May 4, 2015, LRB

I used to read a Canadian magazine that would only discuss the safety and reliability of specific cars once they were determined to be good. “Manufacturer X overcomes safety and reliability problems in their brand Y model” No bad news about their advertisers would ever be printed. I hated them for it, but now that it’s my turn to write about review agencies I can sympathize. Our line has been “some issues are too sensitive to write about here.” The review process is improving in Alberta, so I feel it is safe to discuss the improvements.

A topic of debate in our office is that there are enough design surveyors in Canada to get all jobs registered in a reasonable time frame (one week), but we cannot do this because too much time is spent re-reviewing work that has already been registered in other provinces. This then leads to the observation that once a jurisdiction can no longer keep up with its review workload, it will get buried by the extra work in managing the backlog and never be able to recover. ABSA is making the effort to both recover and reduce the amount of time re-reviewing.

Noted changes

We have noted some improvements in the registration process at ABSA in the last 9 months. ABSA has posted policy changes making these improvements possible in The Pressure News Volume 20, Issue 1, March 2015. The complete article, (with our comments) is below:

Design Survey Process Improvements

The number of design submissions has increased by 45% since 2010. In 2014, we received a record number of 10,500 submissions which had been climbing steadily over the last 5 years. More than 50% of the submitted designs have deficiencies and cannot be accepted the first time around. This sends them into a loop that involves putting the review on hold, resubmission, and repeated reviews until registration requirements are met. The process is inefficient and frustrating for both the submitter and Design Survey.

We submit more than 250 applications a year to ABSA so we contribute to about 2.5% of ABSA’s registration volume. The loop process was particularly bad at ABSA where by policy, submissions with issues were put to the bottom of the pile. This often resulted in 3+ month delays between rounds of questions, and due to the loss of continuity, the same questions would get repeated. This disastrously inefficient policy appears to have met its only just end – it has been abolished. This change on its own would be worth noting.

What are “design deficiencies” is a difficult topic, as what causes a project to be rejected varies by reviewer. We have seen a reduction in our rejection rate with the changes in personnel as noted below.

ABSA is actively working on improvements to design review processes in order to improve efficiency, reduce frustration, and decrease the turnaround time on design registrations:

1. More design surveyors are being hired – three new design surveyors started training in December 2014, and we are adding three more design surveyors in March.
2. For certain piping submissions , once we ensure that all required documents are submitted and have the required P.Eng. stamp and signature, we will register the design.
3. Design surveyors will use an ‘audit’ process to expedite design reviews for submissions from companies with a history of designs having few deficiencies.
4. Companies with a history of high deficiencies will see submissions rejected sooner.
5. Dedicated positions have been added to respond to general inquiries from clients.
6. We will continue to look for and implement improvements to the process for reviewing and registering designs.
7. We will accept designs registered by other jurisdictions provided that we receive the proper documentation.
8. We have added more administrative support staff.
9. ABSA technical staff have been seconded from the Inspections Department on a temporary basis to help with design reviews and registration.
10. Guidelines are being applied that will direct the ABSA review to higher risk items.

We have already experienced some of these changes. We have had projects reviewed by new surveyors. We have seen new applications processed much faster than in previous years. We have received reciprocal registrations based on review of other provinces:

This registration has been issued:
1. Based on TSSA’s review
2. Based on the Association of Chief Inspectors Policy on Reciprocal Recognition of Design Review for Fitting Design Registration

The above quote is from an application that was submitted first to TSSA. The Ontario expedited review took one week. The reciprocal ABSA registration only took 3 weeks. This is an interesting development as TSSA and ABSA reviews differ. This provides new hope for applicants who’s designs were rejected by ABSA, but obtained registration in the rest of Canada.

We feel that this change will result in more registration work being sent to other provinces first, in particular Ontario. The fastest review time from TSSA is a 2 week expedited registration (it sometimes happens faster). Followed by a reciprocal acceptance from ABSA without review which takes 2-3 weeks. The total review time of around one month is a considerable improvement. However TSSA is already very busy and removes expedited services when overloaded, but other provinces can also help.

Please note that this policy only applies to new ABSA applications. Applications currently in the stack still take up to one year for an initial partial review leading to full review or rejection, even if proof of registration from another province is included. Full review is being applied to the older submissions.

This change, when fully implemented takes us one step closer to the dream of someday only having to submit a design once, to one province or organization, to get complete Canada wide approvals…

Your Job

Back to ABSA’s article:

Design submitters can help: A check list has been added to the AB-31 application so submitters can confirm that all requirements have been addressed. Please make sure that your submission is complete. Deficient information could lead to immediate rejection. Please help us to help you.

In our experience, the assigned reviewer is the most important variable determining success or failure of an application. However, the quality of an application is the second most important. Extra effort applied to making a quality submission has a beneficial impact on the whole registration process.

We would welcome a return by ABSA to the times of 2000-2007 when they were the most helpful and resourceful jurisdiction in Canada, but we have seen these current changes make a big improvement.