< Previousbmta.co.uk The challenge going forward is for the country to be prepared for the next time a crisis of this nature occurs. There is an enquiry scheduled in 2022 on the pandemic response, promising to examine all the circumstances and actions in the handling of the crisis. However, given the time such enquiries take, BSIF calls on the government now, to design and publish a PPE Strategy to enable the timely provision of adequate and suitable PPE for frontline and emergency services without billions of pounds being wasted and the safety marketplace polluted with non-compliant and potentially dangerous PPE. This Strategy must create a workable set of contingencies involving the appropriate regulators and experienced PPE manufacturers, along with approval bodies and logistics experts. As a minimum, a task force should be in place including but not limited to, OPS&S, BEIS, HSE, MHRA, an empowered representative of Trading Standards and the BSIF. In this way, a plan can be ready and on the shelf to provide a rapid reaction for PPE security. What lessons have we learned? We learnt that the UK was unprepared for the pandemic and that it appeared the authorities did not understand PPE. The existing stock was inadequate and reactive supply attempts were disorganised and chaotic, with much of the stock brought in not fit for purpose. We learnt that a great deal of non-compliant, unsafe PPE was able to be placed on the UK market with the authorities often apparently incapable of stopping it. This was not news to BSIF, but the exaggerated volumes highlighted the problem with dramatic effect. However, we also learnt that ultimately where there is enough publicity, the authorities will take an interest in ensuring that PPE is fit for purpose. A dedicated technical team headed by the HSE triaged 20incoming shipments of PPE purchased directly by the Government on behalf of the NHS and Healthcare and the HSE also established a Product Safety Market Surveillance Unit and was then actively engaged in PPE market surveillance and intelligence gathering. Many of the HSE team involved at the time have since been re-directed onto other activities. We learnt that the legislators, the market surveillance authorities and the institutions of this country did not have adequate PPE knowledge but with the direction and focus created by the crisis they will seek training and input. BSIF provided access to the content of our Safe Supply Qualification modules on Product Standards and Certification. The learning provided by BSIF was used by OPS&S and the Chartered Trading Standards Institute (CTSI) to help their field officers. We learned or had re-enforced, the ease by which bogus products are sold via the internet, with the market surveillance authorities impotent to stop it. Furthermore, the authorities appear content to stand behind the “safe harbour” defence of portals taking no responsibility for the PPE their platforms promote. Ultimately the PPE crisis of 2020 will be seen as a moment in time but the problem of non- conforming PPE continues and will continue until the enforcement of the applicable Regulations is effective. PPE was a significant priority in 2020, a topic central to the political challenge of the time. It no longer is. However, the country must be prepared for the next pandemic and in the context of PPE, it must have a robust strategy in place. So what can be done? We have already laid out what needs to happen on the strategic pandemic response level, but events of the pandemic highlighted the problem of product compliance we encounter every day in the safety industry. Action must be taken to protect those that rely on PPE in the general market. PPE is critical to wearer safety and goes far wider than the narrow range of Covid related PPE. The Regulation must be enforced and users kept safe in the short term and have their long term health protected. Achieving more resources and a transformation in approach by the authorities seems unlikely to happen, but some simple actions will produce disproportionately strong results in the battle against unsafe non-compliant PPE being placed on the UK market. The non-compliant PPE will exist in the supply chain prior to its sale for occupational use and the problem should be addressed, in that supply process, prior to it reaching the wearers. Trading Standards have the experience of dealing with traders and in a wide range of supply chains, HSE does not have a history of involvement or access to suppliers. BSIF believes that Trading Standards must be the primary enforcement authority for PPE. This document was written in its full article during the latter stages of 2021 after some of the dust had settled around the PPE crisis created by the Covid-19 pandemic. The British Safety Industry Federation (BSIF) is the UK Trade Association for the Safety Industry, whose members include the manufacturers, importers, distributors and specialist service providers in personal protective equipment (PPE) and associated safety apparatus. BSIF was established in 1994 and since that time has been providing leadership and authoritative information on a wide range of workplace safety issues and representing the needs of the UK market and the country’s workforce. It is our mission to support all businesses in the UK that help to keep people safe and healthy at work and we are passionate that safety and health are universally recognised