PVE-4045, Last Updated: May 26, 2014, By: LRB

Q – If your company changes name or address, do you need to update the registration of your fittings?

A – Yes.

In Canada, fittings are considered to be small pressure vessels with the permission for inspection granted to the manufacturer under the control of the manufacturer’s quality control program, as specified and sworn in the statutory declaration. When the companies name or address changes, the statutory declaration on file with the provinces is no longer valid. The statutory declaration for each CRN in each province needs to be updated.

Changing the brand name to be affixed on the product is another case where the statutory declarations need to be updated. This case is not discussed below.

The following is required to update the CRN applications:

  • A cover letter explaining that your corporate name has changed or that your company has moved and that you are updating your registered products as a result.
  • A copy of the updated QC certificate issued in your new company name or new address (this is the plaque that hangs on your wall).
  • A copy of the original proof of registration (the original statutory declaration returned by the jurisdiction with the CRN number on it, or the letter of registration – whatever was returned by the Jurisdiction when the fitting was originally registered).
  • The correct number of revised statutory declarations covering the same scope as the original statutory declaration.
  • Additional requirement for Alberta and Ontario only – sometimes the entire original drawing and calculation package must be re-submitted for re-review. “Renewals are treated as original submissions.” This depends on the assigned review engineer. See ABSA notes below on how the name change will usually go.

Process:

Step 1 – get the original jurisdiction that did the first registration on the original CRN to update the CRN using the above listed materials.

Step 2 – included a copy of the updated CRN from step 1 with the above listed materials and send it out to all other jurisdictions.

Additional Information from ABSA:

The following clarification was received from ABSA regarding moving a company manufacturing fittings and vessels.

1. If a fabricator changes the name of the company, what is involved with updating the paperwork at ABSA?

  • Fittings Name Change – A separate submission for each CRN consisting of a new AB-31 application form, a new QC certificate, two new Stat Decs and a cover letter explaining the name change. No drawings or calculations are required as they are already on file at ABSA.
  • Fittings Add a Factory – A separate submission for each CRN consisting of a new AB-31 application form, a new QC certificate, two new Stat Decs and a cover letter explaining the new manufacturing location. Please note that the supporting documents referenced by the original statutory declaration must remain identical for the new manufacturing location.
  • Vessels Name Change- A letter of explanation outlining the name change and listing all of the affected CRN numbers is all that is required.

2. Can a company own a CRN on a fitting or vessel and have multiple fabricators manufacturer the design for them? Assuming valid QC documentation and Stat Decs (fittings only) for each fabricator.

  • Fittings – No. A different CRN number is required for each manufacturer. Each manufacturer must submit their own complete application package (dwg, calcs, Stat Decs, proof tests, etc…).
  • Vessels – Yes. However, if a different drawing number is used by different fabricators, they must all reference the original drawing that the CRN covers. The data report needs to show the original drawing number and any other fabricator drawing number should be shown in the remarks section only.

3. Can ownership of a CRN be purchased by one company from another?

  • Fittings – This will result in a new CRN being issued to the purchasing company due to the fact that new Stat Decs need to be submitted with a different manufacturing address.
  • Vessels – This would work the same as a name change. A letter of explanation outlining the name change and listing all of the affected CRN numbers is all that is required. Although Company A may purchase the registered vessel designs from Company B, please note that Company A is not just purchasing the design, they also accept full responsibility and liability of the designs including vessels that were previously built by Company B.

Costing and Timeline:

For our job where the brand name to be affixed to the product needed to be updated, the re-registration process took about the same amount of time as the first submission with design review – 8 weeks for Canada wide. The renewal fees at about $2000 came in at 85% of the original registration cost. The product was registered Canada wide both times, except for BC and Saskatchewan where it was exempt from registration.