The National Regulator for Compulsory Standards (NRCS) held a consultation meeting with IESSA representatives and other stakeholders on 3 November 2016 for further discussions on the Draft Compulsory Specification for Electric Luminaires (VC 9012).
This followed on the previous stakeholders’ meeting on 6 July 2016 where it was decided that the NRCS would engage with the Department of Trade and Industry (DTI) on the way forward regarding the scope of the compulsory specification, and that the final draft would be circulated to all stakeholders for comment before promulgation. The engagement between the DTI and NRCS resolved that a consultative meeting with key role players be convened to discuss the scope of this regulation further. These role players would include municipalities which were not part of the previous consultations.
IESSA was represented by council member and official VC 9012 spokesperson Daniel Kasper; IESSA Technical Committee chairperson Sekwanele Kubeka, as well as by myself. In addition, Connie Jonker and representatives from the NRCS, DTI, City Power and the SABS Lighting Technology Laboratory also participated.
A new draft compulsory specification was circulated for discussion on 20 October 2016. This document differed significantly from the draft discussed at the previous stakeholder meeting. The scope no longer referred to luminaires used by “ordinary persons”, but now covered all luminaire types including street lights.
In terms of scope, one participant argued that all luminaires would comply with the national standard in accordance with the requirements of Section 55 of the Consumer Protection Act and that there was therefore no purpose in discussing the scope of the compulsory specification . This was not the view put forward by IESSA.
A phase-in period for all exclusions in the current VC 8055 specification was also discussed. IESSA added this provision in response to the possibility of an amended scope and stated that a period of at least 24 months was required.
Also discussed was the removal of power factor specifications for luminaires and their replacement with a statement that the calculated value would be sufficient but should be covered in the type-test report or marked on the label (with a maximum tolerance of 10%), removing the requirement for a test certificate to prove compliance.
The meeting concluded that standards issued by different standardisation bodies such as ISO and EN would only be accepted if it is proven, in the form of a declaration report from an accredited conformity assessment body, that they are technically equivalent to the relevant South African National Standard or an equivalent IEC standard.
Participants from the lighting industry requested that the efficiency of the administrative process for issuing Letters of Authority (LOAs) be discussed. This was added to the agenda, but it was understood that the NRCS and DTI representatives were not authorised to make binding decisions regarding the LoA administrative process.
Also raised were the long service turnaround time and backlog; the volume of applications to be added once VC 9012 is promulgate; cost implications and time delays due to the SABS Product Testing laboratory’s termination of partial testing, and the significant cost burdens to lighting companies, especially SMMEs.
Implementation of VC 9012 will be severely problematic unless these challenges are addressed quickly and efficiently.
The NRCS representatives are responsible for preparing the proposed final draft from the input received during this consultation meeting for stakeholder comment prior to submission for ministerial approval.
IESSA will respond to the NRCS formally, with comments both on the proposed compulsory specification drafted by the NRCS after the stakeholder meeting, as well as with corrections to the minutes. I have arranged for the deadline to be extended to 31 January 2017. IESSA members were invited to submit comments on the proposed compulsory specification through an online survey. The input received will be used to draft the formal IESSA response.
The way forward
To ensure an effective solution for all stakeholders, it is imperative that the lighting industry engage with the relevant public entities on the VC 9012 and the efficiency of the LoA process in a unified and determined, yet systematic and professional manner. IESSA is leading this process on behalf of its members. This includes regular consultation and feedback opportunities for members, through both events and the electronic media.
IESSA is pursuing, with the relevant authorities, the efficiency of the administrative process for issuing a LoAs and the suitability of this process for its intended purpose. In doing so, it is necessary for the society to reference reliable statistics regarding the negative of impact the current LoA system on the lighting industry and on how the implementation of the proposed VC 9012 will further impact the lighting industry. IESSA has undertaken to draft such a report and the procedure for collating the data with input from members and other sources has been approved by Council at its meeting on 15 November 2016.
I assure members on behalf of Council that IESSA is pursuing relentlessly all reasonable avenues to resolve these matters to the benefit of our industry and without compromising the interests of the public at large. I urge members to support Council constructively in this endeavour by responding to surveys and calls for participation in committees or working groups throughout the process.
Contact Sue Swash, IESSA, Tel 011 476-4171, email@example.com