Top CRN Registration Changes in 2022 to be Aware Of

As we all embark on 2022, there are several noteworthy topics to consider as you navigate the CRN regulatory landscape, pursuant to acquiring CRN registration and marketing or using your pressure equipment in Canada.  From CAMMAR Corporation’s perspective, the most significant CRN topics of interest include ASME code changes, engineering regulator trends, and the resulting increase of required engineering involvement. 

Significant Code Changes

ASME Section VIII-1

As of January 1, 2022, the 2021 edition of ASME Section VIII-1 is current.  

Changes in the 2021 ASME Section VIII-1 code now reference greater involvement of the engineering profession.  

With mandatory Appendix 10, calculations justifying pressure vessel designs must now be verified and in accordance with the quality control program of the manufacturer, under the responsible charge of a certified engineer, qualified engineer, or qualified designer.  A certifying engineer in responsible charge must be either chartered, registered, or licensed.  Mandatory Appendix 47 clarifies what the qualifications and experience for a certifying engineer, engineer, or designer in responsible charge are required to be, according to ASME.  

Though ASME codes have stated for a long time that proper use of code rules requires engineering judgement, the new requirements noted above emphasize and clarify this fact.  Per code, engineering involvement is now mandatory when designing and manufacturing pressure vessels.  

Further to just pressure vessel CRN registration requirements and related equipment permits issued by jurisdictional authorities, trends amongst Canadian professional engineering regulators emphasize professional authentication requirements in a significantly more specific manner than ASME.  See below for more details.

ASME B31.3-2020

As of January 2022, the 2020 Edition of ASME B31.3 is current.  

Changes most notably occurred to Chapter IX, in relation to high pressure piping system design.  Options for pressure boundary justification of unlisted components have been reduced, and a significant amount of further complexity is now required.  CAMMAR Corporation has assisted companies with navigating through ASME B31.3 Chapter IX, with unlisted components, to obtain CRN registrations.

It should always be remembered that, as a general rule, proof testing is strongly preferred by Canadian regulators and many others over finite element analysis (FEA), since properly performed physical testing is not ever subject to modelling error, invalidation, or lack of verification.  From evaluations CAMMAR Corporation has made, FEA models available these days are certainly not all of equal quality.  And based on experience, CAMMAR Corporation advises that despite the provisions of B31.3 paragraph K304.7.2(a), extensive service experience of equipment for pressure boundary justification is difficult to properly document and attest.  Accordingly, ASME B31.3 paragraph K304.7.2 (a) is considered unacceptable to Canadian regulators for CRN registration, paragraph K304.7.2(b) is acceptable for design justification only if code rules for calculations are inapplicable, and paragraph K304.7.2(c) is only acceptable provided that proof testing is infeasible for reasons satisfactory to the regulator.  

ASME Section VIII-2 analysis is no longer an optional approach for justifying the pressure boundaries of unlisted components in ASME B31.3 Chapter IX high pressure piping systems.  Instead, ASME Section VIII-3 (including cyclic analysis and fracture mechanics analysis as warranted) is now mandatory for Chapter IX designs if pressure boundary design justification beyond code rules is necessary, when proof testing is infeasible for good reason. 

Similarly, and though cyclic analysis is still mandatory for ASME B31.3 Chapter IX deigns regardless of unlisted components, ASME Section VIII-2 is no longer an option for cyclic analysis, and ASME Section VIII-3 rules for cyclic analysis (including fracture mechanics as warranted) is now required, per ASME B31.3 paragraph K304.8.  

Accompanying the above noted changes are some notable increases in the allowable stresses of materials for Chapter IX use, as listed in ASME B31.3 Table K-1.

Canadian Engineering Regulator Changes

For proper use of pressure equipment that relies on engineering theory and judgement, engineering regulators are making it clearer that having just a CRN is now insufficient for design use.  CRN registration is necessary, but not enough to properly use pressure equipment.  Engineered pressure equipment designs must be professionally authenticated in accordance with the engineering authority having jurisdiction, where the equipment is to be used.  This advice certainly seems to run contrary to popular knowledge and practice. 

There are two kinds of regulators that exert governance over pressure equipment in Canada: pressure equipment regulators; and engineering regulators.  Requirements of pressure equipment regulators like TSBC in British Columbia, ABSA in Alberta, and TSSA in Ontario, are more commonly considered.  Engineering regulator requirements like those of EGBC in British Columbia, APEGA in Alberta, and PEO in Ontario are at least as important though they are not as frequently discussed.

Over the last year or so, the perspectives of engineering associations about professional responsibilities for pressure equipment (pressure vessels, boilers, fittings, and piping systems), seem to be coming into clearer focus.  And that focus is somewhat different than what the pressure equipment regulators seem to envision.  

