The GMR 2(1) Appointment Is a Leadership Role That Requires More Than Technical Competency
In South Africa, mechanical and electrical engineering graduates have several career paths, each with its own professional development pathway. One such path is as a competent person appointee under General Machinery Regulation 2(1) of the Occupational Health and Safety Act (OHSA) Section 43 regulations. We refer to this appointment as the GMR 2(1) appointee.
The GMR 2(1) is a legal appointment that carries significant responsibility for ensuring machinery does not cause harm to persons and complies with the requirements of the OHSA, regulations, and standards.
However, becoming a GMR 2(1) appointee requires more than obtaining an engineering qualification and the Government Certificate of Competency (GCC Factories). It also requires relevant practical experience, an understanding of applicable legal requirements, and leadership competency to establish and manage systems that ensure machinery remains compliant.
In this article, I will explain:
the legal context of the GMR 2(1),
GMR 2(1) role and responsibilities as stipulated in the OHSA and GMR,
the GMR 2(1) qualification and competency requirements,
the link between the GMR 2(1) and the Engineering Council of South Africa (ECSA),
the importance of leadership and continuing professional development, and
possibly help you decide if the GMR 2(1) is the right career path for you.
The legal basis of the safe use of machinery can be traced back to the Constitution of South Africa.
The South African Constitution establishes the Republic of South Africa as a sovereign, democratic state and serves as the supreme law of the land. Any law or conduct inconsistent with it is invalid.
The Bill of Rights under Chapter 2 of the Constitution is the cornerstone of democracy and anchors the core constitutional values of human dignity, equality, and freedom listed in Chapter 1.
A Bill of Rights provision relevant to this article is Section 24(a), which stipulates that “Everyone has the right to an environment that is not harmful to their health or wellbeing…”
Various Acts of Parliament make provision for ensuring that everyone’s right to an environment that does not harm their health or wellbeing is protected in different situations.
For persons at our workplaces, the Occupational Health and Safety Act (OHSA) is established to “provide for the health and safety of persons at work and for the health and safety of persons in connection with the use of plant and machinery…”
The question then arises:
Who must ensure that the health and safety of persons at work is protected?
How must they ensure this?
What happens when they don’t do what they must?
The employer is responsible for protecting the health and safety of persons at work, and the CEO has overall management and control.
The employer is the essential stakeholder responsible for protecting the health and safety of persons at work. The OHSA defines an employer as any person who:
employs or provides work for any person and remunerates them (OHSA 1(1)), or
is vested and charged with the control and supervision of an employee (OHSA 1(2)).
OHSA 16(1) requires the appointment of a Chief Executive Officer (CEO), who is responsible for the overall management and control of the business and must ensure that the employer's duties are fulfilled. In essence, the CEO must ensure compliance and execution of every matter where the OHSA says “the employer shall”
The employer's duty to ensure safe use and general supervision of machinery is assigned to the GMR 2(1).
The CEO can’t be everywhere, do everything, know everything, and be competent in everything.
OHSA 16(2) allows the CEO to assign any employer’s duty to any person under the CEO's control and direction.
The respective regulations further detail how the employer’s duties are assigned. For instance, the General Machinery Regulations (GMR) require the appointment of a competent person who shall ensure that “the provisions of the Act and the GMR in relation to machinery are complied with…”
We refer to this competent person as the GMR 2(1) appointee. The GMR 2(1) is basically a legal appointment made in terms of the General Machinery Regulation 2(1), and they assume the overall responsibility of ensuring that the machinery in the premises of the employer is safe for use and complies with the OHSA as well as applicable regulations and health and safety standards.
The GMR 2(1) is essentially an assignment of the employer’s duty to provide general supervision of machinery as contemplated in OHSA 8(2)(i).
The GMR 2(1) is not the only person who provides supervision of machinery.
OHSA 8(2)(i) stipulates that the employer must ensure that “…plant or machinery is used under the general supervision of a person trained to understand the hazards associated with it and who has the authority to ensure that precautionary measures taken by the employer are implemented”
Persons who are assigned the duty to provide general supervision of machinery are responsible for ensuring that machinery is designed, installed, operated, maintained, and decommissioned in a manner that does not harm their health or wellbeing.
