Updated Yet Again – A New Hope
File: File:PVE-4703, Last Updated: Mar 19 2015, By: LRB
In spite of the ever increasing rules and mountains of paperwork required to register vessels and fittings in Canada, five provinces have been working on alternatives to make the CRN system work better in their provinces.
British Columbia has two innovations to make life easier for people dealing with the CRN system:
1 BCSA has set up a Reciprocal Designs registration process. If your design has previously been registered in Alberta, Ontario or with ACI, you can get your design registered for less than $200 in a couple of days. BCSA relies on the review done by the original province of registration as allowed by the CSA B51 standard [B51-14 4.2.2]:
4.2.2 Initial registration with one regulatory authority may be accepted by the regulatory authority in another province if the latter is provided with an accepted copy of the statutory declaration form and the supporting documentation…
We have found that this process works fast – it only takes a couple of days and saves money. We have also noticed a reduction in registration times associated with regular registrations as more jobs are done this way. Note that some restrictions apply.
2 BCSA (like TSASK below) does not require registration of Category A, B, C and G fittings of standard design. We have seen whole piping systems get registered only requiring a CRN on one fitting. There are restrictions on what fittings are exempt. More Information.
TSASK has three innovations to simplify the registration process:
1 Like BCSA, TSASK does not require the registration of Category A, B, C and G fittings. The BC additional restrictions do not apply.
2 TSASK allows the use of National Board only registered vessels in some cases.
3 Saskatchewan is one of two provinces that has joined CSA’s CCRN program.
Canadian Central Registration Number (CCRN) — a registration number, allotted by a nationally recognized organization such as CSA in accordance with procedures accepted by more than one province, that allows a fitting to be used in such provinces.
With Manitoba opting out of the program, now Quebec is the only other province that is a member of this program.
Inspection and Technical Services Manitoba is now issuing reciprocal registrations. Like B.C., reciprocal registrations can be issued based on the review being done by other provinces. We do not know yet which provinces are acceptable, and under what circumstances the reciprocal process will be applied. When applied the registration time has be reduced to half. Per the first review we got registered this way:
Note: CRN registered under reciprocal agreements & is conditional based on compliance with the notes set by the original issuing Jurisdiction: TSSA. See attached stamped “this is part of CRN” for scope of registration. This registration expires Dec 16 2024″
Quebec has two programs under way to reduce the scope of systems requiring CRNs and the complexity of registration:
1 Quebec is one of the two provinces that are a member of CSA’s CCRN fitting program. Unfortunately Saskatchewan is the only other member province for this program. We at Pressure Vessel Engineering currently register fittings directly through Quebec and Saskatchewan. CSA is currently trying to get renewed interest in this program with additional provinces, we wish them good luck.
2 Quebec is currently rewritting its legislation to reduce the number of piping systems and machines with piping systems that need registration. Also Quebec is planning to exempt Category A, B and C fittings of standard type from registration. The legislation is in process, but can be applied to jobs currently on the go. Contact RBQ for more information or if you wish to implement this prior to the legislation being finalized. The changes go beyond this – more preliminary details here.
Many of our customers have the most trouble getting CRNs in Alberta. The reasons are: 1) the volume of work is greatest in Alberta leading to long wait times; 2) Alberta has many unique requirements not based on pressure codes, only some of which are documented; 3) (this policy is no longer being followed)ABSA’s policy of putting a job on the bottom of the pile every time the reviewer needs to ask a question and .4) registration requirements that vary by reviewer. Although at this time we have outstanding jobs waiting for review for more than 1/2 year, many new submissions are being reviewed in less than 4 weeks.
Last year there were some important personnel changes in the ABSA: 1) chief inspector Dr. Lau has retired. 2) The design review department has been reorganized under Po Fok the new Design Survey Manager. There has also been turnover in the review staff beyond these reported changes. These changes have had a huge impact making it easier to deal with ABSA.
ABSA accepts registrations based on other jurisdiction reviews without re-review as permitted by CSA B51-144.2.2:
Initial registration with one regulatory authority may be accepted by the regulatory authority in another province if the latter is provided with an accepted copy of the statutory declaration form (see Figure D.6) and the supporting documentation specified in Clause 4.2.8.
When these reciprocal registrations are accepted, the review time is less than 2 weeks. We do not yet know under what circumstances reciprocal registrations will be accepted. We continue to be optimistic about ongoing changes at ABSA. A process that has been going down hill since 2007 is for the first time getting better.
These simple changes to the registration process show that there is considerable flexibility in the CRN system allowing many improvements to the system, when the jurisdictions are so inclined.