For example, in British Columbia (BC):

The engineering regulator (EGBC) now indicates that for pressure vessels engineered in and destined for use in BC, designs and engineering documentation must be professionally authenticated (stamped) by a professional engineer registered with EGBC.  Engineering in BC is now governed by the new BC Professional Governance Act and the BC Engineering and Geoscience Regulation of the new Act.  And though the new statute and regulation seem to still rely on some aspects of the replaced BC Engineers and Geoscientists Act, it seems to indicate that if any pressure vessel is destined for use in BC, then its design documentation must be authenticated by a professional engineer registered in BC.  For clarification and confirmation or exceptions, EGBC should be contacted directly for details in relation to your particular instance.  

Despite EGBC requirements, the pressure equipment regulator in BC (Technical Safety BC) does not necessarily require pressure equipment designs to be stamped by a professional engineer licensed in BC, for BC CRN registration.  

For another example, in Alberta: 

The engineering regulator (APEGA) recently published the Standard entitled “Authenticating Professional Work Products”.  It indicates that engineered pressure equipment designs destined for use in Alberta requires professional authentication (stamping) unless the equipment is, as defined by the APEGA Standard, commercially engineered.  Obviously, pressure equipment does not meet the definition of a commercially engineered good as defined by the APEGA Standard since, though pressure equipment designs must meet adopted codes and standards or their equal, the pressure equipment regulator in Alberta (ABSA) never certifies pressure equipment designs.  In fact, by registering a design with a CRN, ABSA merely accepts a design for CRN registration but certainly does not vouch for it or take responsibility for it in any way.  Of interest, the APEGA Standard makes no mention that an exemption from required professional engineering involvement per Section 2(4)(d) of the Alberta Engineering and Geoscience Professions Act exists, or that any other exemption from required professional engineering involvement included in Section 2of the Act exists.  

Despite the APEGA Standard, ABSA does not necessarily require professional authentication by any engineering professional prior to CRN registration for most pressure vessels and fittings.

And in Ontario:

TSSA requires all pressure vessel design documentation to be professionally authenticated (stamped) by a professional engineer registered with the engineering regulator (PEO) of Ontario, but professional authentication of non-nuclear pressure fitting designs is not required before CRN registration.

Summary of Top CRN Registration Changes for 2022

There are contradictions with how the pressure equipment and engineering regulators are administering legislation that governs pressure equipment, and this is of interest.

Even though many codes and adopted standards obviously and increasingly require the application of engineering theory for proper design, and engineering regulator requirements are becoming clearer to all, professional authentication is not yet always required by pressure equipment regulators before CRN registration.

More engineering involvement and professional authentication of pressure equipment designs before their use is now required in many instances.  Despite differences between code changes, engineering and pressure equipment regulator standards, statutes, regulations and approaches, the overall message and trend about how pressure equipment designs are to be properly registered with CRNs and used in Canada seems to be getting clearer.  

Professional engineering involvement is becoming more important to both pressure equipment and engineering regulators, and clear alignment will become even more necessary in the future, as regulators continue to work together pursuant to consistent messaging, enforcement, and public safety.

Fitting CRN Registrations

Fitting CRN Registrations

In Fitting CRN Registrations, any fitting that is part of a pressure piping system or attached to a pressure vessel or boiler, usually requires CRN registration, unless exempt.

What a Fitting Is

The term ‘fitting’ includes pretty much all components of a piping system except the pipe itself and external supports.  Pipe is considered material, and does not need a CRN.  Components often needing a CRN include fittings such as elbows, couplings, reducers, flanges, valves, expansion joints, hose assemblies, strainers, filters, separators, steam traps, instrumentation, pressure gauges, transducers, safety relief valves, rupture disks, fusible plugs, and small pressure vessel shaped fittings < 6 inches in diameter are subject to fitting CRN registrations requirements.

Per CSA B51, fittings needing CRN registration are put into the following categories:

A – pipe fittings

B – flanges

C – all line valves

D – flexible connections

E – things that separate stuff, like steam traps, filters, and strainers

F – measurement devices

G–over pressure protection devices

H–all other fittings

Exemptions from CRN Registration

Exemptions from CRN registration vary across jurisdictions.

In general, sometimes fittings are exempt from CRN registration if the pressure equipment to which they are part of is exempt from registration.  If a pressure vessel or boiler is exempt from CRN registration, then fittings that are part of the equipment are also exempt from CRN registration.  Sometimes, even for pressure piping, the premise applies.  In Alberta and Ontario, if a pressure piping system is exempt from piping registration, then fittings are sometimes exempt from CRN registration.

For example, in Alberta (ABSA), piping system component fittings are exempt from CRN registration if the associated pressure piping system is:

  • sized only less than 2 inch NPS, 
  • has a maximum allowable working pressure not exceeding 1035 kPa, 
  • has a design temperature between -29C and 186C, 
  • contains only relatively innocuous fluids (like air, nitrogen, argon carbon dioxide, steam, hot water, or glycol), AND 
  • is constructed to an applicable adopted ASME code.  

