Registration of Fittings – Changes Since 2005
PVE, Last Updated: October 7, 2011, By: LRB
The requirements to register fittings have changed significantly. Around late 2004/early 2005 we started getting phone calls from companies having difficulty renewing their CRN registrations in various Canadian provinces. We started doing calculations and drawing sets to get lines of valves, sensors and other pressure products registered. Prior to this time we did almost none of this type of work.
What had changed? Why did these manufacturers need engineering help now, and not before? The manufacturers were providing the jurisdictions what they had always provided: signed statutory declarations; a copy of their product catalog; and a copy of their ISO or other QC certificate. But no longer was this enough to get their products registered. They now had to send in additional proof of burst tests and/or calculations along with detailed product drawings – the same requirements as if they were registering a pressure vessel.
The 1997 B51 standard outlined the requirements to get a CRN for a fitting (B51 – 4.2.5): As a minimum the following documentation in support of an application is required:
- Statutory declaration
- Designation of the code or standard
- Material specifications
- Maximum allowed working pressure
- Maximum working temperature
- Detailed calculations and/or copy of proof tests witnessed by an Authorized Inspector acceptable to the regulatory Authority.
- (not listed) Proof of an acceptable quality control system must also be shown
By the 2009 edition, the list had changed slightly but not significantly. The Canadian code had not changed; the jurisdictions decided it was time to enforce it.
Prior to 2005 CRNs were routinely being issued without items (vi) and (vii) above. It was so easy that the services of a company like ours were not required. As we did more fitting renewals, we found that there had been an earlier even easier registration method – submit a statutory declaration and a catalog (without proof of the QC program). The original intent of the statutory declarations became apparent – the manufacturer was swearing that the QC program and the calculations existed, but were not including them in the registration package. Companies still have to fill out statutory declaration forms, but their purpose is no longer to declare that the missing information exists – all information must be provided.
This change in requirements caused significant difficulties for some manufacturers as widely used clauses such as B31.3 304.7.2(a) – extensive successful service -were no longer acceptable. Other difficulties included providing material specifications acceptable under B31.3 323.1.2 and getting previously run proof tests accepted under the requirements of Section VIII-1 UG-101. We also believe that some companies were declaring that non-existent calculations or proof tests existed.
The changes resulting from this are twofold: 1) – some products that were previously registered in Canada are not being renewed; and 2) those that are being renewed are being done at a much higher cost. Manufacturers are now spending $10,000 to $50,000 to register a few pages out of a catalog which had previously been completely registered for $3000. The review times are also much longer. It is not unreasonable to budget one year to do the calculations and get Canada wide registration of a series of fittings.
It will be a few more years before all fittings registered under the old methods expire upon their ten year anniversary. At that point will Canada have the world’s safest pressurized equipment or will we be trying to cobble together marginal systems from a selection of available parts that is too small?