for what they are – a positive force for good. BSIF works closely with the Health and Safety Executive and Trading Standards with whom we have Primary Authority partnership. BSIF is the UK’s leading association for the Personal Protective Equipment (PPE) Regulation 2016/425 and provides guidance for PPE compliance, working closely with Regulators and is active across a range of Government departments. bmta.co.uk 21bmta.co.uk FACILITY UPGRADE INVESTMENT REDUCES UNCERTAINTY AND FINANCIAL EXPOSURE Dr Carl Wordsworth, Head of Water Sector, TÜV SÜD National Engineering Laboratory 22 TÜV SÜD National Engineering Laboratory (NEL) has recently completed a £650,000 upgrade of its Elevated Pressure and Temperature (EPAT) test facility, funded by the UK Government’s Department for Business, Energy and Industrial Strategy (BEIS) as part of the UK’s National Flow Programme. NEL originally invested £1 million to create the EPAT test facility, which allows customers to test equipment at close to field conditions and replicate the effect of high pressure and temperature on instrument performance. In 2016 it was awarded ISO/IEC 17025 accreditation, making it the first and only high-pressure, high-temperature facility in the UK to hold this internationally recognised certification. Previously, the standard practice for calibrating flow meters for the oil and gas industry was to match the fluid viscosity and, if possible, the fluid temperature and pressure. However, matching all parameters was seldom possible due to the limitations set by a calibration facility’s operating range and available test fluids. Industry, therefore, had to rely on testing flow meters at ambient conditions in a laboratory, even though they would be deployed at elevated conditions in the field. bmta.co.uk 23 To ensure optimum performance, end users now demand a meter calibration that is closer to service conditions, delivering high accuracy and low uncertainty flow measurements. Furthermore, in Issue 9 of its Guidance Notes for Petroleum Measurement under the Petroleum (Production) Regulations 2014, the Oil and Gas Authority (OGA) stipulated that temperature and pressure compensation applied to any meter between its calibration conditions and its operating conditions must be “agreed in advance with OGA” and must be “traceable and auditable”. Recreating in-field service conditions NEL’s EPAT test facility is a traceable flow laboratory that enables operators, meter manufacturers and end users to recreate conditions that are more closely matched to those experienced in the field. By operating across a range of temperature, pressure, flow rate and viscosity conditions, the effects of these factors can be determined more effectively to ensure that flow meters are more closely matched to process conditions and measuring accurately in the field. These more realistic measurements reduce oil and gas operators’ financial exposure as the uncertainty of meters deployed in the field is minimised significantly. This latest upgrade to the EPAT test facility greatly improves operability and incorporates NEL’s FlowStudio, an interface and calculation engine for effective data capture and live uncertainty determination. A new in-line heater will also enable the automation of process control. Optimising data FlowStudio is NEL’s in-house data acquisition and traceability management software, which offers advanced configuration and collection of data for engineers conducting tests on the UK’s national flow facilities. Furthermore, FlowStudio performs real-time engineering and uncertainty calculations, and assists with the management of quality critical instrumentation with associated traceability data, thereby serving to minimise the cost of providing traceability to the UK’s national flow facilities. FlowStudio can be pre-configured with a matrix of testing conditions that allows the software to automate the execution of tests. The test matrix includes acceptance criteria to allow for automated validation of the data. The outputs and calculations can also be pre-configured allowing the software to produce a full draft certificate of calibration automatically. Giving industry confidence The EPAT test facility’s loop is a unique, purpose-built flow meter calibration and evaluation facility, having two separate flow lines that cover a wide range of flow rates in different line sizes. Offering great flexibility, the facility can allow a large selection of flow meter sizes to be calibrated at service conditions. The test sections can be constructed to offer long, straight lengths upstream or specific configurations designed to replicate actual installations. The loop can operate at pressures up to 100 bar(g), flow rates up to 100 l/s, and temperatures up to 80°C. The facility can calibrate flow meters at temperatures between 20°C and 80°C, at flow rates between 0.5 and 100 l/s, and at fluid pressures between 4 and 93 bar(g). bmta.co.uk 24 Muir Porter, Head of Facility Operations at TÜV SÜD National Engineering Laboratory, said: “This additional investment in our EPAT test facility is an important step, as it will give both our UK and international customers confidence that their meters have been independently assessed and that all of the measurements it makes are traceable and auditable. Oil and gas production is increasingly taking place in fields where high temperatures and pressures are the norm. The EPAT facility