By contrast, in Ontario (TSSA), piping system component fittings are exempt from CRN registration if the pressure piping system they are in never exceeds ¾” NPS and contains only air.

And sometimes, though the pressure piping system is exempt from registration, exemption for all components fittings does not necessarily follow, depending on the exemption.  For example, in Alberta, if a pressure piping system is exempt from registration due to its aggregate volume being less than 0.5m3, it does not follow that fitting components in the associated piping system are exempt from CRN registration.  Similarly, in British Columbia (TSBC), if a pressure piping system is exempt from registration since it is sized 3” NPS or less, it does not follow that all associated fitting components are exempt from fitting CRN registrations.

Categorical Fitting CRN Exemptions

Each Canadian pressure equipment jurisdiction has its own exemptions and directives.  For example, and per the summary Table noted below, some jurisdictions are uninterested in registering entire categories of fittings, subject to some requirements.  British Columbia does not require registration of most Category A, B,C and G fittings, per Directive D-B-2013-03, if they are used in accordance with and in compliance with the applicable standards listed in in ASME B31.1, B31.3, B31.5, or B31.9.  Alberta has no such exemptions from CRN registration,  Saskatchewan exempts Category A,B,C and G fittings in a manner similar to British Columbia.  So does Manitoba (ITS Bulletin OFC ITSM 18-001).  Ontario has no such exemptions from registration.  In Quebec, category A, B, C fittings that meet a nationally recognized standard do not need to be registered with a CRN, but design records are to be retained for Quebec (RBQ) verification.  Nova Scotia, New Brunswick, Prince Edward Island, Newfoundland, the Yukon, Northwest Territories, and Nunavut have no such exemptions from fitting CRN registration.

Summary of Categorical Exemptions from Fitting CRN Registration

JURISDICTION REGULATOR / REGISTRAR CATEGORY EXEMPTIONS FROM FITTING CRN REGISTRATION CONDITIONS OF EXEMPTION
British Columbia TSBC A, B, C, G Note 1
Alberta ABSA none NA
Saskatchewan TSASK A, B, C, G Note 1
Manitoba ITS A, B, C, G Note 1
Ontario TSSA none NA
Quebec RBQ A, B, C Note 1
New Brunswick Gov of NB / ACI none NA
Nova Scotia Gov of NB / ACI none NA
Prince Edward Island Gov of NB / ACI none NA
Newfoundland Gov of NB / ACI none NA
Yukon Territory Gov of NB / ACI none NA
Northwest Territories Gov of NB / ACI none NA
Nunavut Gov of NB / ACI none NA

Note 1: use in accordance with and in compliance with the applicable standards listed in in ASME B31.1, B31.3, B31.5, or B31.9.  Category G fittings must be marked with an appropriate ASME or NB stamp.

Despite the broad strokes painted above, each situation and equipment design must be carefully considered on its own merits.  CAMMAR Corporation provides clientele with insightful assistance. And though it is unlikely that CAMMAR Corporation’s opinion will differ from the regulators’ perspective since our foundational experience from working at ABSA provides good enviable insight into the Canadian regulatory system, regulators do have the last say as to whether pressure equipment is to be registered with a CRN or not.  CAMMAR assists clientele like you, by providing insightful comments, and assistance pursuant to proper CRN registration in accordance with good engineering practice, applicable code, and regulation requirements.

CRN Reconciliation vs Harmonization

CRN harmonization vs CRN reconciliation. Are they different?

Reconciliation has been touted as an improvement to the CRN registration process.  But is it simply a new and weaker buzzword for harmonization?  Does reconciliation increase the speed of CRN registration and reduce registration and design costs?  Are jurisdictions somehow harmonized further than they were before?  Is public safety further enhanced?  Read on.

CRN Harmonization and Issues to Resolve

CRN harmonization has been around for a very long time.  Starting with the 1939 edition of CSA B51, and continuing up to the most recent edition of CSA B51 in 2019, a harmonized pressure equipment CRN numbering system has been recognized across Canada, to facilitate jurisdictional cooperation and recognition, while maintaining safety in the best interest of Canadians.  Over the intervening years, various revisions to the Canadian pressure and vessel code have added Canadian jurisdictions, specific fitting categories, and more clarification of the CSA B51 rules as Canada progressed.  CRN’s (Canadian Registration Numbers) have thereby been around for more than 80 (eighty) years.  Revisions in CSA B51 to help address these statutory and regulatory differences might well be addressed in the next edition of CSA B51, but are not yet complete.  Businesses in Canada that make and use pressure equipment like boilers, pressure vessels, pressure fittings, thermal liquid heating systems, heat exchangers, pressure piping, hot water tanks, etc., need to know how to navigate CRN requirements, understand the system, and understand the CRN regulators that administer the system.  CAMMAR helps.  

