Do I need a CRN number?
Determining the kind of CRN number you need is not simple!!
A Few Important CRN Questions For Us to Ask, First....
There are few underlying questions that need to be answered first, including:- First and foremost, if you're a seller, distributor, or manufacturer, where is your market? If you're an end user, where is the place that the equipment will be installed? In other words, where in Canada will the equipment be used? You need to know this, since Canada has 13 separate, distinct jurisdictions that govern pressure equipment. Each one has their own legislation governing pressure equipment pursuant to public safety and, though all the jursidctions refer to CSA B51, CSA B52, ASME codes (ASME Section VIII-1, ASME Section I, ASMe B31.3, ASME B31.1, etc) and referenced standards (ASME B16.5, B16.9, B16.11, B16.34, MSS-SP-***, etc.., each jurisdiction has its own set of exemptions and/or directives. If an exemption from CRN registration is applicable for where your market or equipment installation will be, then CRN registration will not be required in that jurisdiction. See questions 2 and 3 noted below for more.
- Second, what type of pressure equipment are you considering? Is it a pressure vessel, some fittings, a piping system, a thermal liquid heater, a thermal liquid heating system, a boiler part, or a boiler, etc.? To determine what exemptions from CRN registration would apply if any, you'll need to know the type of equipment referred to in the jurisdiction's statutes and regulations. Types of equipment are referred to in the statutes and regulations in accordance with the definitions they contain or refer to.
- What are the design conditions of the equipment in relation to maximum pressure and temperature, inside diameter, and volume, etc? This information is needed to compare with available exemptions that may apply and that depend on these things.
And a Few General Comments to Consider:
- Many regulations refer to something called an 'expansible fluid'. Though definitions for this differ slightly from jurisdiction to jurisdiction, the gist of 'expansible fluid' means a substance that is a gas or vapour when exposed to atmospheric pressure or temperature. For example, pressurized steam existing in a pipe as liquid that expands to vapor when suddenly exposed to atmospheric pressure, is an epansible fluid. Similarly, liquid oxygen existing in a cryogenic tank at a very cold temperature that expands to a gas at atmospheric temperature, is an expansible fluid. And all gases and vapours at ambient temperatures are expansible fluids.
- A pressure of 15psig is the line demarcating where jurisdictional pressure equipment regulations often kick in. Expansible fluids above 15 psig are often subject to regulation requirements in the absence of any applicable exemptions.
- Boilers are somewhat unique in that some regulations don't require a boiler pressure greater than 15 psig before CRN registration is required.
- Some jurisdictions refer to CSA B51 Part 1 Figure 1(a), and some do not. In other words, for some regulators, 150F is a demarcation between where CRN registration is required or not.
- If no applicable exemption applies for the pressure equipment you're considering, then it will need to have a CRN number before it can be pressurized. Some jurisdictions require that a CRN numer is obtained before construction starts.
- Deciding on whether you need a CRN Number by solely considering whether your competitor has one or not, is not a good idea. Regulators are quite willing to fix whatever mistakes they may have made, and will not relieve you from CRN registration requirements eventhough your competitor did not register their equipment.
- Fitting registrations expire 10 years from when initially registered first by the originating jurisdiction. Without renewal before expiry, a new CRN number will be needed.
- Equipment in good condition that was manufactured in acordance with the CRN number requirements, with an acceptable quality control program while the CRN registration was current, is still registered even if it were to sit on a distributor's shelf for more than ten years before use.