From an OHSA perspective, they must ensure they protect the health and safety of persons in connection with the use of plant and machinery.
The OHSA 8(2)(i) appointment is not only the GMR 2(1). The various regulations establish other OHSA 8(2)(i) appointments, for instance:
Operators: GMR 4(1) insinuates the existence of the operator of machinery, and the employer must ensure that this person is “authorised to operate machinery" and must be “fully aware of the dangers attached thereto and is conversant with the precautionary measures to be taken or observed to obviate such dangers”
Shift Supervisors: GMR 4(3) requires the appointment of a “shiftsman” where machinery requires constant attention to avoid accidents, and the shiftsman must remain on the premises while the machinery is in operation.
Electricians: Electrical Installation Regulation 5(4) requires a registered person to exercise general control over all electrical installation work.
Gas system installation: Pressure Equipment Regulation 17 requires an authorised person responsible for installing or removing gas appliances or systems.
Many other such persons at workplaces provide general supervision of machinery as contemplated in OHSA 8(2)(i). The GMR 2(1) is essentially the legal appointment responsible for the overall management and control of machinery. They must ensure that the employer’s machinery does not harm the health or wellbeing of all persons who interface with it.
Machinery may include more than just the equipment you see in a factory, and it’s important to properly establish the GMR 2(1) appointee’s scope.
In the context of the OHSA, machinery is defined as
“any article or combination of articles assembled, arranged or connected and which is used or intended to be used for converting any form of energy to performing work, or
which is used or intended to be used, whether incidental thereto or not, for developing, receiving, storing, containing, confining, transforming, transmitting, transferring or controlling any form of energy”
Some factories may refer to machinery as plant. However, what you call plant at your workplace may not mean the same thing under the OHSA and the GMR.
Whether the plant falls within the scope of GMR 2(1) depends on what your appointment letter says.
The OHS Act defines plant as “fixtures, fittings, implements, equipment, tools and appliances, and anything which is used for any purpose in connection with such plant”
Furthermore, GMR 2(10)(a) stipulates that a GMR 2(1) does not need to be designated in relation to the following:
elevator, goods elevator, escalator, or
electrical installation in any shop or office or on, or in, any domestic premises, or
any domestic appliance used as such, or
any machinery used in connection with building work, or
any vehicle or earth moving plant, or
any refrigeration, cooling, air conditioning or freezing plant.
Strictly speaking, plant and GMR 2(10)(a) exclusions do not form part of the GMR 2(1) appointment, provided the employer appoints a competent person to inspect and maintain them. This is consistent with OHS Act Section 8(2)(i), which requires the employer to ensure that “plant or machinery is used under the general supervision of a person trained to understand the hazards associated with it and who has the authority to ensure that precautionary measures taken by the employer are implemented”
With that said, employers may still include plant and GMR 2(10)(a) exclusions as part of the GMR 2(1) appointee scope. Furthermore, GMR 2(10)(b) includes a provision where the Chief Inspector may provide a written notice to the employer instructing them to designate a GMR 2(1) for the GMR 2(10)(a) exclusion.
In short, make sure your GMR 2(1) appointment letter clearly states your scope. You may include this in the appointment letter, or reference your job description and responsibilities, which should include a breakdown of your scope of appointment.
GMR 1 provides the technical competencies for GMR 2(1) appointees.
The competency definition is provided in GMR 1, and it splits them into competency (a), (b), (c), and (d), and can be summarised as follows:
Level | Description | Minimum Qualification | Post qualification experience (see note 6) | Certification |
|---|---|---|---|---|
(a) | Artisan | Served an apprenticeship or at least five years' practical experience in maintenance & operation (see note 1) | Two years (at least one year in factory) | Not specified (see note 1) |
(b) | Technician | T3 or N5 in mechanical or electrical engineering (see note 2) | Two years (at least one year in factory) | Not specified |
(c) | Graduate Engineer | Bachelor’s degree in mechanical or electrical engineering (see note 3) | Two years | Passed GCC Factories OHS Act exam (see note 4) |
(d) | Certificated Engineer | National N Diploma, National Diploma, or Bachelor’s Degree in mechanical or electrical engineering | Not specified (see note 5) | GCC Factories (see note 6) |
Note 1: GMR 1 stipulates only a served apprenticeship. However, in general practice, employers require candidates to have a relevant mechanical or electrical engineering trade. In the case the machinery is used for electricity distribution, GMR 2(5)(a) requires candidates to be registered installation electricians (i.e., must have a wireman’s license), which by implication requires the candidate to have the electrician trade.