Canada’s constitution assigns pressure equipment safety to provincial and territorial jurisdictions, each with its own unique legislation.  Even pressure equipment safety at federal facilities is governed by provincial and territorial jurisdictions, at the request of and through agreements with the federal government.  This is unlikely to change without an amendment to the Canadian constitution, and such a change would be unprecedented. 

Canadian jurisdictions remain autonomous from one another and, despite the appearance of various free trade agreements and even with the Reconciliation Agreement itself, regulators each have unique safety legislation and jurisdictional requirements to administer.  Jurisdictions have not adopted each other’s regulations.  Though the Canadian Registration Numbering (CRN) system is recognized across Canada without exception, the statutes and regulations of each jurisdiction are somewhat different, particularly in terms of definitions, and exemptions.  Some exemptions from CRN registration are more lenient than others.  Regulators reportedly work with each other behind the scenes to help ensure, as much as possible, that designs to be used in different provinces are compliant in all. 

Different jurisdictions also have different per capita concentrations and varieties of pressure equipment and, therefore, the regulators in different jurisdictions naturally have different levels of experience when it comes to pressure equipment evaluation.  Some literally review thousands more CRN applications and types of equipment than others.  Jurisdictions with the most pressure equipment intensive concentrations often have the largest regulatory departments, with the largest number of regulatory officers, and arguably have the most regulatory experience.  ABSA in Alberta, the TSSA in Ontario, and Technical Safety BC in British Columbia see the lion share of pressure equipment use in Canada. 

Per capita, Alberta is one of the most if not the most pressure equipment intensive regions in Canada and North America.  ABSA, the pressure equipment regulator in Alberta, thereby has one of the most, if not the most experienced. staff of regulatory officials in any Canadian jurisdiction.  

CRN Reconciliation and Persistent Questions

CRN reconciliation is a recent effort where some jurisdictions have agreed publicly, at least ostensibly, to accept the reviews of other regulators in lieu of any subsequent regulatory review by signing a Reconciliation Agreement.  Alberta, New Brunswick, and Newfoundland have not signed the arrangement.  

Reconciliation is Different Than Harmonization.

Reconciliation is fundamentally different than harmonization since, on the surface at least, jurisdictions no longer have the ability to conduct their own independent reviews of pressure equipment designs.  For jurisdictions that have signed the agreement, it means that for any pressure equipment registered in Province A (for example, any jurisdiction, including smaller and less pressure equipment intensive provincial jurisdiction in Canada), registration would automatically follow in Province B at the applicant’s request and further payment, regardless of whatever additional requirements or environmental challenges Province B would otherwise address.  Obviously, different regions in Canada have different climates, wind loadings, and seismic activity.  Beneath the surface of the Reconciliation Agreement, problems can obviously potentially arise, and questions abound.

Potential Safety Issues

To facilitate use across Canada per the Reconciliation Agreement, does the safety officer conducting the initial review in Province A automatically assess whether the design is suitable for absolutely every location in Province B and everywhere else in Canada?  Would a vessel registered in Province A necessarily be suitable for the most seismically active region in Province B?  Perhaps not and if not, then how can Province B in good conscience allow use of the equipment registered in Province A per the Reconciliation Agreement without more, and automatically accept all vessels registered in Province A, or C, or D, or…?  Who is overseeing and auditing the registration process to ensure that all equipment is registered consistently at a high level of compliance, in the interest of public’s safety?  If there are exceptions and options to when the Reconciliation Agreement is to be used, none seem to be stated publicly by those jurisdictions that have agreed to it.

Economic and Competitive Issues

Must all vessels registered via the Reconciliation Agreement thereby be overbuilt, in case they are potentially used at the most seismically active Canadian spot, or windiest Canadian spot, or coldest Canadian spot, or etc.?  By imposing uniform requirements to allow use everywhere, how much extra cost associated with overbuilt designs would be involved if the Reconciliation Agreement is applied properly?  Is this extra cost in industry’s best interest?  Conversely, how many vessels will be put into service that do not meet jurisdictional requirements, if those requirements are overlooked in the interest of market service?  In the event of a registration error, how much re-work will be needed to correct it after distribution and installation, at what cost?

Need for High Standards and Regulatory Consistency

Do the regulatory officials in all provinces have the same level of expertise, and do they all apply the same level of scrutiny to all their reviews?  Any perception that the Reconciliation Agreement is a regulatory race to the bottom, that facilitates the delivery of all applications to the most obliging regulatory port of entry, need to be avoided.  What assurance and evidence is there that all regulatory officers evaluating pressure equipment across Canada have equivalent, comparable experience and consistent high standards when evaluating pressure equipment for safety?

