CRN Essentials

CRN Number Registration Problems, Pitfalls, and the Dreaded Loop of Despair

From my years worked at ABSA as a Safety Codes Officer, together with my engineering experience in industry and now at Cammar Corporation, I have a very good idea about what the CRN number registration process problems are, including its pitfalls.  I’ve evaluated and pointed out in detail the deficiencies for thousands of designs needing CRN number registrations.  Some designs were good, and some were – well, let’s just say that they needed improvements and more revisions than others.

The CRN Registration Process

The generalized CRN number registration process is sketched below for reference.  Note the loop of despair.

CRN Number Registration Problems, Pitfalls, and the Dreaded Loop of Despair

Regulator’s Role

During a review, the regulator decides whether to accept and register a design in accordance with provincial legislation, with a focus on safety and technical aspects.  They should be satisfied that the design meets the requirements of the legislation and is designed in a manner that protects the public, before it is registered.  The regulator can consider whatever design information it wants to for it to reasonably decide that a design is safe, but what it considers (or doesn’t consider) is up to them.  They do not approve any designs, and instead accept or reject them.  They are not the owners of designs and are not responsible for them.

If a regulator determines that a design application is deficient in some way, is not safe or does not meet the adopted codes etc, the design application can be put on hold awaiting a revision or can be rejected, at the regulator’s discretion.  If put on hold, then it enters what we call the dreaded loop of despair and, unless the required revision is provided, the application will remain there until rejected or withdrawn.

Hopefully regulators will continue to proactively review applications as thoroughly as possible and continue with detailed design evaluations.  But given the somewhat recently published statistics (see below), the temptation and pressure to fast track the process by eliminating proactive independent third party reviews must be high.  Succumbing to that pressure and temptation would be, in Cammar’s opinion, a mistake and a race downhill that nobody, including the public, would win.

 

Dreaded Loop of Despair

How many applications enter the dreaded loop of despair? Well, published numbers are scant but ABSA alone reported that in 2014, of the more than the 10000 applications it received that year, more than 50% were deficient (see page 2: ABSA article) and could not be accepted without a resubmission.  This is quite shocking and means that during that year more than 5000 applications either went into the loop of despair and required a revision of some kind, or were rejected or withdrawn.

If a purchase order is cancelled or if production is delayed due to the loop of despair, then associated costs to industry can obviously be large.  But they would potentially be even larger with the use of unsafe or illegal equipment, so it’s good that the bad applications were caught.  Registering applications without detailed third party evaluation and instead conducting audits after registration and sale or installation etc would be, in our opinion, fraught with risks for manufacturers, end users, and the public.  If a deficient product is mistakenly registered and installed, what then?  Recalling a product after installation would certainly cost far more than fixing it on the shop floor before any sale.  And how much reactive auditing after registration would ensure the same level of safety as proactive reviews?

 

Avoiding the Loop of Despair

Avoiding the loop of despair while maintaining a high level of quality is, in Cammar’s opinion, key to public safety.  Strategies for this will be discussed in the next blog article.  Stay tuned.

Is a CRN Number Required? When and Why.

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.

When Should I Apply For a CRN? And Why.

When should a CRN application be made?  This is a common question. After all, knowing when you should apply for a CRN number is important.

Some people only want to know what they ‘must’ do, and they want to know the difference between requirements and suggestions. And though ‘should’ apply for a CRN really means ‘must’ apply for a CRN in normal circumstances, the same people might instead consider ‘should’ to somehow mean a suggestion and will go on endlessly as if there is somehow a misunderstanding as to what is required.  And they also want their ‘musts’ listed in bullet form. Thankfully, there aren’t many of those people around.

But for those people and the rest of you, please be assured that ‘should’ in this instance is really a polite way of saying ‘must’. And at risk of upsetting my web editor for using sterile and unfriendly language, and to appease those who dislike reading too much, here is a bulleted list that inherently includes occasions when a CRN should (must) be applied for and when CRN registration should (must) be obtained:

  • Before operation in Canada

Pretty simple eh?

And it gets more complicated. Believe it or not, legislation and CSA B51 state that CRN registration is required before construction. So this means that an application should (must) also be made and CRN registration should (must) be obtained before the equipment leaves the shop, is shipped, is purchased, or is installed.

The list gets longer with the details. Here is a more detailed bulleted list that includes occasions when a CRN should (must) be applied for and when CRN registration should (must) be obtained:

Before

  • Construction.
  • Shipment.
  • Offer To Sell.
  • Purchase.
  • Installation.
  • Operation in Canada.
  • Alterations to existing pressure equipment commences.

Practically speaking, operation under pressure delineates a line between what modern art and pressure equipment is. Nevertheless, the law refers to CRN registration of designs when the equipment has not even been built yet, and designs are at the finalized stage.  So, why should (must) CRN registration of designs be acquired at such an early stage?