more effectively fills the gap between calibration and real field conditions, allowing manufacturers to prove the performance of their meters, while operators and taxation authorities can be assured of more accurate fiscal reporting.” NEL is the Designated Institute for Flow and Fluid Density Measurement, under contract from BEIS, and part of the UK’s National Measurement System. The EPAT upgrade is part of a wider programme to refurbish existing flow measurement standards at NEL’s laboratory to address the future needs of flow measurement in the UK. About TÜV SÜD National Engineering Laboratory www.tuvsud.com/en-gb/nel The company is a global centre of excellence for flow measurement and fluid flow systems and is the UK’s Designated Institute for Flow and Density Measurement, with responsibility for providing the UK’s physical flow and density measurement standards. TÜV SÜD National Engineering Laboratory is a trading name of TUV SUD Ltd, a company of the TÜV SÜD Group, an international service organisation. More than 24,000 employees work at over 1,000 locations in about 50 countries to continually improve technology, systems and expertise. They contribute significantly to making technical innovations such as Industry 4.0, autonomous driving and renewable energy safe and reliable. bmta.co.uk 25 If you are reading this newsletter and would like to become a member of the BMTA, please send an email to enquiries@bmta.co.uk, requesting a membership application pack. Enquiries about associate and individual membership should also be addressed to enquiries@bmta.co.uk. Membership of the Association is open to all organisations in the measurement, testing and calibration industry. We encourage senior people in organisations to become individual members, and organisations to become corporate members. BECOME A MEMBER Our membership fees are based on the size of your organisation making it affordable to the smallest company. Take a look at our website to discover the benefits of BMTA membership: www.bmta.com DEDICATED TRADE LISTING Build your brand credibility and trust from our dedicated trade listing. KEEP YOUR FINGER ON THE PULSE Help your business stay ahead of the game by receiving full access to the regular updates on the latest industry news and information. INFORMATION AND INSIGHT Access to surveys, reports, forecasts, market information, whitepapers and the latest guidelines that may impact upon your business and industry. 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Here are some of the things BMTA can do for you: TO FIND OUT MORE ABOUT BMTA MEMBERSHIP PLEASE CLICK HERE TO SEE OUR WEBSITE FOR DETAILS.bmta.co.uk INTER-LABORATORY COMPARISONS (ILCS), PROFICIENCY TESTING (PT) AND MEASUREMENT AUDIT (MA) IN ACCREDITATION Paul Greenwood, UKAS Operations Director 26 Why is inter-laboratory comparison important? The objective for any organisation performing testing activities is to ensure that results are fit for their intended purpose. Quality assurance is fundamental in supporting robust analysis and there are a wide variety of processes and procedures that calibration, test and inspection bodies can implement to provide confidence in their data. Accuracy reflects how close a measurement is to a known or accepted value, while precision reflects how reproducible measurements are, even if they are not close to the recognised value. Measurements that are both precise and accurate are repeatable and very close to true values. Internal quality control procedures provide important information on both the accuracy and precision of a test but can be limited by factors relating to the environment in which the test has been conducted. In an ideal world, results generated by one competent laboratory will be directly comparable to those produced by another for the same parameters on the same items. Many laboratories operate in isolation from other laboratories however and do not have ongoing opportunities to compare their data with others.bmta.co.uk 27 Inter-laboratory comparison is the organisation, performance and evaluation of tests on the same or similar test items by two or more laboratories in accordance with predetermined conditions. Participation serves the purpose of validating the capability of a laboratory to provide accurate and reliable results within permissible levels of uncertainty and therefore ensure that the adopted analytical method is suitable for the intended purpose. In summary, it provides independent verification of laboratory competence. So where does Proficiency Testing fit in? Many people use the terms “inter-laboratory comparison” and “proficiency testing” interchangeably, but proficiency testing can be more accurately described as the evaluation of participant performance in inter-laboratory comparisons by an independent third party. The addition of independent oversight of the ILC process brings clear benefits in many ways. For example: • Laboratories can remain anonymous from each other so that participants can take part in the same scheme without fear that a competitor could use any performance issues to undermine them. • When issues arise with laboratory performance, these can be quickly identified and investigated. Opportunity is then available for technical discussions with independent, competent scientists employed by (or under contract to) the PT provider. • When issues arise with the comparison exercise itself, these too can