CRN Review Times and Cost

Updated Oct 6, 2014, LRB

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Average Registration Time and Cost

How long will it take to get a registration? How much will it cost? We get asked these questions every day. We have used the full data from our registration database to answer these questions.

Through these graphs you can see global financial crises, the rise and fall of resource pricing and the effect of employees taking leave from and returning to their jurisdictions.

In our experience, registration times, fees and overall stress level vary on 3 key variables: Most importantly who the review engineer is, secondly the complexity of the job and finally the province it is being registered in. The graphs here examine only the last and least important variable so the results can only be used generally.
Graph of CRN review volume by province.
The 2907 completed registrations shown in this graph clearly show both the global financial crisis affecting all provinces combined with changes in resource pricing affecting fewer provinces, both happening at approximately the same time. As of late 2012, our CRN registration volume has finally recovered to the levels seen before the crash of 2008.

Why so many more jobs in Ontario than anywhere else? Although most provincial engineering societies have tried, TSSA was told by PEO, and agreed to only let local Ontario engineers sign off on vessels registered in Ontario. This is unique in the world of pressure vessels and is the age old local engineer vs specialized engineer argument.  Regardless of how you feel about this, we provide review and P. Eng. stamping services for many customers who are able to deal with the other jurisdictions on their own.  More information on the Ontario only registration requirement can be found in this letter to the editor of Engineering Dimensions, Ontario’s Professional Engineers magazine:

PEO Protectionism

Michael Mastromatteo’s article discusses the challenges PEO has in regulating projects outsourced to other countries. It does not discuss another side–the problems out of-province and international manufacturers have in getting their mass-produced products that they ship worldwide into the Ontario market. My industry – pressure vessel manufacturing – has recently been affected by PEO and its actions on engineering outsourcing.

Pressure vessels used in Ontario are designed and built to internationally recognized ASME standards. They are subject to Ontario Regulation 220/01–Boilers and Pressure Vessels that states, “The design for a boiler or pressure vessel shall bear the signature and seal of a professional engineer who is experienced in the design of boilers, pressure vessels, piping or fittings.” Gordon Sterling, P.Eng., then President of PEO, wrote a letter in April 2001 to the Technical Standards and Safety Authority (TSSA), stating: “While we acknowledge that many professional engineers outside of Ontario may have the appropriate skills to design boilers and pressure vessels, they are still required to be licensed by PEO to ensure that they are accountable to the people of Ontario through the Professional Engineers Act.”

TSSA, who regulates pressure vessels, from the simple mass-produced air receiver found in a home garage, to the giant custom industrial vessels, now only registers new or modified pressure vessel designs sealed by an Ontario engineer’s stamp. Prior to 2001, engineers licensed in other provinces or countries could get their designs registered for use in Ontario.

Although Ontario is the only place in North American to have such a requirement, this would not stop others doing the same. In the worst nightmare scenario, all the other states/provinces would create legislation to allow them to do what we have done: a vessel design would require about 60 engineers’ stamps to gain access to the North American market. Although I cannot imagine this happening, others would only be doing what we have done first.

When we look at outsourcing, we must get past the not-engineered-in-Ontario mentality, and accept that other engineers in the world are capable of doing engineering work with the safety of the public at heart.

Laurence Brundrett, P.Eng., Waterloo, ON

Published: May/June 2004 issue, Engineering Dimensions magazine

Our Ontario volume is also affected by our location – we are also located in Ontario and get involved in Ontario maintenance and construction jobs.

Graph of average review times.
Registration times are the most contentious aspect of the CRN process. The above chart is an average per jurisdiction. Times are total from submission date to receipt of CRN. Included is all time taken by the jurisdiction and the time taken by us and our customers to answer all questions.  Also keep in mind that review times change with the assigned reviewer and with the complexity of the job. A typical chart for one province looks like this (real data):

A graph of the review times for a typical province

Averaging the data makes it much more understandable, but unfortunately hides important variances in the data.

Individual Reviewers

Variation between reviewers within a jurisdiction is very important. Experienced jurisdiction reviewers are quite capable of examining a submitted project and summarizing all of the important issues in one shot. You have to wait for this reviewer to get to the job, but once they are working on it, the issues can be resolved quickly and a CRN granted. Unfortunately a new method of registration is gaining prevalence – a fast review is being promised, but it does not cover much of the scope of registration. The job is then put to the back of the pile and examined many more times, a couple of questions being asked each time. Sometimes the same questions get asked several times due to the long time spans and generated confusion involved.

Graph of CRN Review Times for two reviewers in the same province.

This graph shows the difference the reviewer makes (real data over the same time span). These two reviewers both work for the same province. Reviewer B costs one third as much per review, and did three times as many reviews for us over the same time period compared to reviewer A. Reviews are charged out by the hour. Over this time period both reviewers worked the same number of hours for us and generated the same revenue for the jurisdiction.

Review times are most closely related to review style. Reviewer B does a complete review and asks all questions at once. Reviewer A does a partial review, asks a few questions and then puts the job to the back of the pile – once the job comes back to the top it is reviewed again and a few more questions asked.  Sometimes the job is closed, and a new application that answers some of the questions before file close are answered.  The difference in review costs is multiplied many times by the time you must spend answering questions and making revisions before the project is finished. Again, times are total from submission date to receipt of CRN. Included is all time taken by the jurisdiction and the time taken by us and our customers to answer all questions.

