the ‘volume of learning’. The volume of learning identifies the notional duration of all activities required to achieve the learning outcomes of the course including all teaching, learning and assessment activities. Put simply, the volume of learning defines the complexity of a proposed course. Allowing enough time to train and quickly assess people is only one part of the issue. Sufficient time must also be given to allow staff to understand and demonstrate the required skills and knowledge but also to ensure they retain the information in the long term. This usually requires delivering key pieces of information on multiple occasions using variety of delivery techniques and this takes time.
Another key issue that is often overlooked and misunderstood is how rigidly the Australian hazardous area and electrical standards are applied as well as minimum industry expectations for workmanship. It is often the case that designers and staff have selected the correct equipment and even understood its hazardous area functions but have then failed to install and terminate it correctly. When establishing competency of staff, they need to understand not only the hazardous area compliance requirements but also have a detailed understanding of Australian quality and workmanship benchmarks expected by the Australian Oil and Gas industry in order to avoid costly quality mistakes. When it comes to quality and compliance in the Australian Oil and Gas sector near enough is not good enough.
Understanding that establishing the competency of staff is not an administrative process, but rather a vital part of the quality and compliance chain is the first step in ensuring packages imported for use in Australia are compliant. Having the appropriate pieces of paper should not be seen as a box ticking exercise but should be seen as a critical first step in ensuring compliance. The small upfront cost for ensuring appropriate training and assessment is delivered, combined with job specific verifications of competency is easily offset by the savings resulting from equipment being designed and built correctly the first time.
Contact Lithium Oil and Gas today to find out how we can help tailor training to your needs as well as help verify the competency of staff working on equipment bound for Australia.