Well, hopefully this won’t sound repetitive, but CRN registration is required unless an exemption or Variance applies! Requirements vary by province/territory – some regions have specific exemptions and others have more general ones. Alberta has an entire regulation devoted to some exemptions. See this article for more .
And, of course, CRN registration is required before the pressure equipment is operated in Canada. To follow the legislation and CSA B51 even more carefully, CRN registration is required before the pressure equipment is even built, while still at the finalized design stage. So as to avoid a whole host of complications, a good rule of thumb to follow is that CRN registration is required before the assembled equipment leaves the manufacturer.
But sometimes, this is not possible. For example, boilers assembled in the field obviously need to be put together after leaving the manufacturer but nevertheless, the design should have a CRN well before assembly. As another example, unregistered code stamped vessels can potentially be registered after they leave the manufacturer, but the rule of thumb stated above is the best way to avoid issues.
For those unfamiliar with CRN requirements, the obvious question is why are CRN numbers required? No other nation beside Canada has them. One reader recently wrote to ask these questions: Do CRN numbers improve safety, or help Canada to be competitive? Our answer was that given their indirect reference in public safety legislation, governments in Canada recognize the importance of CRN numbers. They help to ensure that pressure equipment is designed, built and tested to codes and standards that have, through careful collective deliberation, been written to help ensure public safety by using adequate safety margins and other considerations. In Canada, designs that meet code and legislated requirements are competitive.
Canadian Registration Numbers (CRN numbers) are used by provincial governments to record, document, and ascribe responsibility for pressure equipment designs in Canada that are non-exempt from registration. The exemptions associated with each province should be considered carefully for each type of design to ascertain the differences between each jurisdiction. If a Canada wide CRN number is required then the jurisdiction that has, on balance, the most stringent requirements with the fewest exemptions should be identified and applied to first – pursuant to harmonization and efficiency.
Similarly, revisions or additions to a CRN number must be registered in related regions following a particular sequence to avoid issues. Permission from the province that first issued the CRN is needed before the revisions in another region can be registered. And this can cause problems and delays if this requirement is not known.
For example, suppose a category H fitting or a vessel design was registered in Ontario first and then registration was subsequently sought in Alberta. Further suppose that Alberta (ABSA) requirements exceed those in Ontario for the design in question. In that case Ontario will need to consider the revised design before ABSA will consider registering it with the same CRN number.
CRNs follow a format as specified in CSA B51 and are first issued by the region identified by the digit following the decimal point. Other registration numbers for alternative or special designs are issued numbers with a different format, but they are relatively rare. CRN numbers are unique for each design. Referencing specific CRN numbers cannot be done without linking the design owner. Without owners’ written permission, publication of CRN numbers could cause confidentiality issues.