MSIR – Schedule 3
Anyone responsible for managing classified plant on a mine site will be familiar with MSIR 1995 Schedule 3. For those unfamiliar, this section of the MSIR 1995, details the “Maximum periods of inspection of registered classified plant”, including pressure vessels. Schedule 3 lists the maximum period of inspection for pressure vessels as 3 years. However, the regulations also state that pressure vessels shall be inspected in accordance with AS/NZS 3788. This is where it gets tricky, as the inspection intervals in AS/NZS 3788 do not necessarily align with the periods stated in MSIR Schedule 3. Many sites default response is to just go by schedule 3, which is potentially costing them big $$ in terms of inspections and maintenance down time. We at Rapallo decided to dig a little deeper and ask DMIRS directly to confirm our understanding of how the regulations should be applied.
Although Schedule 3 mandates that any registered vessel operating on a mine site must be inspected every 3 years, it does not detail the type or extent of inspection required. As such the only requirement to comply with schedule 3 is that the appointed competent person ensures the vessel is adequately assessed for fitness for continued service until the next scheduled inspection at each 3-year interval.
As Schedule 3 does not outline the required inspection activities, the activities required to determine whether a vessel is fit for continued service is completely up to the discretion of the competent person or inspector. They may choose to rely on the reports of the most recent inspection, utilize NDT reports in the past, or potentially complete an entirely new inspection if they believe it is necessary. Essentially, the appointed section 44 competent person must demonstrate with reasonable confidence the vessel is suitable for continued use and record the details of their inspection activities and the result in the classified plant record book.
As stated above, pressure vessels on West Australian mine sites need to be inspected in accordance with AS/NZS 3788. Unlike schedule 3, AS/NZS 3788 does contains specific inspection requirements. Inspections planned in accordance with AS/NZS 3788 must be physically completed and documented, and the activities specified within the standard must be completed. However once risks associated with the equipment are considered, the AS/NZS 3788 inspection periods are highly flexible when compared to schedule 3, and this is where your improvements in safety and cost come into play. If you want to learn more about compliance with AS/NZS 3788, read this blog post, which applies to all pressure vessels in Western Australia (on a mine site or not).
If you would like to know more about inspection periods for pressure vessels, need to have your vessels inspected, would like assistance with setting up your inspection schedule or want to determine if your vessels are suitable for risk-based inspection, please contact a Rapallo team member using the form below.