Besides abiding by the law, there are two reasons that come to mind:

    1. Nobody wants to necessarily fix equipment to meet the requirements of a CRN number issued after construction. For example, there is no greater pain than for someone to realize that installed equipment is unregistered and a startup needs to be delayed to fix it. Hence before pressure equipment is even constructed, it should (must) be registered to avoid potentially huge headaches and costs.
    2. Canada does not need or want unregistered and illegal pressure equipment made, shipped, sold, purchased, installed, or operated. It is not worth it.

Obviously not all pressure equipment in the world already has a CRN yet – but we’re working on it!

All this leads to another question, is all unregistered pressure equipment that is already built necessarily unable to be assigned a CRN number?   Hmm…, of course not, though some situations are certainly more challenging than others.

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.

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.

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.

Generic CRN Registration Cammar Corporation

Generic CRN Registration

It makes the most sense to include as many options as possible in a generic CRN registration to minimize the frequency of applications. In general, it is up to the applicant how they want to organize their CRN registration applications in accordance with model numbers, equipment use, markets, etc.

To help optimize the registration process, it is important to consider what a generic design is and if it makes sense to use in your circumstance.
When a design includes options or variations, the design is called generic. In other words, a generic design describes a range of options for the equipment. And if the design is described properly, in many circumstances only one CRN is required for a generic fitting or a generic vessel.

Except for category ‘H’ fittings, any number of model numbers and configurations of the same category can often be included in one generic CRN registration. For example, a bunch of control valves, ball valves, globe valves and butterfly valves are all inline valves and could all be included in a single category ‘C’ CRN registration number. Or a bunch of ASME B16.5 and custom ASME Section VIII-1 Appendix 2 flanges could all be included in a single category ‘B’ registration number. Similar considerations apply for pipe fittings (category ‘A’), expansion joints (category ‘D’), strainers, filters, evaporators and steam traps (category ‘E’), instrumentation including measuring devices like pressure gauges, level gauges, sight glasses, levels, and pressure transmitters (category ‘F’), and certified relief valves and fusible plugs (category ‘G’). Generic category ‘H’ fittings can also be registered but requirements are a bit more restrictive and akin to generic vessel registration.

Generic vessel CRN registration requirements are more restrictive. Authorized inspectors need to quickly ascertain whether a vessel design meets registration requirements or not. So, to avoid generic vessel applications where every conceivable option and geometry is proposed for registration under a single CRN number, some guidelines have been put in place by ABSA. In addition to ordinary design requirements, generic vessels are also to have:

  • fixed maximum allowable working pressure (MAWP)
  • fixed maximum allowable temperature
  • fixed minimum design metal temperature
  • fixed corrosion allowance
  • fixed head geometry and thicknesses
  • fixed diameter(s)
  • all relocatable and optional nozzles, together with their potential locations, identified
  • a nozzle spacing chart for relocatable nozzles meeting requirements of ASME Section VIII-1 paragraph UG-36 for pairs and clusters
  • only one nozzle configuration (neck thickness, internal projection, weld size and reinforcement) for each nozzle size, except for ASME Section VIII- paragraph UW-16(f) fittings

To achieve the maximum amount of spacing variations, nozzles normally exempt from reinforcement per ASME Section VIII-1 paragraph UG-36 should instead be reinforced.

Depending on complexity, generic vessel designs might take slightly longer for the regulator to evaluate and register, but if all possible variations of a vessel are included with one CRN number, it is of benefit to the design owner to register a generic design. Even complex generic designs can be described clearly so that registration is not significantly delayed.

CRN Renewal 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,
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?
Thanks,
I M Interested


Dear Interested,
In general:

  • 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.

Harmonizing CRN Process Benefits 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,
I read your article about harmonizing the CRN process, in which it is stated that we need CRN’s. I am puzzled about the benefit to the general public safety of this process for fittings, seeing that this is only practiced in Canada. How do we compete with countries that don’t have CRN process? How can we claim to have a higher standard of safety, when the rest of the world manages quite fine without CRNs for fittings? How do we produce a compliant design when equipment is available but without a CRN that the manufacturer does not see the need to apply for and register their product?
I look forward to hearing from you.
Concerned Ontarian


Dear Concerned Ontarian,
Thanks for your email.
Governments in Canada deem the CRN process worthwhile and pursuant to public safety, given that CSA B51 is referred to in Canadian legislation. CSA B51 helps to ensure through third party oversight that pressure equipment is designed, built and tested to codes and referenced standards that have, through careful collective deliberation, been written to help ensure public safety by using adequate safety margins and other considerations.
These codes and standards are adopted by legislation and stipulate minimum requirements. In some foreign locales where CRNs are not required, designs do not always meet minimum code and referenced standard design philosophies. And when they do not, designs are therefore less safe than those that do.
In Canada, pressure equipment designs meeting legislated requirements are competitive and registerable.
Public safety is, I’m sure you would agree, of paramount importance.

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.