Consistent Safety and Regulatory Training

How can a regulator in a less intensive pressure equipment jurisdiction, which would ordinarily see only a small fraction of the applications seen by a more pressure equipment intensive province, gain the same experience to properly evaluate and review complex or diverse designs, except with significant time and work share arrangements?  How can safety officers be adequately trained in such a short time to properly evaluate whether designs comply with all Canadian environmental conditions and regulatory requirements, so that the Reconciliation Agreement does not potentially adversely affect public safety?

Legal Questions

The scope, protections, and limitations of regulatory officials are described by the legislation that their authority is derived from.  Different jurisdictions have different legislation, with different exemptions from CRN registration.  So, how can a regulatory official in a jurisdiction where CRN registration in a particular circumstance is exempt from and not supported by their legislation, still register the pressure equipment with a CRN in good faith and in accordance with the authority the legislation gives them? 

Market Forces Affecting Safety

Will some jurisdictions, that traditionally received fewer applications, suddenly receive more if industry believes that CRN acquisition is easier via some routes than others?  What if an applicant wants to initially limit where their equipment is registered, and then expand the registration at some later date after the initial review.  Based on the Reconciliation Agreement, subsequent reviews would not be required, regardless of the equipment’s final destination and age.  How would this practice be consistent with proper consideration of all requirements at the equipment’s final destination, in the interest of public safety?

The Bottom Line

The whole point of the regulatory system associated with pressure equipment is to help ensure public safety and confidence.  Many unanswered and intriguing questions about the Reconciliation Agreement remain.

Hopefully, pressure equipment regulators will not lose sight of the fact that their customer is the public and, for them, the public’s interest in safety must remain paramount. 

 

Generic Designs Revisited

The truth is, fewer CRNs are better in many ways.  

With fewer CRNs, it’s easier to keep track of CRN registration numbers, it’s easier to ensure the right CRN registration number is affixed to the right equipment, and it’s easier if the regulators need not be contacted as much.

It’s usually possible to combine several pressure equipment designs of a particular type into one design.  This is what a generic design is all about.

Generic Pressure Vessels and Boiler Components

For example, pressure vessels or boiler vessels and components with different nozzle locations in heads and shell, different nozzle sizes, and different shell lengths can be combined into one design, i.e. a generic design.  For pressure vessels, nozzle spacing tables showing required nozzle spacing distances in accordance with ASME Section VIII-1 paragraphs UG-36, UG 37, UG-39, UG-40, UG-41, UG-42, UW-14, etc., can be included on the drawing and considered as part of a design.  Similarly for boiler vessels and components, nozzle spacings are governed by paragraphs PG-32 etc.  

Only relative locations of nozzles need to be prescribed; specific locations for each nozzle need not be defined.  In this way, a virtually unlimited number of nozzle combinations and locations can thereby be included with a vessel design, as long as they reasonably represent the product line and market demand.  The idea is not to combine all possible nozzles at all possible locations, at all nozzle offset distances, and at all nozzle inclination angles.  A reasonable set of nozzle locations and sizes is acceptable to the regulators.

Generic vessels must have a fixed:

  • maximum allowable working pressure 
  • max design temperature, 
  • minimum design metal temperature (MDMT), 
  • shell diameter, 
  • corrosion allowances for each vessel component, 
  • weld configuration for each nozzle
  • head type
  • head and shell thicknesses, and
  • materials of construction, with reasonable exceptions.

A drain must be located at a location to permit drainage, if required.  And inspection openings, if required, must be located within a diameter’s distance of the heads’ circumferential seams.

Generic Fittings

Fittings designs are regularly combined into one application for CRN registration, as long as the same fitting category is considered.  For example, a catalogue of category A ASME B16.9 pipe fittings can be registered with one application.  Same thing for various different catalogues with sets of drawings: category B flanges, whether ASME B16.5 or custom in accordance with ASME Section VIII-1 Appendix 2; category C valves fittings in accordance with ASME B16.34, or ASME B31.3, etc.; category D expansion joints or hose assemblies; category E filters, separators, or steam traps; category F measurement instruments like gauge glasses, pressure transmitters, flow meters, etc.; or category G pressure relief valves, rupture disks and fusible plugs.  Such CRN registrations cover a wide range of sizes, pressure ratings, temperature ratings, materials of construction, etc.  In general, requirements for generic fittings are less stringent than for pressure vessels.

An exception to the above is for category H fittings, which typically look like little pressure vessels.  For generic CRN registrations involving category H fittings, it is advised to apply the guidelines for generic vessels  noted above. 

Revisions and Additions to Generic CRNs

After registration is obtained and before it expires, a CRN revision can add new design models or variations to the list of equipment already included with a CRN registration.  With a revision to a CRN, the same CRN number can be used for new models or for design variations, further to what was originally anticipated.

ASME B31.3 is different than API 6A. FInd out how with Cameron Sterling from Cammar.

