Thanks.
During our stage-1 audit, the same answer was given to the auditor, but he was not satisfied and stated that the Factories Act and Rules have mentioned only a generalised scope for pressure vessels, but there are separate safety acts/rules which were not identified and complied, as far as safety is concerned.
I have gone through the following regulations but could not come to any conclusion as to which act/rule can be applicable to our type of organisation where we have 1 pressure vessel only to store compressed air:-
The Factories Act, 1948
Indian Boilers Regulations, 1950
The Gas Cylinder Rules, 2004
The Static and Mobile Pressure Vessel (Unfired) Rules, 1981
Please help
Minrah
IMO the auditor has unnecessarily taken a lot of burden on himself.
As a minimum, he must specify:
a) What was the requirement that wasn't identified and complied?
b) What was the evidence of failure?
There are no separate safety acts/ rules especially for Pressure Vessels other than what you mentioned here. In your case only the Factories Act/ Rules apply. See the definition of a pressure vessel applicable for
Static & Mobile Pressure Vessel rules :
"pressure vessel" means any closed metal container of whatever shape, intended for the storage and transport of any compressed gas which is subjected to internal pressure and whose water capacity exceeds one thousand liters...........
and the one that applies to
Factory Rules
“pressure vessel” means a vessel that may be used for containing, storing, distributing, transferring, distilling, processing or otherwise handling any gas, vapour or liquid under pressure greater than the atmospheric pressure and includes any pipeline fitting or other equipment attached thereto or used in connection therewith;
Compressor air receivers are stationary equipments and thus form part of a pressure plant.
Further, section 3 of the SMPV Rules state
Nothing in these rules shall apply to vessels which form part of a process plant. For the purpose of this rule, vessels forming part of a processing plant shall mean vessels which contain, as a process requirement, a compressed gas received from the consumed in the same processing plant, provided that the water capacity of the vessel(s) shall be such that the gas stored therein at the maximum working pressure shall not exceed the requirement for feeding the consuming point(s) for a period not exceeding 16 hours at the designed flow rate.
Gas Cylinders Rules only apply to 'cylinders'
“Gas Cylinder” or “Cylinder” means any closed metal container having a volume exceeding 500 ml but not exceeding 1000 litres intended for the storage and transport of compressed gas, including any liquefied petroleum gas (LPG) container/compressed natural gas (CNG) cylinder fitted to a motor vehicle as its fuel tank but not including any other such container fitted to a special transport or under-carriage and includes a composite cylinder, however, the water capacity of cylinders used for storage of CNG, nitrogen, compressed air, etc. may exceed 1000 litres up to 2500 litres provided the dia meter of such cylinder does not exceed 60 cm;
Indian Boilers Regulations are specific to (fired) 'Boilers' only.
Still you can ask the auditor to cite the rules he thinks are applicable in this instance or he still needs training on Indian EHS legislation.
Thanks
