Chemical engineers are essential to the optimum performance of many factories.
Appointing a chemical engineer as an engineering manager in factories is sometimes expected. The appointee may be responsible for ensuring machine/system performance, Occupational Health & Safety (OHS) Act compliance, and OHS Act regulations compliance.
It is not strange to see chemical engineers taking responsibility for mechanical/electrical maintenance and operation (M&O) activities. Sometimes they are appointed as GMR 2.1 and charged with the duties defined in the General Machinery Regulation 2. However, the GMR 2.1 appointment of chemical engineers need to comply with the General Machinery Regulations (GMR).
The purpose of this post is to present the specific requirements for chemical engineers looking to fill the GMR 2.1 role.
What is a GMR 2.1 appointment?
South African factories, just like many other workplaces, are required to comply with the OHS Act. Section 8(1) of the OHS Act requires employers to protect their employees' health and safety.
OHS Act Section 8(2) further elaborates on the employer's specific duties and what measures they need to protect employees' health and safety.
One of the employer's requirements is to ensure there is the supervision of machinery. But, what does the supervision of machinery mean?
To answer questions on how employers should ensure compliance with the OHS Act requirements, Section 43 gives the Minister of Employment and Labour the authority to promulgate regulations. The regulations support the OHS Act's provisions.
A regulation that attempts to define supervision of machinery is the General Machinery Regulation (GMR).
The GMR 2.1 stipulates that the employer must appoint a competent person to supervise machinery. Supervising machinery means that the competent person must ensure that the premises and machinery are compliant with the OHS Act and its other regulations.
The chemical engineer appointed as a GMR 2.1 must be a competent person.
Note: Premises and factories are interchangeable terms in this context.
What are the requirements of a competent person?
A competent person's requirements depend on the sum of the power generated by machinery in the premises. For instance, the minimum requirements of the competent person at different power outputs are as follows:
0 to 1200 kW: Qualified artisan or five years M&O practical experience + Minimum of one year experience in the maintenance and operation of machines relevant to the class machinery he/she needs to supervise.
1200 to 3000 kW: Artisan with minimum N5 in mechanical/electrical engineering + Minimum of two years experience in the maintenance and operation of machines relevant to the class machinery he/she needs to supervise.
Above 3000 kW (Option 1): Graduate engineer + Minimum of two years experience in the maintenance and operation of machines relevant to the class machinery he/she needs to supervise + Passed GCC Factories OHS Act exam.
Above 3000 kW (Option 1): Certificated Engineer (i.e., must be in the position of the GCC Factories)
What do the requirements of a competent person mean to a chemical engineer?
The GMR defines a graduate engineer as any person who has obtained:
a degree in mechanical or electrotechnical engineering at a South African university, or
a degree recognised by the Department of Higher Education as equivalent to any such degree. In other words, a degree equivalent to a degree in mechanical or electrotechnical engineering.
Is a chemical engineering degree equivalent to a mechanical/electrical engineering degree? It will be difficult to argue that.
An option for a chemical engineer is to become Certificated Engineers by:
obtaining a GCC Factories acceptance letter from the Department of Employment and Labour (DOL),
writing and passing the GCC Factories plant engineering and OHS Act exams, and
get issued the Certificate of Competency in mechanical/electrical.
Once achieving these requirements, the chemical engineer may assume the GMR 2.1 role for any premise since they qualify for the maximum power output.
Note: The chemical engineer must accept the GMR 2.1 only when they have experience in the maintenance and operation of the class of machinery they are to supervise and have obtained the GCC Factories.
What must a chemical engineer do to obtain the GCC Factories acceptance letter from the DOL?
All persons wishing to obtain the GCC Factories mechanical/electrical must write and pass the prescribed exams. You need to obtain permission from the DOL to write the GCC Factories exams.
The DOL grants permission to write the GCC Factories on the following basis:
Must be at least 23 years of age
Must have the relevant qualification in mechanical/electrical
Must have the relevant experience in mechanical/electrical machinery maintenance and operation
The DOL Commission of Examiners does consider other qualifications other than mechanical or electrical engineering qualifications. The consideration of these qualifications will be done on merit by the Commission of Examiners.
The chemical engineering qualification falls under the "other qualifications."
The chemical engineer must have their qualification evaluated by the Department of Higher Education & Training (DHET) for the Certificate of Competency mechanical or electrical. You must include certified copies of the statement of results certified and qualification.
Theoretically, the DHET will indicate what additional subjects, if any, must be passed to comply with the requirements for acceptance.
The Department of Employment and Labour has confirmed that:
"...all the applications are sent and evaluated at DEL and only foreign qualifications are sent to SAQA to determine their NQF level."
This means that chemical engineering applicants must send their qualifications to the Department of Employment and Labour until further notice. Only persons with foreign qualifications need to send their qualifications to the South African Qualifications Authority to determine the equivalent South African qualification for their foreign qualification.
Conclusion
The GMR does not have the chemical engineering qualification as an "acceptable" qualification for the GMR 2.1 appointee. It leaves the chemical engineer with the option of becoming the Certificated engineer by completing the following steps:
Obtain permission from DOL to write the GCC Factories exams,
Write and pass the GCC Factories plant engineering and OHS Act exams, and
Obtain the GCC Factories from the DOL.
Another possible option is obtaining an exception from the Minister. This is allowed in terms of GMR 2(11) but it is a long shot.
It is essential at this point that you review:
The above will help get a better understanding of the requirements and bring you one step closer to getting your Government Certificate of Competency (GCC) factories letter of acceptance from the Department of Employment and Labour.
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