be quickly identified and rectified by the PT provider. ARE YOU LOOKING TO UNDERTAKE AN ILC? BMTA is evaluating the viability of creating a new, industry-led, inter-laboratory comparison service to assist you in meeting your accreditation obligations. If this would be of interest, our short survey, accessed HERE, will take no more than two minutes to answer and will provide us with a better understanding of your ILC requirements.bmta.co.uk 28 • Trends in performance can be highlighted and used by participants (and often the technical sector in general) to improve the quality of testing or identify issues in analysis. • • Proficiency testing providers (PTPs) are often accredited to confirm their competence to organise, conduct and evaluate ILCs. Accredited providers are recognised against the requirements of international standard ISO/IEC 17043:2010. This standard is currently under review for revision, probably within the next 12-18 months. Measurement Audit Historically, many areas of calibration were not well covered by appropriate PT schemes. As a result, UKAS created a “measurement audit” assessment tool which provided an independent means by which laboratories could demonstrate competence by calibrating UKAS-owned artefacts with known parameters. While it does give an independent perspective on competence, measurement audit does not constitute an inter-laboratory comparison because the results are compared against known reference values rather than data produced by other laboratories. During the Covid pandemic, it was not possible to access the UKAS measurement artefact storage facility or distribute artefacts for calibration and the mechanism became dormant. Now that the restrictions imposed during the pandemic are being relaxed, UKAS has reviewed the ongoing viability of reinstating the measurement audit function and has reached a conclusion to stop offering the service because of the alternative mechanisms that have developed in the interim. As a result of that decision, UKAS policy document LAB 46 (UKAS Policy for Participation in Measurement Audits and Interlaboratory Comparisons) is currently under review and revision and will be reissued shortly.bmta.co.uk 29 The requirement for participation The general requirements that testing and calibration laboratories must meet if they wish to demonstrate that they operate to a management system, are technically competent and are able to generate technically valid results are contained within ISO/IEC 17025:2017. ILAC document P9/06:2014 (currently under revision to reflect the requirements of ISO/IEC 17025:2017) also specifies ILAC policy requirements on laboratories and accreditation bodies in relation to proficiency testing activities. Section 7.7 of ISO/IEC 17025:2017 requires that laboratories shall plan and undertake quality assurance procedures for monitoring the validity of tests and calibrations undertaken. This shall include participation in interlaboratory comparison or proficiency testing programmes where available and appropriate. As part of its routine assessment programmes, UKAS will review participation in external quality assurance to ensure any selected schemes are appropriate to the items being tested or calibrated and that the frequencies of participation are suitable. Additionally, in the absence of such participation, the laboratory can justify its approach or use of alternative mechanisms. It is worth bearing in mind at the outset when considering an application for accreditation that UKAS policy will remain that before accreditation is granted for any measurement, there must be at least one instance of satisfactory participation in an appropriate ILC or equivalent activity. If no such audits or ILCs are available, the laboratory will need to put additional quality assurance activities in place or arrange their own inter-comparisons with another laboratory. UKAS experience is that this requirement for satisfactory participation in ILC can often lead to significant delays in obtaining accreditation while applicants wait for a suitable scheme to become available and then wait for the outcomes of the exercise. Going forwards, there is mounting interest in the development of “Rapid PT” which is where a PT provider sends out an unknown, well-characterised test sample (often a CRM) for which the assigned (certified) value is already known, so as soon as the laboratory send back their result a performance evaluation can be provided (in a similar manner to Measurement Audit). There are many pros and cons to this mechanism (not least the lack of comparability with other laboratories and whether this fits within the requirements of ISO/IEC 17043:2010 but on the plus side, the speed and ease with which fitness for purpose can be evaluated) and the laboratory committee (LC) of the European Co-operation for Accreditation (EA) is working in conjunction with the EA, Eurolab and Eurachem proficiency testing working group (EEE-PT WG) to determine the suitability and benefit of such Rapid PT (or Quick Response) events. ARE YOU LOOKING TO UNDERTAKE AN ILC? BMTA is evaluating the viability of creating a new, industry-led, inter-laboratory comparison service to assist you in meeting your accreditation obligations. If this would be of interest, our short survey, accessed HERE, will take no more than two minutes to answer and will provide us with a better understanding of your ILC requirements.Next >