Note 2: BTech and Advanced Diploma in mechanical or electrical engineering are post-graduate qualifications which require the National Diploma as entry. Candidates with a National N Diploma, National Diploma, BTech, or Advanced Diploma are competency (b). GMR 2(6) stipulates that persons with other qualifications (e.g., chemical engineering, industrial engineering, etc.) may obtain approval from the Chief Inspector to be designated as GMR 2(1).
Note 3: Master’s and Doctoral degrees are post-graduate qualifications that require a bachelor’s degree (and, in some cases, a BTech or National Diploma) as entry. Candidates with Master's or Doctoral degrees are (c) competent, provided they have a bachelor's degree in mechanical or electrical engineering and have passed the GCC Factories OHS Act exam. GMR 2(6) stipulates that persons with other qualifications (e.g., chemical engineering, industrial engineering, etc.) may obtain approval from the Chief Inspector to be designated as GMR 2(1).
Note 4: Passing the GCC Factories OHS Act exam does not lead to certification. It is listed under certification for ease of reading and to indicate an additional requirement beyond the bachelor’s degree.
Note 5: GMR 1 specifies only that the candidate must have the GCC Factories, which implies the candidate must have at least two years' experience, as required to be accepted to write the GCC Factories exams.
Note 6: The experience must be in the maintenance and operation appropriate to the class of machinery the appointee is required to supervise. The GMR does not directly stipulate that the GMR 2(1) with the GCC Factories must have maintenance and operation appropriate to the class of machinery the appointee is required to supervise. However, in practice, this is required, and it is also ECSA's general approach, since GMR 2(1) does engineering work that falls under the Identification of Engineering Work Regulations.
Click here to view and download the latest OHSA regulations.
The applicable competency depends on the cumulative size of the machinery in or on the premises.
The competency of the GMR 2(1) appointee depends on their qualifications, experience, and certification, and varies depending on the cumulative power generated by machinery or the electricity distributed on the premises.
GMR 2(4) provides the GMR 2(1) competency requirements for mechanical machinery.
GMR 2(4) does not explicitly state that the competency is for mechanical machinery; instead, it provides the kilowatt ranges for the “sum generated by machinery” and the associated competency ranging from (a) to (d). In general practice, GMR 2(4) is referred to as the mechanical competency for ease of reference.
The GMR 2(1) competency can be summarised as follows:
Sum of power generated by machinery (kW) | Competency |
|---|---|
Less than 1200 (see note 1) | (a), (b), (c), or (d) |
Between 1200 - 3000 | (b), (c), or (d) |
Greater than 3000 | (c), or (d) |
Note 1: GMR 2(4) does not explicitly specify competency where the sum of the power generated by machinery is less than 1200 kW. In general practice, minimum competency (a) is used where the sum of the power generated by machinery is less than 1200 kW. Failing to appoint a competent person where the sum of the power generated by machinery is less than will contradict GMR 2(1), as it would assume that GMR 2(1) is not required when the sum of the power generated by machinery is less than 1200 kW.
GMR 2(5) provides the GMR 2(1) competency requirements for electrical machinery, but it does not explicitly define it as an “appointment for electrical machinery”. In general practice, this is a GMR 2(1) appointment for electrical machinery, and the competency requirement can be summarised as follows:
Maximum demand over a 30-minute period (kVA) | Competency |
|---|---|
Less than 3000 | (a), (b), (c), or (d) |
Between 3000 - 10000 | (b), (c), or (d) |
Greater than 10000 | (c), or (d) |
Experience in the class of machinery is essential to ensure the GMR 2(1) is competent to identify hazards and precautionary measures.