API 6A Is Not The Same as ASME B31

API 6A and ASME B31.3 Chapter IX High Pressure Piping Components are NOT the Same.

As those in the oil and gas industry venture to where ASME codes prevail, you could find out the hard way that API standards do not govern these component designs. Expensive assumptions about API applicability can be made incorrectly, at great cost to budgets and schedules. In Canada, regulators like ABSA in Alberta and the TSSA in Ontario govern pressure equipment use and CRN registration requirements when related safety regulations apply.

For example, API 6A – Specification for Wellhead and Christmas Tree Equipment, is unacceptable as a code of construction for valves or equipment for any ASME B31.3 service in the jurisdiction of CSA B51. Regardless, many high-pressure valve and equipment suppliers often mistakenly use API 6A as their standard and do not realize that its requirements differ markedly from ASME B31.3 Chapter IX.

Here’s a quick list of some significant requirements associated with ASME B31.3 Chapter IX for you to consider:

User Design Specification:

Per paragraph K300, at their option to use Chapter IX as the code of construction, the owner must designate piping as being in ASME B31.3 Chapter IX high-pressure fluid service and must provide the designer with all system operation information necessary to properly design the equipment. In return, the designer must make a written report to the owner that certifies that calculations and the design have been performed in accordance with the code requirements.

Cyclic Analyses:

Cyclic analysis is necessary per paragraph K304.8 unless the owner designates that the piping system will not undergo cyclic loading, that there will be no pressure or temperature cycles throughout the lifetime of the piping system. If the component is listed and conforms to standards listed Table K326.1, fatigue can be analyzed with either ASME Section VIII-2 or ASME Section VIII-3 methodologies.

Flanges:

For pressures that exceed #2500 class, flanges are to be validated through ASME Section VIII-2 Part 4 calculations, per paragraph K304.5.1(b). Regulators will be reluctant to consider proof tests or FEA justifications.

Unlisted Components:

Valves etc. not conforming in any way to ASME B16.34 per K307.1 and other components unlisted in ASME B31.3 Chapter IX per K304.7, must be validated through an ASME Section VIII-3 finite element analysis (FEA) which inherently includes a VIII-3 fatigue analysis, a proof test, or a combination of both these methods. Even with meticulous records and affidavits, it is exceedingly difficult to adequately document successful service to the satisfaction of the regulator and all stakeholders.

Proof Testing:

Proof test pressure is different in ASME Chapter IX than for ASME B31.3 Chapter VI requirements and is a function of yield strength at ambient and at temperature.

Listed Materials and Allowable Strengths:

Refer to Table K-1 of ASME B31.3, not Table A-1 for pressure boundaries. Refer to ASME Section VIII-2 for bolting materials per paragraph K309 and Section VIII-2. Allowable strengths are a function of yield strength alone, per paragraph K302.3.2.

Pressure Boundary Thicknesses:

Cylinder thickness is calculated based on thick cylinder theory per ASME B31.3 Chapter IX paragraph K304.1.2, and differs from the thin-walled theory approach of ASME B31.3 Chapter II.

Impact Testing:

Impact tests are necessary for base metals and welds in accordance with ASME B31.3 Chapter IX Table K323.3.1 requirements, further to material specifications. Exemptions unrelated to specimen size are unavailable. There are no exemptions associated with material thickness.

Valid Canadian Registration Number (CRN) Database & Directory Info

Valid Canadian Registration Number (CRN) Database and Directory Information

To ensure a strong supply chain, industry often needs to locate manufacturers of CRN registered pressure equipment. Pressure piping, vessels, boilers, and thermal liquid heating systems unexempt from CRN registration need components suitable for CRN registration and, though it can be difficult to find legitimate manufacturers, locating them and the registered pressure equipment they make is necessary.

Is there a legitimate directory available to the public and industry, that lists the tens of thousands of CRN numbers that exist? And is there a published list of all legitimate manufacturers in a jurisdiction with acceptable quality control programs?

Yes! There already are legitimate and valid CRN directories on official regulator and registrar websites, that are publicly available to everyone that wants to look for CRN registration records. Only regulators have access to all legitimate CRN registration and manufacturer information, keep it complete and up to date as much as possible, and publish it as they see fit in accordance with their governing regulations. However, significantly incomplete, substantially limited, and unofficial lists are found elsewhere on the internet.

CRN’s are considered confidential information and many manufacturers do not want their CRN information published by others, as commonly evidenced by non-disclosure agreements and requirements for confidentiality.

