CRN Training

CRN Reconciliation, Harmonization, History, and Public Safety

CRN harmonization vs CRN reconciliation. Are they different things?

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. 

 

Canadian Registration Number

Cammar Corporation Discusses Selected CRN Issues: Part 1

Recently, Cammar Corporation was asked to deliver a presentation to pressure equipment industry professionals in Drayton Valley, Alberta, about Canadian Registration Number (CRN) topics of interest. Check out the video below for a brief introduction to some of the CRN issues that were presented.


If the content of the above video is something that would benefit your business or organization then I invite you to contact Cammar Corporation to schedule a CRN training session/presentation.


About Canadian Registration Number (CRN) Training:

Cammar Corporation can tailor training agendas and schedules to suit your needs.  The recent Canadian Registration Number training session in Drayton Valley was one and a half hours in length and included topics like:

  • Documentation requirements for CRN / pressure piping applications and construction reports
  • Pressure testing requirements and responsibilities relating to components and assemblies
  • Fitting modifications and procedures
  • Issues with intermixing components from different manufacturers
  • Priorities in building a QC program (Quality Control program content was discussed such as quality manuals, quality procedures and quality work products)

The training can be held at your workplace or place of convenience to deliver customized presentations about pressure equipment topics of most interest to you and your colleagues. Ordinarily if the presentation is in a conference room with about 15 people or less, the participants will be asked to introduce themselves so that they can mention any questions that they have on their minds, so they can be addressed during the presentation.

If the presentation is to one company and their representatives alone, then this allows for a detailed questions-answer period where confidential information can be discussed and solutions relating to their particular specific issues can be identified.

About the Facilitator:

Cameron Sterling MSc, PEng, Director, Cammar Corporation
Cameron Sterling is the Director of Cammar Corporation and he’ll be facilitating these learning sessions.

Cameron has been a professional engineer in Canada since 1991 and is registered in Alberta with APEGA (Association of Professional Engineers and Geoscientists of Alberta) and Ontario with PEO (Professional Engineers Ontario).

Cameron provides engineering expertise in relation to pressure equipment design evaluation, compliance, and registration (CRNs). All of these topics are related to helping clientele obtain Canadian registration and to enhancing public safety.

His past working experience at ABSA as a Safety Codes Officer and NB Commissioned Inspector gives additional value and expertise to training sessions provided by Cammar Corporation. With a relatively high per capita concentration of pressure equipment in Alberta, ABSA is a very significant pressure equipment regulator in Canada. Experience and expertise enhanced from working at ABSA is very valuable to industry.

Cammar Corporation has a lot of experience to share about pressure equipment design evaluation and CRN registration. The comments in this presentation series are general in nature, so please bear in mind that specific topics relating to your particular situation deserve greater attention and advice tailored to your particular circumstances.  We would be pleased to speak with you about your particular projects in more detail.

For further information, stay tuned and for Cammar Corporation to tailor a presentation to meet your needs, don’t hesitate to contact us at your convenience.