Operation of Chemical Process Automation Control Instruments – The Issue of DCS Engineers Working Without Proper Certifications
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During one of the DCS circuit tests conducted by our company, which is a hazardous chemicals enterprise, the task was carried out by a DCS engineer (who holds a certificate issued by the DCS manufacturer and is primarily responsible for DCS configuration and maintenance) and an instrumentation electrician (who possesses a certification for working with chemical automation control instruments). According to the procedures in place, both individuals had to sign the test records. The DCS engineer was responsible for monitoring the circuit conditions in the control room and keeping records, while the instrumentation electrician carried out the on-site testing. The safety supervision department deemed it necessary for both individuals to have the appropriate certifications; therefore, it was determined that the DCS engineer might face penalties for working without the required certification! We explained to the safety officers that the maintenance of the instruments on site is carried out by certified personnel, and that DCS engineers are only responsible for monitoring the situation at the control panel and keeping records. However, the safety officers insisted that everyone must be certified, or at least that only certified persons should sign off. (The DCS recorder does not sign.) Could everyone help figure out if there is a way to show that the regulation regarding working with a valid license was not violated?
I’m from Qinghai; for DCS-related positions, I have certificates for working with instruments, and some of us also have certificates as intermediate engineers. During inspections in the key counties, no issues have been raised.
The certificates issued by DCS manufacturers are not valid documents
Of course not. Working with chemical automation instruments is a type of special job; just like electricians and welders, those who work in this field need to obtain safety certificates recognized by the safety supervision authorities.
Then the basis for imposing a fine upstairs is problematic
There was no mention of any basis upstairs either; the safety inspection concluded that there were no issues, and the person who signed off on the work records identified them as workers! It is considered a major safety hazard when special operation personnel work without proper certification.
According to the job procedures, the test records require signatures from two persons: the DCS engineer is responsible for monitoring the circuit conditions in the control room and making records, while the electrical and instrumentation staff carry out the on-site tests. The safety supervision department believes that both individuals need to hold relevant certificates; therefore, it is likely that the DCS engineer will be penalized for working without a valid certificate!
Is there a problem? DCS engineers are classified as personnel working with chemical automation instruments, and they need to hold a special operation permit; working without such a permit is illegal. What’s the problem here? The wording is vague, so it’s up to the law enforcement officers to make the decision. You say it’s not the case, but you still sign the records, and the safety supervision department uses those records as evidence. DCS engineers are professionally trained by DCS manufacturers, and they are certainly capable of passing those simple questions in the safety inspection; yet the fact that they haven’t taken the exam and obtained a certificate serves as a basis for authorities to enforce regulations against them.
As clearly stipulated in Article 9.16 of the list of special operations outlined in Order No. 30 issued by the State Administration for Work Safety, titled \"Regulations on the Management of Safety Technology Training and Assessment for Special Operations Workers\", the work related to chemical automation control instruments (i.e., the installation, repair, and maintenance of such systems) is classified as a special operation
As clearly stipulated in Article 9.16 of the list of special operations outlined in Order No. 30 issued by the State Administration for Work Safety, titled \"Regulations on the Management of Safety Technology Training and Assessment for Special Operations Workers\", the work related to chemical automation control instruments (i.e., the installation, repair, and maintenance of such systems) is classified as a special operation