“…more than 50% of 10,000
applications for registration in
2014 were deficient…”
how new programs,
without a proactive
third party detailed examination
of each design,
can remedy this statistic.”
This is the second article in the Canadian Registration Number (CRN) series. The first article, “CRN: What’s in a Number”, outlined CRN numbers, the types of equipment they’re assigned to, and who assigns them. Design acceptance as historically depended on regulators’ proactive detailed design review of each design. So now, we’re tackling a question that naturally follows:
Is CRN number certification /registration needed?
Opinions and answers depend on perspective, but public safety should always be of paramount significance! Here’s Cammar Corporation’s view on some answers:
Some applicants answer ‘no’!
They incorrectly seem to suggest that the CRN number registration application process is necessarily:
• an inconvenient, troubling, confusing, contradictory series of hurdles; and
• fraught with problems that are the fault of regulators, or the CRN system itself.Though potentially loud, this perspective is relatively insignificant since getting a CRN number can indeed be a smooth process, is the responsibility of the applicant, and convenience should never outweigh public safety! Applicants should consider that, in reality:
• A regulator’s intense attention to an application, is a warning sign! What might be viewed as inconsistency or obstruction by some, is likely an indication of a regulator’s reasonable interest. Posting police at everyone’s door can’t be justified since it would be too expensive, and people are responsible for their own safety and behavior. But police are usually present when needed. Similarly, the degree of detail that regulators use to look at applications is often dictated by economics and reason.
• A CRN number is not a statement of responsibility. Though regulators help to ensure public safety in good faith, they are not responsible for pressure equipment safety; owners and end users of pressure equipment are. Registration does not represent a hurdle to overcome, but a minimal bump on the ground to fly over. Quality should exceed regulatory requirements.
• Applications that exceed all regulatory requirements are registered, with minimal delay. Though different regulators have slightly different requirements based on collective experience accumulated in their provinces, if a
design exceeds the most stringent of these, then all requirements are satisfied. That said, duplication of design
reviews that preface CRN number registration should be unnecessary. Obstacles associated with repetition, delays, duplicate fees, etc. should be minimized. To enhance economic benefits and greater inter-provincial cooperation,
perhaps there is a way to improve the CRN number process while maintaining or enhancing safety. Inter-provincial harmonization should be seriously considered, and further thoughts and developments relating to harmonization efforts might well be posted under separate cover! Others seem to answer ‘yes’. But their tacit support for third
party (regulator) review seems to be over rated!
One regulator recently published a new optional / alternative concept seemingly with the intention to develop a registration program based on audit principles instead of proactive third party detailed examinations of each design, to thereby grant CRN numbers to accredited provincial vessel manufacturers that have an accredited employee! Also, if previously registered in any another province, it’s reported that designs are to be registered in some instances with just proper paperwork! And some regulators have indicated that for some categories of fittings, registration is not even required!
These steps seem to be a response to the volume of received applications for registration, and somewhat regardless of the percentages that do not pass initial reviews. Some of these deficient design applications likely came from manufacturers already accredited with certificates of authorization permits!
Published reports show that more than 50% of the 10,000+ applications for registration received in 2014 by one province were deficient in one manner or another. But it’s unclear how new programs like the one noted above,
without a proactive third party detailed examination of each design, can properly contribute to the remedy of this statistic.
A proactive third party detailed examination of each design at least adds some independent assurance that minimum regulatory requirements are met for each specific design, and also requires revisions to deficiencies before operation. Without a thorough third party examination of each design, registrations would seem to be less meaningful than they used to be.
Other questions that remain to be answered include:
• Will consequences of retroactive audits after registration or operation benefit society more than proactive third party detailed examinations of each design before registration and operation?
• Are out of province or foreign manufacturers treated fairly by the new program?
• And, are other regulators going to follow suit, by honoring design registrations that were part of an audit program, with reciprocal registrations?
These developments seem to question whether a CRN number system, based on third party detailed reviews of each design, is still considered necessary by some regulators – or even viable!
Still, other Canadians would clearly answer ‘yes’! CRN numbers are needed!
Public safety is paramount and, without third party detailed examinations of each design, legislated factors of safety would not be independently confirmed before operation, and safety could thereby be reduced.
Pressure equipment can be extremely dangerous, serious stuff. Stored energy calculations show that just one small refrigerator sized vessel with 230 psig of air pressure has the same stored energy as about 1 lb of dynamite!
A sudden failure of the vessel would result in quite a release of energy! But of course many vessels in use are much larger, with internal pressures and volumes far in excess of this.
Public safety is very important, and factors of safety should be respected and confirmed. Thanks to accumulated collective experience, the implementation of pressure equipment codes and standards, and third party oversight of their use, Canada has benefited from few pressure equipment related fatalities.
Absence of third party reviews in other nations is no reason to discontinue the system here. Current legislation echoes this view.
Provincial legislation stipulates that registration is required even before pressure equipment is constructed!
Practicality intervenes though, and un-pressurized modern art that merely looks like pressure equipment, is just art. Repairs or alterations to registered pressure equipment must be agreed to by provincial authorities before they
commence. Unless exempt from registration, pressure equipment must currently be registered to legally operate in Canada.
Canadian registration numbers (CRNs) are archived, and link to those responsible for designs: the owners and end users.And the law has teeth. For example, potential penalties in Alberta under the Pressure Equipment Safety regulation and Safety Codes Act have somewhat recently been increased to $100,000 CAD and 6 months in prison for the first offence, and $500,000 CAD and 12 months in prison for a second or consecutive offence.
Additional penalties are available for each additional day that the offence continues! So, this is very serious stuff.
CRN numbers are currently necessary to help ensure safety per the behest of provincial governments and, by extension, in response to the desire of Canadians. Canadians have democratically empowered their governments to provide protection, and to help ensure safety.
And Cammar Corporation believes that the public deserves nothing less.