Reviews are abandoned when no answer can be provided to satisfy the reviewer’s questions. The project has to be closed down and the review fees paid. In this case Reviewer B caused no abandoned jobs but 21% of reviewer A’s reviews were abandoned and all fees had to be paid. Cost for reviewer A is $ 1,259 per successful review, 3.4x the rate of A.

Which reviewer would you want on your project? No other variable comes close to the differences between reviewers – something you have no control over.  This is the most important variable in the registration process.

More on Registration Time – Updated Oct 2014

Yes, the above data was for the province of Alberta – everyone seemed to know, even though we did not originally state it, and most people we talked to could identify who reviewer A was.  However, these differences, to a lesser extreme can be seen in other jurisdictions, and to a lesser extent, in Alberta today.

Unfortunately the original graphs were a bit confusing. The data is more understandable when re-graphed:

Graph of CRN Review Times for two reviewers in the same province.

As mentioned above, Reviewer A cost 2.7x as much per job (3.4x if revenue is divided per successful job), took 2.5x as many weeks per job, completed 1/3 the number of jobs for us, but generated the same revenue for ABSA from us. The number of jobs abandoned – no way forward could be found to obtain registration – at 21% is without match. Differences like this one can be found in other provinces, but not as extreme. The assigned reviewer remains the most important variable in registration costs and time regardless of the province. As of 2014, Reviewer B has been promoted within ABSA and reviewer A has left.

As an illustrative example we had a simple valve registration job stuck on reviewer A’s desk for 4 years (PVE-4768). The project was complicated by using 12L14, a commonly used, but not code listed material of construction. During the long process of registration new issues were raised on a 2-3 month interval. The project was complicated by being closed multiple times by the reviewer – we had to re-apply while answering questions to keep the project moving. When reviewer A left ABSA, the file was passed to another reviewer and registered within a week, no more questions.  We doubt otherwise that this project would ever have been completed. Due to the timing of this project, it is not included in the above statistics.

Most of our ABSA rejections came from this one engineer, raising the question: is it time to re-examine other rejected jobs to see if they can now be registered?

Registration Cost

After delivery time, the second most common question is the cost. Here are our average costs for 2011, our most recent study.

Chart of average review cost in 2011 by province.

* We make heavy use of Ontario’s expedited registration services (at 2x the regular service rates), and we start many of our Canada wide jobs with Ontario, providing proof of registration to other provinces to reduce their costs. (See B51 4.2.2 that allows one province to rely on the review of another province). If your application is submitted with regular service, expect fees roughly 2/3 of the value in the chart.

** The ACI number is an average of both single province/territory and multiple province / territory registrations. We budget $1200 for registration in all ACI member provinces/territories, and approximately $400 for a single province or territory.

A graph of the costs by province.

Average costs per jurisdiction per year. Alberta average costs can be seen to rise as large oil sand projects are being built again like in 2008. The reason for the Ontario price increase from 2009-2011 during the economic downturn is not known and is not matched in the other provinces.

Graph comparing review costs from 2006 to 2012

The graph shows how much the cost of registration can vary. For example, the Ontario average is $768 for 2011, but the range for all our data is from $100 to $10,000 representing projects that varied from simple to anything but! Be careful using averages.

As a guideline, we often suggest that customers budget $5000 for jurisdiction fees to get a vessel or fitting registered across Canada. Our customers are happier when the actual bill runs a bit under than when it runs over.

More on Registration Cost – Updated Oct 2014

To measure how registration costs vary by province and with time the same vessel would have to be registered multiple times across many provinces. We obviously do not have that data, but we do have something close. We handled 383 registrations for one customer across all of Canada from 2006-2014. Each vessel had two heads, a shell and 2-3 nozzles. Dimensions varied but the complexity remained the same. We consider these vessels to be standard designs with few complex components.

A graph of the costs by province.

ACI fees cover registration in multiple provinces and territories. The years 2007 and 2009 include some single province registrations resulting in lower average fees. Remove these years and increasing fees similar to inflation can be seen.

Alberta submissions were mostly registered by one reviewer. The fees varied from a low of $160 to a high of $800. It is important to remember that the registration process does not guarantee an engineering review in any province. Here the fees varied as the files were either spot checked or reviewed in depth. Using the past to predict future fees is difficult. Overall an increase in costs rising faster than inflation can be seen.

Ontario and Saskatchewan both sharply increased their per job review fees between 2009 and 2011. This also happened in Alberta, but it is harder to see in the Alberta plot. At the same time all Canadian jurisdictions were experiencing reduced registration work from the deep recession and the collapse in energy prices. Review work has since surpassed pre-recession levels and review fees have stabilized. In this data set, Ontario was usually used as the lead off jurisdiction for jobs we took Canada wide. The resulting proof of registration was sent to other provinces to reduce their review burden.

Manitoba fees have increased roughly with inflation and Quebec’s are practically flat.

Remember, these vessels are on the lower end of the complexity scale and the fees are also on the lower end of what we see.