Last Updated Nov 8 2016
Many people who have attempted to register fittings or vessels in Canada tell us that this is the most difficult task they have accomplished in their career. We listened to the stories about products not available in Canada: those who gave up in frustration, many more who didn’t even start. We have seen a surprising number of projects where the 3rd or 4th individual is taking a swing at getting CRNs – hoping that if they try one more time they will have better luck. Their predecessors changed jobs to avoid the pain. Shockingly, the biggest obstacle they have to overcome is finding out what the Canadian / provincial / reviewer registration requirements are.
The struggle in getting jurisdictions to answer questions, and having the answers stick once submissions are made is tough. Extremely long incremental review times which get stuck once minor issues are found is still happening, but fortunately less common. Changing requirements once one province has signed off and the job goes on to others also cause a lot of pain. High costs of registration are also mentioned, but often turn out to be trivial compared with the associated in house costs. (And also those products that were supposed to be registered before going into service but never were…)
This website was written with the hope of creating a list of guidelines that could be used universally to get acceptable CRN reviews. Just do A then B and Finally C – presto here is your CRN – works every time. Although it is unlikely that the CRN system will ever become uniform enough across provinces or reviewers, knowing the requirements and doing your best to meet them before submission remains your best approach. Doing it yourself, or getting expert help from a company like ours, this article is your high level introduction. Other articles on our website contain more in depth information and specific guidelines.
Our system is not always difficult, slow or expensive. The better your submission, the better your results. Just what should be submitted? Some companies use our services to learn the system and carry on themselves, others use us for every registration. Know when you need help – we are here to lend a hand!
What Gets Registered?
What Gets Registered?
Both Canada and the United States use the ASME Section VIII-1 code for pressure vessel construction but Canada has a CSA B51 standard that provides a more restrictive definition of what a PRESSURE VESSEL is. Canada also registers FITTINGS – items that in other countries would be considered too small to need registering. Likewise we also register many PIPING SYSTEMS in Canada. All vessels, fittings and piping systems need to be built under appropriate quality control programs.
Key Point: Canada’s system is more restrictive than other countries.
Who Does the Registration?
Who Does the Registration?
Each province does its own registration and provides a CRN number which is put on the vessel nameplate. The Atlantic Canada provinces and the northern territories have joined together to use one registration organization, ACI Central. We have 13 provinces and territories, but to register across all of Canada, you must register with 7 Organizations or Jurisdictions.
Key Point: Canada’s system is really a series of provincial systems. Calling the registration system a Provincial Registration System would be more appropriate.
Key Point: You must register in EACH and EVERY province you will be using your equipment in.
See Provincial Contacts and Requirements for the jurisdictions.
How Do I Apply for a CRN?
How Do I Apply for a CRN?
You need the following paperwork:
The appropriate Fees if the Jurisdiction requires payment up front (Saskatchewan only).
Specific Cover Forms required by the jurisdiction – see Provincial Contacts
A printed Drawing – number of copies and requirements to have a P. Eng. Stamp varies by province – see Provincial Contacts for details. The drawing is expected to be complete with all details required to order the material and fabricate without having to refer to the calculation set.
Calculations done to an acceptable code. See our ASME Samples section for examples of matched drawings and calculation sets suitable for CRN registration.
Proof of Quality Control program. The QC program must be suitable. For example, a copy of a National Board + ASME U Stamp registration would be suitable for a VIII-1 vessel registration. An ISO 9001 with appropriate scope or ASME Stamp could be suitable for a fitting.
The correct number of Statutory Declaration forms for fittings. If registering more than one category of fitting, separate statutory declarations will be required for each category. Each jurisdiction has its own statutory declaration form – do not use the wrong one. If more than one category of fitting will be included in a submission, statutory declarations will be required for each category. The required number of statutory declarations per jurisdiction can be found on the Provincial Contacts page.
Used vessel requirements, the following are required: nameplate photo or rubbing, Ultrasonic Thickness (UT) test results with level II signoff if the vessel is subject to corrosion, location of installation and U1 form.
Fitting registrations also require Statutory Declarations. The Alberta web site has a guide to filling out Statutory Declarations. Statutory declaration forms are confusing – please fill out the forms carefully.
