In this space, some questions posed by customers and industry are published in case others have similar questions. Anonymity is preserved. Check back for updates and new correspondence.
We have a fitting CRN for some equipment in Alberta and a second Canada wide fitting CRN that originated in Ontario for different models of the same equipment category. If we renew the Canada wide CRN, is it advisable or possible to add the equipment registered in Alberta to the Canada wide CRN that was first registered in Ontario?
I M Interested
- In general, fittings registered with a CRN in one province can be added to a Canada wide registration that has a different CRN, subject to regulator acceptance. It is arguably easier for manufacturers to have one CRN for all of Canada to avoid a very problematic situation where the CRN and province to where the equipment is shipped or stocked do not match. Our advice therefore continues to be that when equipment is to be used in all provinces, Canada wide registration should be sought whenever possible to best avoid any problems associated with not doing so.
- Some categories of fitting registrations like piping (Category A), flanges (category B), or inline valves (Category C), etc. can include any combination, or number of models if requested by the manufacturer, but at the discretion of the regulators. Category H fittings are less accommodating.
- Regulators will try to avoid duplicate CRN numbers in their province if they become aware of overlap, to help ensure consistency and avoid confusion. If an overlap is noticed, the applicant might be asked to not renew or merge one CRN in favour of the overlapping Canada wide one.
- For example, if Ontario adds fittings registered in Alberta to 0******.5**, then if/when Alberta agrees to the addition and if they notice, Alberta might well ask that fittings already registered in Alberta be extracted from 0*****.2 or if the fittings already registered in Alberta comprise all the designs in 0*****.2, they might ask that 0*****.2 be merged with the Ontario based registration number. (Actual CRNs are masked to preserve anonymity)
- If a fitting CRN has a ‘2’ after the decimal, then additions to the existing CRN must be initiated in Alberta. Additions must be initiated in the province where the CRN was first issued, else the amended CRN would be invalid since the originating province would not know about the addition and a new CRN would need to be issued by an alternate province if it accepts the application for registration.
- Fitting CRN registration will expire 10 years from the date of the first registration or latest renewal, not 10 years from the date of the last addition.
- Each province has a ‘final call’ for their region as to whether they want to accept or merge an addition to a CRN or not. Ontario does not have a final call for Alberta. If, for example, Ontario requires X# of FEAs but Alberta later requires more FEAs or other requirements, then despite previous registration in Ontario, Ontario will subsequently need to accede to Alberta’s request and reconsider the application again if the addition is to be considered for registration in Alberta. That is why it is important to first register equipment in the province that has what is perceived to be the most challenging requirements for any particular application. And similarly, Ontario is under no obligation to merge fittings registered in Alberta as an addition to an Ontario based CRN.