Given the relatively high concentration of pressure equipment per capita in Alberta, it is worthwhile knowing that the Alberta regulator (ABSA) has allowed access to its CRN Directory here: https://bit.ly/2MvnFHi. And though less populated, the maritime provinces’ CRN Directory can be accessed here, with the assistance of the registrar (ACI Central) and permission of the CRN recipients: https://bit.ly/2A8LamR. The ABSA directory is searchable based on particular CRN numbers, while the ACI Central directory is searchable by CRN and / or manufacturer name. ABSA search results provide the manufacturer name, CRN, drawing number, description, and expiry date. The ACI Central site also provides a more detailed description, including notes associated with the registration.

Using these two CRN Directories, manufacturers with pressure equipment registered in Alberta and / or the maritime provinces can be located and, if the equipment is registered in other jurisdictions too, it’s ordinarily noted.

Fitting CRN registration numbers are categorized per Table 1 of CSA B51, according to the following schedule:

Category Type of Fitting
A pipe fittings, such as elbows, tees, couplings, wyes, caps, unions, etc.
B flanges
C Line valves
D expansion joints, flexible assemblies, hose assemblies etc.
E Strainers, filters, and steam traps etc.
F Measurement devices such as pressure gauges, levels, transducers etc.
G Pressure relief devices
H All other pressure retaining components that don’t fall into categories A through G

 

Unfortunately, wide searches within a fitting category cannot be manually conducted instantaneously. However, formats of CRN numbers as defined in CSA B51 assists with searching the CRN directories for suitable manufacturers. A fitting category letter is included with all fitting CRN numbers, and so specific searches for manufacturers of fitting categories can be made.

For example, if you want to find a piping fitting manufacturer that initially registered their equipment in Alberta, you can successively conduct a manual search using the 0AXXXXX.2 number format until a manufacturer (or all such manufacturers) are found. Similarly, if you want to find a piping fitting manufacturer that first registered their design in Ontario, then you can successively conduct a manual search using the 0AXXXXX.52 format until a manufacturer (or all such manufacturers) are found.

Spending just a minute or so with the ABSA search template, and starting a search at 0A10000.2, revealed the one of thousands of CRN registrations listed there: 0A10032.2. To the best of ABSA’s knowledge, data published on their site is valid, and includes the manufacturer name, registration details, and the expiry dates of all pressure equipment registered in Alberta. A lengthier search, or a lengthier search within a different fitting category, will yield more lengthy lists of CRN numbers and manufacturers!

For the maritime provinces, similar CRN registration searches can also be conducted with manufacturers’ names, and this can shorten the searching process.

The legality of scraping websites with even a simple VBA software routine, to systematically identify and log all fitting CRNs and manufacturers, is questionable since ABSA has claimed copyright on its website contents. Public access to the CRN registration directory information is freely available to anyone that would like to look for it.

A list of qualified manufacturers is also a good place to start looking for registered fittings that might be of interest to you. ABSA publishes a searchable list of all Alberta companies qualified to manufacturer all categories of pressure fittings here: https://bit.ly/3gXKzFk . Manufacturers with an acceptable quality control program can get CRN registration for fittings, provided that the designs meet code and regulation requirements.

CRN Number

Is The CRN Valid and Legit?

“It’s registered they said.  Here’s the proof they said.”

Really. Ok, so what can you believe?

As an end user of pressure equipment (valves, flanges, fittings, instrumentation, vessels, boilers, thermal liquid heaters, etc), you are responsible for its safe operation in accordance with all applicable ASME codes, standards, and jurisdictional regulations.  This means that you need to ensure it is properly registered with a CRN.  CAMMAR Corp can help you do this.

“But wait a minute.  Aren’t the regulators responsible for registering pressure equipment?”  Nope, they aren’t. They just accept it for registration, but before the equipment is used, sold, distributed or even offered for sale, the responsibility for registering it, and ensuring that it is registered properly, rests with those who have care and control over it.  Regulators don’t own it.

“Ok, but I asked the vendor if it was registered and they said it was.  They even provided ‘proof’ of the registration with the CRN number. And that CRN is valid, so it’s registered, right?”

Uh, not necessarily.

For example, suppose your project needs some ASME B16.34 valves with a CRN number.  You ask your vendor for proof of registration, and they provide you a copy of a stamped Statutory Declaration with CRN included.  But what they neglect to tell you is that the acceptance letter provided by the regulator has a condition included, that goes something like this: “Only valves which comply with all aspects of ASME B16.34 in its entirety are part of this registration.”

So, what does that mean?  

It means that the regulator does not always itemize which of the vendor’s valves or items meet the requirements and which do not.  And with the note above, if pressure parts of any valves are made from any materials not listed in ASME B16.34 and supported by mill test reports, then those valves are not registered.  And if the flanges of those valves are improperly reamed or hollowed out, or chambered, too thin, too short, or whatever, and thereby don’t meet ASME B16.5 or B16.47 dimensions in their entirety, the valves are not registered.  Etc.

So, even though there may be a CRN number, the equipment might well not be registered.  Despite what your vendor might tell you!  