Applying for Registration in One Jurisdiction or More
To register your design in one jurisdiction, determine where your product will be used (watch out for ship to addresses that are fabricators who will send the finished product to other provinces). Submit all of the required information to that jurisdiction. They will review your submission and return a CRN. If your product is a vessel, the CRN is stamped into the nameplate.
Getting your design registered in more than one jurisdiction is a bit more difficult. Start your registration in one province. Once accepted, the proof of registration can then simultaneously to other regions, which would also review your design, and if all goes well, would also register it. See our Guide to CRN Numbers for more information on how this works.
The process can get more difficult. Often the jurisdictions have questions which were not covered by the first review, and additional information is required (each reviewer has its own rules and requirements). If changes to the drawing or calculation are required, then the changes have to be sent back to the first jurisdiction to accept, and update the CRN number, then it has to be sent out to the other jurisdictions to accept.
Further note: Just because one jurisdiction accepts a design, it cannot be assumed that others will as well. It is not worthwhile looking for the “easiest” province to get a design registered in first. It is more worthwhile to get the fussiest, pickiest province to register the design first, and then submit the design to other provinces that often come back with fewer questions about the design.
What about National Board?
What about National Board?
Saskatchewan is the only province that recognizes the internationally recognized National Board registration system as an acceptable alternative to CRNs, although an additional Saskatchewan filing fee also has to be paid per vessel. [Update: Saskatchewan now only accepts National Board as an alternative for registration on used vessels]. Vessels that are CRN registered can also be National Board Registered if desired. If a vessel is built outside of Canada for Canadian use, it must be both CRN registered and National Board registered.
From B51-14 page 20 188.8.131.52:
Manufacturers in countries other than Canada that manufacture and export boilers and pressure vessels to Canada shall ensure that all boilers and pressure vessels are stamped with the appropriate ASME Code product certification mark and registered with the National Board.
Key Point: Fabricators outside of Canada must also register with National Board.
Updated Nov 2015, for Ontario:per Ontario’s Code Adoption Document (BPV-13-01, 1.20): Registration with the National Board of Boiler and Pressure Vessel is not required (applies to Ontario only).
Those who take a historical interest in rules and regulations would find strong correlation between Canada’s current system and the American system before the development of the National Board registration system in 1919-1921. History of National Board
When Should I Apply for a CRN?
When Should I Apply for a CRN?
The CRN should be applied for before construction begins. To quote B51 –
Acceptance and registration shall be obtained before construction is commenced.
For a foreign manufacturer who has a finished vessel, and has been told on the shipping date that the vessel is bound for Canada, this can be a problem. In reality, this requirement varies by jurisdiction.
The Ontario vessel act offers this alternative:
4.(2) A person who submits a design submission for registration may commence construction of the boiler, pressure vessel, fitting or piping before the submission is registered if the person assumes all risks related to the construction, whether for an installation or alteration.
The CRN can usually be applied for at any point in the construction, the risk is that if any changes are required from the review, the vessel will need to be reworked or scrapped. The earlier the CRN can be applied for, the better. See the Provincial Review Times page. Many Canadian manufacturers really do not wait for their CRN before starting production – it takes too long.
Key Point: Register as early as possible! Allow for unusually long review times. Do not accept liquidate damages clauses on contracts bound for Canada if you are responsible for the registration!
Is My Quality Control System Acceptable?
Is My Quality Control System Acceptable?
Pressure Vessels and Boilers: ASME U stamps are required for pressure vessels signed off by National Board Inspectors. See TSSA’s list of acceptable inspection agencies.
Piping: requirements vary by province, see the QC section on the Piping – Do I Need a Registration Page?
Fittings: two things must be met :
- 1) the requirements of B51 Annex F “Quality control program for manufacturers of fittings” must be met, and
- 2) the program must be 3rd party audited (although this is not a requirement of CSA-B51, this is mandatory). Various 3rd party audited programs can be acceptable ranging from ISO, TUV, Mil Spec, ASME LLoyds, ABS, Det Veritas and provincial B51 programs. The party doing the auditing must be acceptable to the reviewer.