The distinction between mechanical and electrical is essential because GMR 1 emphasises that the experience must be in operation and maintenance in the class of machinery the GMR 2(1) is meant to supervise.
Furthermore, OHSA 8(2)(i) stipulates that the person providing general supervision of machinery must be “trained to understand the hazards associated with it and have the authority to ensure that precautionary measures taken by the employer are implemented”
The GMR 1 and OHSA 8(2)(i) are consistent with the general practice required of persons undertaking engineering work as per the Engineering Professions Act, and in particular the Identification of Engineering Work Regulations (IDoEW), which requires engineering practitioners to do work that they are competent in.
The GMR 2(1) competency extends to matters governed by the Engineering Council of South Africa (ECSA)
GMR 2(1) appointees do engineering work as defined in IDoEW. This can be clearly noted from the fact that:
ECSA has the Candidate and Profession Certificated Engineer registration category, and
The GMR 2(1) does work that fulfills the eleven ECSA competency outcomes for broadly defined work.
As such, GMR 2(1) must also comply with the Engineering Professions Act and IDoEW. This means they must meet the ECSA competency outcomes and register with ECSA as required by IDoEW.
The IDoEW covers the technical and leadership competency requirements for GMR 2(1) and is an essential consideration when taking up the GMR 2(1) position, in addition to the GMR 1, 2(4), and 2(5) requirements.
The GMR 2(1) appointment is a leadership role and requires the skill to set up systems and lead others in implementing them.
The GMR 2(1) appointment can be intimidating, especially for large facilities with hundreds of machines and employees who help ensure the safe use of machinery.
Relying on your technical competency alone may not be enough to fulfill your roles and responsibilities.
Remember that the GMR 2(1) position requires you to provide overall leadership in the design, installation, operation, maintenance, and safe decommissioning of all machinery.
If you want to be a successful GMR 2(1), you must learn the skill of:
Developing, implementing, and managing a system that ensures the legal and other requirements are fulfilled,
while ensuring the sustainability of the organisation is protected, and
you will lead others to implement the system.
Conclusion
Qualification: The GMR 2(1) appointment is meant for persons with mechanical or electrical engineering qualifications (i.e., mechanical or electrical artisans, technicians, technologists, and engineers). GMR 2(6) provides an exception for persons without a mechanical or electrical engineering qualification, but they must get permission from the Chief Inspector.
Experience: GMR 2(1) appointees must have appropriate operations and maintenance experience in the class of machinery they are meant to supervise. They must have the skills to identify hazards and implement precautionary measures.
Certification: A person can be appointed as a GMR 2(1) without a GCC Factories certificate, provided that:
the total power generated by machinery is less than 3000 kW and, if the machinery is used for electricity distribution, the maximum demand is less than 10000 kVA, and
the person meets the qualifications and experience appropriate to the size of the facility.
Anyone looking to advance in the GMR 2(1) career must complete the GCC Factories, as it does not limit them to certain facility sizes, and the GCC Factories journey will help develop the technical and some legal competencies needed to fulfill the role and responsibilities.
Professional registration: GMR 2(1) appointees do engineering work and, as such, must also comply with the Engineering Professions Act, particularly the Identification of Engineering Work Regulations, which require them to register with ECSA.
Leadership competency: The GMR 2(1) role and responsibilities go beyond technical and legal competency; they also require leadership competency. The GMR 2(1) must have the skill to develop, implement, and manage a system that ensures legal and other requirements are fulfilled, protects the organization's sustainability, and leads others to implement the system.
Continued Professional Development: Pursuing the GCC Factories and attending appropriate professional development courses aligns with ECSA and IDoEW competency outcome 11. The GMR 2(1) must undertake professional development activities sufficient to maintain and extend their competency and ensure they can fulfill their role and responsibilities, while protecting themselves from legal liability.
Next steps
[Guidelines] Learn about the GCC Factories requirements.
[Guidelines] Submit an application to write GCC Factories exams.
[Programme] Prepare for the GCC Factories plant engineering exam.
[Programme] Prepare for the GCC Factories OHS Act exam.
[Short Course] Join the GMR 2 short course.
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