By Andre Wagener, Chairman, Highveld Region Executive Committee

About two years ago, when I considered the possibility of expanding my company’s operations to include PV installations, I did some investigation to find out what qualifications I needed and what training would I have to undergo to design and install PV.

It was frightening to discover that there were no accredited PV courses; they were all industry led and the quality control was done by individuals within the industry and not against a set standard. Simply put, there was no set standard for PV installation qualifications.

At that time, the ECA(SA) did not offer a PV course and I approached the South African Photovoltaic Industry Association (SAPVIA) and did the GreenCard Training that they offered through one of their service providers.

I first did the five-day Super Solar Course, after which I completed the two-day assessment to qualify as a GreenCard Installer. I later did a course for commercial PV design up to 1 MW and also attended the two-day PV course, which the ECA(SA) had subsequently introduced.

During this time, I realised there were huge issues within the PV Industry, which can be summarised in two areas:

1. There is no industry norm when it comes to qualifications. There are several training providers that offer courses and issue ‘certificates’, but there is nothing that can be called an actual qualification so, in other words, there is no such thing as a qualified PV designer/installer.
2. Anyone can install PV installations because (Both in the OHS Act or SANS 10142-1) it is regarded as an ‘appliance’. The law (as above) does cover the PV installation (Domestic and large-scale Commercial) and this ties in with what is covered in NRS 097-2-1:2020, which, in short, is:
   1. Design on larger Installations must be done by an electrical technologist or engineer.
   2. The electrical interrogation/tie-in can only be done by a registered person such as an Installation Electrician (IE) or a Master Installation Electrician (MIE).
   3. The Certificate of Compliance (CoC) can only be issued by a registered person such as an IE or a MIE.
   4. The electrical installation work must be carried out by a registered electrical contractor. 6(1).
   5. Any PV work that is designed and installed must be under the general control and supervision of a registered person.

I feel strongly about compliance and as an electrical contractor and ECA(SA) committee member, I saw the need for the ECA(SA) to get involved in accredited PV training and establish an industry standard.

I did some more research and, based on my dealings with SAPVIA, which I regard as a leader in the PV industry, it became obvious that as the two largest role players in the PV and electrical industry space, SAPVIA and the ECA(SA), should be talking to each other to drive home the necessity of introducing accredited training and qualifications.

I believe that most electricians would like a law that would make it illegal for anyone other than Registered Electrical Contractors to undertake PV installations. Currently electrical contractors are excluded when it comes to working outside of the point of supply and related equipment so the reality is that this installation work cannot be reserved for electrical contractors only, although Electrical Contractors are the only ones who can issue the CoC’s.

Should we look at inviting the Department of Employment and Labour to become involved and drive the legislation that would see that only PV installation companies, registered with the DoEL would be permitted to undertake PV installations?

It would make sense to classify small scale embedded generator systems as under 10 kVA; under 1 MVA; and above 1 MVA. The levels are in the NRS 097:2 and tie in with the requirements in the General Machinery Regulations (GMR).

No person may use components within an electrical installation unless those components comply with the standards referred to in the relevant incorporated standard referred to in sub-regulation (1), and proof of compliance shall be identifiable on the components or certification shall be available from the manufacturer or supplier of the materials or components in terms of the National Regulator for Compulsory Specifications Act, 2008 (Act NO.5 of 2008).

Under 10 kVA: Design of PV system/installation can be done by a registered electrician with a PV qualification.

Under 1 MVA: Design of PV system/installation can be done by a technologist. (technician with a PV qualification)

Above 1 MVA: Design of PV system/installation can be done by an Electrical Engineer (with a PV qualification)

The exact qualifications above are still to be determined.

As stated earlier, a CoC can only be issued by a registered person such as an IE or a MIE for an installation that was done under his/her general control. I have seen some electricians connecting a PV installation and/or issuing a CoC even though the electrical tie-in was done by the PV installation company! Even scarier, I have seen an incident where the client refused to employ an electrician to do the electrical work and issue the CoC because he didn’t want to pay an ‘additional cost’. This raises more concerns:

• The law states that any electrical work undertaken must have a CoC covering the work done, however, it is important to note that the CoC would only cover the selection and application of conductors and components and not the actual components as per the Electrical Installation Regulations (EIR); regulation 5(2) and 1.4 of SANS 10142-1, which state that the electrical contractor is responsible for the parts between the machinery and the tie -in – not the equipment.
• Electricians who undertake to just sign a CoC for other people’s work is legalising illegal work. Clause 5.4 of the EIR covers “general control” and if electricians would stop this illegal practice, it would be a major step in eradicating illegal ‘pirate’ contractors.
• Many of the CoC’s I see for PV installations are, in fact, non-compliant so I believe that the issuing of CoC’s for PV installations should only be done by IEs and MIEs who are qualified and certified in PV, which would reduce the number of illegal CoC’s being issued.

So where do we stand currently? As tasked by the Highveld Regional Technical Committee in 2019, I have facilitated talks between the ECA(SA) and SAPVIA. The ECA(SA)’s National Director, Mark Mfikoe has endorsed this initiative and the Association is currently involved in talks and working with the Skills Development committee and a PV Green Card Steering Committee, which SAPVIA has put together not only to reform the PV Green Card, but to also finalise recognised qualifications within the PV industry.

This is only the start. There are good people who are doing great things for the PV Industry but much of it is being done independently. I believe the ECA(SA)’s role is not to re-do or replace anything that has already been done, but rather to bring everyone together and combine our knowledge and resources to set qualifications and define industry norms.

Since the ECA(SA) and SAPVIA are talking, the DOEL has taken notice and we would like to invite other Associations to get involved and not just SAPVIA, this way we will have a better chance in getting our point across to the DOEL and get the appropriate legislation in place.

The ECA can play a pivotal role in the future of PV by broadening its scope and, together with other leading role players, facilitate the introduction of PV industry-specific qualifications and training so that the electrical work on PV installations is put into the safe hands of specialised electrical contractors.

The ECA invites other role players within the PV industry to contact us so that together, we can make the PV industry safer.

More info: andre@gpaelite.com

anthony.schewitz@ecasa.co.za

Published in the May-June 2021 issue of SA Electrical Contractor

©ECA(SA) 2021

Article used with kind permission of the ECA(SA) www.ecasa.co.za