See TSSA document Guidelines for the Registration of Non-nuclear Fittings in the Province of Ontario for further information. Usually a QC program is accepted based on the scope as written on the certificate without review of the actual program. Sometimes the scope as declared on the certificate is not clear or acceptable leading to a review of the actual program. For example many TSSA B51 piping programs only cover the scope of manufacturing piping systems and can not be used for the manufacture of fittings. Remember that the program only has to cover those items of the B51 Annex F that actually apply to the manufacture of the fitting being registered. For example it is not required to have a program cover welding if the fitting is made only by machining. From B51-14 “The program that the manufacturer uses shall be suited to its circumstances and reflect the complexity of the products produced.”
Frequently Asked Questions
Frequently Asked Questions
Do I need to hydrostatically test my fitting? Hydrostatic or pneumatic test requirements for a fitting depend on the standard that the fitting is designed to.
For example if B31.3 is used as the design code then: “Prior to initial operation and after completion of the applicable examinations required by para. 341, each piping system shall be tested to ensure leak tightness.” (345.1)
For example if B16.5 (pipe flanges and flanged fittings) is used as the design code then: “Flanges are not required to be pressure tested” (8.1) however, if the item is a flanged fitting, then “each flanged fitting shall be given a shell pressure test” (8.2.1)
For example if B16.9 (factory made wrought buttwelding fittings) is used as the design code then: “Hydrostatic testing of wrought fittings is not required by this standard.” (10)
For example if B16.34 (valves – flanged, threaded and welding end) is used as the design code then: “Each valve shall be given a shell test…” (7.1)
For example if VIII-1 (pressure vessels) is used as the design code then: “A hydrostatic test shall be conducted on all vessels…” (UG-99(a)).
What happens if I Don’t apply for a CRN? There are a large number of fittings, piping systems and pressure vessels in use in Canada that require CRNs but were never registered. These products are often uncovered during authorized inspector visits or insurance audits. If a product is discovered while it is in use, then someone has to go through the effort to get it registered at that point. If it cannot be registered then it must be replaced.
I can’t get my jurisdiction to answer my questions – what should I do? First ensure you are giving them all the information they need to answer your question? We suggest submitting the application in writing along with all required information. Include a purchase order and required upfront fees the same as if the product is being registered. Ask for a response in writing. Having a letter on file stating that your vessel does not need registering is useful during an audit. Saying that you talked to someone and they said that your vessel was okay will not work.
What paper work do I need to get a CRN for a Vessel or Fitting? See How Do I Apply for a CRN?
Do I need a professional engineers stamp on my submission? See Provincial Contacts
How long will it take to get a CRN? How much will it cost? Is it worthwhile? See Review Times
Do I need to update my Pressure Vessel calculations with each code revision? Manufacturers have to re-run or review the calculations each year to determine that the design is still valid. The authorized inspector confirms that the calculations are current or reviewed. (This is the same requirement for National Board fabrication.)
What Material can my Fitting be made from? SeeUnlisted Materials
Can I make my Fitting from plastic? Yes – see Registration of Plastic Fittings
How long can I manufacture Pressure Vessels to my CRN? The CRN for a pressure vessel is valid for the life of the vessel. For a manufacturer, the CRN can be used until the code changes enough to require the design to be changed.
How long can I manufacture Fittings to my CRN? The CRN for a fitting is valid for 10 years. After that time, the design must be re-registered. For a fitting registered across Canada, all the CRNs expire once the first CRN expires. The expiry date is written on the documentation you get back from your jurisdictions.
Do I need to update my Fitting calculations with each code revision? Calculations are not normally updated until it is time to re-register the design.
I manufacture a fitting that will have my customer’s name on it, not mine. How do I register it? The logos that will be affixed to the product need to be indicated on the statutory declaration. Multiple logos can be registered. If the logos will not fit on the box on the statutory declaration page, put them on an additional page.
I need to change the design of my vessel. Do I need to get it re-registered? Typically the answer is yes. Some leeway is granted if the change does not alter the calculation set. For example, you add another nozzle to a vessel identical to one that already exists, and the nozzles are far enough apart that they do not interfere – no new CRN is normally required. If the nozzle requires new calculations, then normally the design will need registering. Enquire with your jurisdiction for more info.
Can I change the operating conditions on my vessel without re-registering it? Maybe – if the calculation set does not need to be re-run because of the change, then you might not need to re-register it. Call your jurisdiction.