And if you were to use such excluded valves or equipment anyways, it would be like you were using unregistered equipment…!  And you don’t want to go there!

Make sure the pressure equipment you want to use is registered properly with CRNs. We, at Cammar Corporation, can help you deal with the complexities of getting a CRN registration. Call Cammar Corporation right away.

Answer Key

Responsibility for CRN Numbers and Safety

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.

Dear Cammar,
If a vessel, fitting, boiler design, or some pressure piping not meeting the legislation requirements and/or that is simply not registered with a CRN number is operated, then so what?
Regards,
IM Concerned


Dear Concerned,

Safety is a big deal to the public, the engineering profession, and the regulator. Breaking the law is not a good idea.

Unless exemptions apply, operation of pressure equipment (vessels, fittings, boilers, pressure piping systems, etc) that does not meet the legislation, or that is without CRN registration, would be against the law.

Though non-exempt pressure equipment certainly needs to be registered before operation, the equipment also needs to meet the minimum requirements of the adopted codes and standards. In all cases, it needs to be safe.

Committing an offense has potential consequences. For example, in Alberta per Section 68 of the Safety Codes Act, those found guilty are subject to a potential fine of $100000 and imprisonment of 6 months for a first offence, and a fine of $500000 and imprisonment of 12 months for a second or subsequent offence.

So… safety, and responsibility for it, is important.

Answer Key

Bleed Ring Design Responsibility Q&A

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.

Dear Cammar,
Does ABSA require that bleed rings be registered or not? I don’t see anything in the pressure equipment safety regulation that exempts bleed rings from having CRN number registration.
I look forward to hearing from you.

Regards,
IM Concerned


Dear Concerned,
Thanks for your email.
ABSA reportedly does not require CRN number registration for bleed rings – in general. See page 5 of http://www.absa.ca/design-registration/fitting-design/faqs-fitting/ for more information. But each circumstance should be considered on its own merits. For example, a pressurized cylinder sealed with o rings between two ASME B16.5 flanges and held together with threaded bars connecting the flanges, is not a bleed ring. The line between a bleed ring and something else can be blurry and open to interpretation.

What is always necessary is a safe design. Instead of your question, a better question would be: can the device with the pressure port included, safely withstand the proposed pressure? ‘Safely’ means within the factor of safety specified by the code of construction as a minimum. Regardless of whether pressure equipment needs a CRN number or not, the design always needs to meet the minimum requirements of available codes and standards, and the design must thereby provide an acceptable safety margin that the designer, vendor, and end user can responsibly attest to.

Cash

How much does a CRN Cost?

The biggest CRN cost might surprise you.  Marketing and operation delays end up costing much more than CRN application and regulator costs. Regulators’ bills aren’t the biggest thing. The regulator will charge as little as about $150CAD or much, much more. Poorly prepared applications for CRN registration will be either rejected, or subjected to a very lengthy iterative review, or both.

Responsibility for registration and application quality rests with the applicant.

Well prepared, professional quality CRN applications will often take a regulator about two to three hours to review on average and this equates to regulator fees of about $500CAD or so or less. But they have many, many applications to review and it might well take a few weeks for an application to reach the top of their pile unless extra expediting fees are paid. Costs are legislated, and registrar’s rates are published (see links here), but regulators’ time can be charged on a half hourly rate if an application is very complex or large. Larger or more calculation intense applications, like a heat exchanger or firetube boiler, will take the regulator a little longer to review but if everything is in order, only a slightly larger fee can be expected for all but the most complex or large applications.

Regulators are NOT responsible for your design.

Poorly prepared CRN applications, that consist basically of a pile of unorganized and unreferenced documents, non-compliant designs, catalogues, drawings, etc., used to be entertained by regulators while the applicant provided corrections. But sorting through such an application would take a regulator longer to evaluate and, as a result, refusals are now a real option. Applicants that rely on the regulator to check their application, to perform the applicant’s quality control, i.e. to do the applicant’s work, are more likely to get a shocking surprise – a bill and no registration! Poor quality applications would result in wasted application and evaluation fees, sometimes higher costs, registration applications that are rejected, and poor relationships with regulators.

Worse yet if a design is mistakenly registered by a regulator, then reactively correcting a mistake once discovered or revealed can obviously be colossally more expensive in terms of reputation than what a proper design application preparation would have been in the first place. Responsibility for registration rests with the owner (end user, seller, distributor, manufacturer, designer, applicant etc.), and recalling or replacing a design that is already distributed and in use can be very expensive. Proper review and checking before an application for CRN registration is submitted should be welcomed, not criticized.

Optimize registration costs by minimizing CRN application delays and mistakes.

Before an application for registration is submitted, ensure that your registration application contains the required information, that the information it contains is correct, that it is well organized with interconnected consistent documents, and that the design meets or exceeds all required regulations, code and standard requirements.