Correcting Errors in Expired Ex Certificates
When a documentation error is found in a current ANZEx or IECEx certificate of conformity that renders Ex equipment effectively non-compliant, the conventional approach to resolution is for the manufacturer to seek a supplementary certification to correct the error. A recent case notified through ExTA is one such instance. In that case, the error was clearly one of documentation (only), with no impact on the type-tested product or compromise of safety.
However, what is the situation where a documentation error is found in an AusEx certificate?
All certificates issued under the AusEx Scheme (bar one) are now expired. However, the ANZEx Certification Scheme website advises that:
“Since the Certificate relates to the product and manufacturing, it logically follows (and is intended by the Scheme) that the Certificate expiry relates to manufacturing and not to events beyond manufacturing. An AUSEx Certificate is therefore deemed valid for a product as long as there is evidence that manufacturing was completed prior to Certificate expiry."
Since the AusEx scheme is considered closed, with certificates of conformity expired, it was arguably not possible to issue a supplementary certificate to correct a documentation error (even if that error had existed while the certificate was current).
To do nothing renders all affected equipment non-conforming, and typically not able to be deployed in hazardous areas, even though the safety of such equipment is not called into question.
A recent case concerning an AusEx certified Ex ‘d’ coupler challenged the industry, since no precedent existed for such a situation. The prevailing industry view was that no mechanism existed to rectify the error.
The responsibility for managing the certificate of conformity rests with the issuing Certifying Body (CB), who also own the certificate. In this instance, the CB looked to the operating procedures of the IECex scheme, where precedents for these situations do exist.
Ultimately the CB concluded that the expired AusEx certificate could be corrected for errors, without necessitating a formal supplementary certificate. That decision, has in effect created a local precedent that upholds the rigor of the national Ex schemes and provide a practical resolution of an unforeseen problem.