PIC/S Interpretation of Annex 1 - Clarifying or Confusing? Pt 3
This is the final part of a three part article on the new PIC/S Recommendation (PI 032). The Recommendation interprets the changes to Annex 1 of the PIC/S GMP Guide. In this part, we look a few minor issues arising from the publication.
There are a few other points in the interpretation which I feel have the potential to cause confusion. These aren’t so significant, but warrant a mention to raise awareness.
- In section 12 the Annex confirms that sample sizes for monitoring do not need to be the same as for classification. The PI 032 interpretation quite rightly points out that needing to sample a full cubic metre before activating an alarm is problematic, especially in Grade A zones. The implication, of course, is that significantly smaller sample sizes are appropriate where fast response is required.
With that in mind, the use of the phrase “sampling of 1 m3 … could be inadequate” is potentially misleading, insofar as the word “inadequate” implies not enough, when really it is too much. A more suitable term to avoid confusion would have been “inappropriate”.
- The inconsistency between sections 34 and 116 was raised in part 2 of this article. If you are unsure about which section to follow, obviously the safer and more advisable route is to stick to section 116 and avoid the use of sealed transfer trays.
In itself this issue is barely worth mentioning, but with PI 032 implying that section 12 is now superseded, it seems that the carryover of section 34 has not been noticed by the reviewers or interpreters.
Additionally, the interpretation states that section 116 is “basically equivalent” to the old section 12, yet there is a very important distinction. There is no provision in the new section for transfer in sealed containers, and it would be impossible to meet this stated requirement using sealed containers, as Grade A airflows cannot be met.
- On a positive note, I should mention that I had some issues with the PI 032 interpretation of clause 121, however, the revision PI 032-2 has largely addressed those concerns. Originally the document could be interpreted to suggest that you could mitigate an ineffective rejection system by improving the quality of the background environment. The revision clarified these comments to put the emphasis on monitoring and the degree of human intervention required in the rejection system.
Finally, it should be noted that there are 20 or so interpretations in the PIC/S recommendation and I have highlighted 4 or 5 which I think could be reworked to varying degrees. The remainder generally provide sound advice, clarity and definitions that the user can employ with confidence.
However, the issues raised should be addressed by PIC/S – especially those covered in parts 1 and 2 of this article. Given that PIC/S was prepared to issue version 2 only a month after version 1, let’s hope that version 3 may not be too far away.PIC/S Interpretation of Annex 1 - Clarifying or Confusing? Pt 2