I need to modify a registered vessel. Do I need to re-register it? If the calculations do not need to be updated then the answer is probably no – example, addition of a nozzle identical to one already on the vessel that is not too close to another nozzle – then you will probably not need to re-register it. You must contact your local authorized inspector. Note: work must be performed by a company with a valid QC certificate like an ASME “R” stamp.
I have a used vessel that was registered in another province. Do I need to re-register it to move it to my province?Yes – you need to submit the original calculations and drawings or re-create calculations and drawings if the originals cannot be found. Requirements vary, but most commonly the calculations need to be re-run using original year of construction stress allowables, but using the latest code rules. A photograph of the nameplate and the manufacturer’s data report are required. A used vessel might need some inspection like ultrasonic testing to prove that the vessel is still adequate. The installation location will be required. For typical requirements see BCSA. Note: for many older vessels the impact test requirements cannot be met.
I have a new vessel from another country. Can I get it registered in Canada? Maybe – are the calculations and drawings available? Is the code of construction acceptable? The most difficult vessels to register are done in codes other than ASME with non ASME materials.
I am importing a machine from another country that has a piping system that needs registering. Can I do this or do I need to scrap and replace the piping system? The piping system will need to meet all the requirements of a Canadian registered piping system – acceptable quality control program, acceptable materials, CRNs on all the fittings, calculation set, a drawing with identified code materials.
We have been involved in imported machines with piping systems not built to Canadian standards but requiring registration. The process can be very long and expensive (think more than 1 year). It is often easier to start from scratch.
Do I need to label the CRN number on my vessel? Yes – stamp the CRN number on the code nameplate. On my fitting? No, but the manufacturers logo (as shown on the statutory declaration form) must be visible on each part. Per CSA B51 2009-5.4 Fittings: Fittings shall be permanently marked as required by MSS SP-25. See MSS-SP-25 for specific requirements that vary based on the size and type of fitting.
Do I need a CRN for bolting or gaskets? No. Bolting and gaskets, while integral to the design of connections, such as flanges, are not considered pressure retaining components. Therefore, they do not require registration. Bolting and/or gasket information may be required by the connection manufacturer to calculation their design for CRN registration. For example, M & Y values for gaskets or allowable strengths for bolting material.
Do I need a CRN for a pump? No.
Do I need a CRN for an air compressor? No – but volume bottles between compressor stages and air receiver cylinders need CRNs.
Do I need a CRN for hydraulic components? No – except in circumstances of high operating temperatures. This varies by province.
Do I need a CRN for pneumatic cylinders? No.
I can’t get my product registered but my competitor who makes the same product the same way I do succeeded – is there anything I can do? Plan A – CRNs are not permanent – for a fitting it will expire after 10 years. You can wait until they try to renew and see if they get accepted. Renewal is not a rubber stamping process – full engineering documentation the same as an original submission is required. Plan B – Document and complain. CRNs can be revoked if you prove that a manufacturer is not following the rules of the codes that they claimed when registering. Start with the first province of registration – if that province cancels then all the other provinces will automatically be cancelled. Because we at PVEng Ltd. believe that there already is enough pain built into the whole CRN system by its design, we will not help companies with this un-registering process.
Can I have more than one manufacturer build FITTINGS for me under 1 CRN? Each fabricator would need to declare their own statutory declarations and provide proof of a suitable QC program. If the jurisdictions can register them together they will, otherwise separate numbers will be issued. This is most likely to work if each fabricator was a different branch of the same company.
Can I have more than one manufacturer build VESSELS for me under 1 CRN? Yes, all provinces except Saskatchewan allow this. The registration covers the design and assigns it to an owner. The authorized inspector will determine that an adequate QC program and suitable quality control procedures will be followed during the construction. Note that this assumes that all manufacturers have a legal right to build the vessel granted by the owner of the design. See Move or Name Change for more information.
Can I build more than one PIPING system from my piping registration? No – piping systems are registered to an installed address. Unless the installed address remains the same, then each identical copy would need re-registering.
TSSA’s guideline for non nuclear fittings.
You can purchase the Canadian B51 standard from CSA (1-800-463-6727 or 1-416-747-4044).
We also suggest reading the other CRN articles on this website.