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Manufacturers Legal Obligations in Terms of

the Mine Health and Safety ActMine Health and Safety Act (Act 29 of 1996)

AA COUTINHO

Director Mine Safety

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Manufacturers Product Scope Declaration (TCF)(SANS 551:2009 Ed1. Detonators, relays and explosives initiating devices for

commercial applications)

Validation of the suitability of the product for the intended application inaccordance with the Product Data supplied in the Manufacturers Product

Catalogue. It would be expected that the Manufacturer should advise the

User in writing if the Product is inappropriate for the application

contemplated by the User.

Review and agree the expected Product Performance criteria as warranted by

the Manufacturer and required by the User in the agreed application

environment

Failure of the Product to deliver quoted levels of performance could possibly

lead to claims by the User against the Manufacturer (CPA)???

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Section 21 (of the Act)

Manufacturer's and Supplier's duty for Health and Safety

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Section 21 (of the Act) contd

Manufacturer's and Supplier's duty for Health and Safety

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Section 21 (of the Act) contd

Manufacturer's and Supplier's duty for Health and Safety

(i) the use of the substance;

(ii) the risks to health and safety associated with the substance; (

(iii) any restriction or control on the use, transport and storage of the

substance, including but not limited to exposure limits;

(iv) the safety precautions to ensure that the substance is without risk to

health or safety, (v) the procedure to be followed in the case of an accident involving

excessive exposure to the substance, or any other emergency involving the

substance; and

(vi) the disposal of used containers in which the substance has been stored

and any waste involving the substance.

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Documentation to be provided by the Manufacturer

Regulatory certification of the Product, or Generic Group of

Products Product Risk Assessment

Comprehensive User Instructions

Specific Safety Precautions

Training Manuals-including pro-forma lesson plans and testsThe information provided must be of such a nature that the User

(Responsible appointed Manager ) is able to compile a Risk

Assessment ;Codes of Practice; and Training Programs; as

required by the Mine Health and Safety Act Section 11

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Product Risk Assessment(SANS 551:2009 Ed1. Detonators, relays and explosives initiating devices for

commercial applications)

Risk assessments are required for all new products and can also be requiredfor previously authorized products that have been changed or otherwise

modified.

For previously authorized products the risk assessment could be limited to

investigation of the effects of the proposed changes.

The objective of a risk assessment is to show that no fault or failure mode in

the construction or operation of an explosive, detonator, or initiator, will

compromise the safe handling of the device and its system in any way.

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Product Risk Assessment contd(SANS 551:2009 Ed1. Detonators, relays and explosives initiating devices for

commercial applications)

In cases where an electric or electronic detonator is initiated by a product-specific

control and initiation system, the risk assessment shall include the test equipment, the

control system and the electrical or electronic system as a whole including, for example

hardware, software and firmware in accordance with

BS EN 61508-1.

The risk assessment shall state the inherent safety of the test, the programming,

logging, and tagging, the inherently safe test equipment used in close proximity of the

blast, and the safety interlocked blast equipment.

Practical steps that shall be addressed in any risk assessment of IDs and IDSs, as well as

the examination of all conceivable causes of faults and failures that are typical to

blasting operations.

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9

Product Risk

Assessment(Specific Responsibility of

the Manufacturer)

Technical

Construction File:(In accordance with

Standards)

ARP 1717:2010: Guide to the regulatoryrequirements for the approval of detonators,

initiators and initiation systems used in

mining and civil blasting applications

SANS 551:2009 Ed1. Detonators, relays and

explosives initiating devices for commercial

applications

Completion of all required Technical testing in

compliance with National or International

Standards:- Verified by competent inspection

authority or qualified subject matter expert

References:'Technical Construction

File''User Instructions'

Comprehensive User

Instructions:

(In respect of the installation

and operation of the

Equipment or Product)

Deployment of the Product

Handling of Misfires

Disposal of Waste/Old Explosives

Schematic of the Product Risk Assessment

Process

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Closing Summary /Key Points

Consumer Protection Act Implications

Manufacturers compliance with MHSA

Section 21 and Hazardous Substances Act

Product Risk Assessment

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Questions

Thank you for listening