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Update on COCs for electric geysers

On 24 June 2022, the requirement to issue a Certification of Compliance (COC) for electric geyser installations was amended and therefore the requirement to issue COCs fell away, having been being deleted from SANS 10254.

“It is important to understand that COCs are still required for solar geysers and heat pumps in terms of other SANS codes: solar geysers SANS 10106 and heat pumps 1352 which haven’t changed. Consequently, there is still a requirement for the COC on those types of installations,” explains IOPSA executive director Brendan Reynolds.

He notes that furthermore, industry bodies such as insurance companies, municipalities, manufacturers, government departments, property managers and some consumers still demand the issue of a COC due to the credibility and accountability it confers on an electric geyser installation. Often, they insist one be issued.

“Therefore, a COC issued to verify that a geyser, heat pump and solar water heater installation is performed according to the relevant SANS standards would be of enormous comfort to the consumer to know the plumbing work is done to standard, especially given that in large areas of the country the building regulations do not catch this factor. This means that any consumer, anywhere in the country and irrespective of the state of his local authority, can have the reassurance that a plumbing job has been done safely by insisting on the plumber issuing a COC. It is a verification that the plumber at least knows what the regulations require and gives the consumer recourse if the plumbing has not been done to standard,” says Reynolds.

New legislation on the horizon

“A further development is that the Department of Trade, Industry and Competition (DTIC), the Departments of Labour, and of Water and Sanitation are in consultation to possibly include the requirement for a COC in some form of legislation in the future. Therefore, the chances are strong that the requirement for a COC will come back into force through some other regulation. Another important point to note is that PIRB audits of COCs issued will continue to be done as normal,” says Reynolds.

Since that removal of the requirement for a COC, matters have been progressing, explains Reynolds. “We’ve since seen no change in terms of the numbers of COCs being issued and requested – it’s remained consistent. This is not what we expected to happen: we expected those numbers to drop quite a lot and then find a stable level. But it just stayed exactly the same. This implies that anyone who ever wanted a PIRB-audited COC still wants one, which points to the COC as being well received as adding value. Although we’re still accumulating statistics, we know that some insurance companies, municipalities and developers are still asking for the PIRB-audited COC. This has been an extremely interesting development. It’s equally interesting that plumbers would still want to issue a COC, with the reason being that it’s obviously about showing themselves to be a professional plumber. It’s a way to differentiate yourself from the unqualified plumber and to show you’re upstanding and doing the job correctly.

“However, there are other people in the industry that are now offering a version of the COC – and these have no legal status. In fact, no COC has any legal status anymore, except to the degree it’s audited by the PIRB.

“The PIRB-audited COC retains credibility, with its code of conduct requiring ethical behaviour – there is an organisation behind it that reviews and audits the job. I believe that the plumber, the consumer and the business person are going to have to make a decision as to whether to have no COC, or if they want one then as to whether they opt for the PIRB-audited COC or one from a different organisation which isn’t worth the paper it’s written on.

“Common sense dictates to go with the PIRB-audited COC that has some substance behind it – that’s going to have real meaning. And I think the reason why the COC numbers have stayed the same is because people understand there’s real substance to the PIRB COC,” says Reynolds.

IOPSA had earlier made a statement of the removal of the requirement for a COC from SANS 10254: “The protracted process of amending SANS 10254 was completed on 24 June 2022 when the revised standard was gazetted. The only changes to the standard from the 2017 version were the removal of the requirement for a certificate of compliance and the removal of the reference to the professional body for plumbers PIRB. All other installation requirements remain the same.

Although SABS has decided that requirements for CoCs will be removed from all standards for all industries, the requirement for a CoC on solar water heaters, heat pumps and grey water systems will remain in force until such time as these standards are updated. We strongly encourage all plumbers to adhere to the requirements of these standards.

IOPSA supports the need for a certificate of compliance (CoC)

In the absence of any other adequate mechanism to ensure compliance to the plumbing laws, regulations, and standards the CoC has proved to be the most effective tool available. The reality is that most municipalities do not have the capacity, skills, or funding to enforce compliance. This includes organs of state as well. The plumbing industry has been flooded by unqualified people doing plumbing work, non-compliant materials, and incorrect, dangerous installations. The impacts on homeowners’ health & safety, the environment, water security and damage to municipal infrastructure has been massive. Not to mention the impact on the formal plumbing sector which has declined every year since 2016, slowly being swallowed by the unregulated informal sector. The only CoC which currently has any meaningful impact is the PIRB CoC. If, in future, another CoC or some other mechanism emerges which can protect the public and qualified plumbers, IOPSA would consider supporting it too.For now, there is only one and without it (or something similar) our industry is in serious trouble. Irrespective of changes to SANS 10254, we still encourage all members to continue issuing CoCs as this brings trust and professionalism to the industry and sets you apart from unqualified people operating in the industry.

Of significant importance is that plumbers in the replacement market continue to notify clients of pre-existing non-conformances, in writing. This requirement of the Consumer Protection Act is critical in ensuring that owners are properly informed and can make an informed decision, while protecting plumbers from liability for work they did not do.

IOPSA supports the need for a professional body for plumbers

If we as an industry want the recognition that plumbers so rightly deserve as a successful professional career, then a professional body is very necessary. A professional body brings more to the table than a voluntary association and is subject to scrutiny by SAQA in terms of the NQF Act. Not only does a professional body raise the awareness of professional plumbers but it ensures that those plumbers act professionally and that the public can rely on them. Now PIRB is the only SAQA recognised professional body for plumbers, hence IOPSA’s ongoing support. It must be noted that the support is conditional and IOPSA regularly challenges PIRB on a range of matters. If, in future, another recognised professional body for plumbers is established IOPSA will certainly consider them too.

A certificate of compliance through a government department

It is important to understand that likely there will soon be a requirement for a CoC in some or other form, through one or more of the government departments. Several government departments have already recognised the impending crisis that will unfold (and in some cases is already unfolding) if there is no mechanism to enforce the standards. Some of these departments are at an advanced stage in their deliberations and we are hopeful that they will be concluded soon.

The PIRB CoC will remain available.

The PIRB CoC has been available for more than a decade. It was only after the benefits of the CoC became known that it was first incorporated in a SANS standard in 2014. The PIRB has assured IOPSA that the CoCs will remain available for use and will be supported by IOPSA. Plumbers, consumers, and all other parties will still be able to benefit from the value and more importantly the protection brought by the CoC.

There is ample evidence that South Africa’s water and sanitation situation is in real trouble. Plumbers obviously play a massive role in this sector and ensuring that there is compliance to the regulations and standards is critical. The effects that unqualified people doing plumbing work, non-compliance, sub-standard materials, and poor plumbing practices are having on the country and our industry are well documented and unless we collectively do something to stem the tide, we will all face profound consequences. IOPSA is determined to do whatever it can to protect its members and ensure that this situation is not allowed to continue.”

Written by Eamonn Ryan

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