Overview
1. Scope
This policy paper outlines TSASK’s position on changing the manufacturer of record on a Canadian Registration Number (CRN). This policy paper applies to situations where the manufacturer of record:
- undergoes a name change (ie. Company XYZ Limited becomes Company XYZ Inc.); and/or
- is acquired by a new organization.
2. Definitions
The following definitions are taken from CSA B51-14 Part 1:
- Canadian Registration Number (CRN) – a registration number, allotted by a provincial regulatory authority, that allows a boiler, pressure vessel, or fitting to be used in the province.
- Design – calculations, drawings, specifications, specimens, models, etc.
- Manufacturer – the company or person that manufacturers, completely or in part, a boiler, pressure vessel, fitting, fired-heater pressure coil, or piping. The manufacturer completes the product and is responsible for the end product.
3. Specific Code References
3.1. CSA B51-14, Part 1
Section 4 – General Requirements
4.1.6 The registration of a design shall not relieve the manufacturer of the responsibility for the design or construction of a boiler, pressure vessel, fitting, fired-heater pressure coil, or piping in accordance with the applicable Act, codes, and standards.
3.2. ASME Section VIII, Division 1, 2015 Edition U-2
U-2(b)1 The Manufacturer of any vessel or part to be marked with the Certification Mark has the responsibility of complying with all of the applicable requirements of this Division and, through proper certification, of assuring that all work done by others complies. The vessel Manufacturer or, when applicable, the part Manufacturer is responsible for the preparation and accuracy of design calculations to show compliance with the rules of this Division, and his signature on the Manufacturer’s Data Report Form shall be considered as certification that this has been done.
3.3. ASME Section VIII, Division 1, 2015 Edition Mandatory Appendix 10
Mandatory Appendix 10 – Quality Control System
10-1 The Manufacturer or Assembler shall have and maintain a quality control system which will establish that all Code requirements, including material, design, fabrication, examination (by the Manufacturer or Assembler), and for vessels and vessel parts, inspection (by the Authorized Inspector), will be met.
4. Background
TSASK issues CRNs in the name of a particular manufacturer. The manufacturer then becomes the manufacturer of record for the CRN and takes full responsibility for the design and ensures that every vessel or boiler is strictly constructed in accordance with the registered design. The registered design drawing with revision level shall be specified on the Manufacturer’s Data Report in the space provided beside the CRN.
When designers or engineering firms apply for a CRN, the manufacturer’s name and a copy of their quality control program Certificate of Registration is provided. When more than one manufacturer is specified, separate CRNs shall be issued to each manufacturer.
5. Manufacturer of Record Change
Manufacturers may maintain effective operational control of CRNs, design drawings and design calculations under a different name and/or different ownership structure.
When the manufacturer of record changes, the CRNs, design drawings and design calculations may transfer to the new manufacturer provided the following requirements are met.
5.1. Proof of Ownership
A letter shall be submitted to Codes & Standards Compliance explaining the manufacturer of record change. In the letter, the manufacturer shall clearly take responsibility for the design, design drawings and design calculations.
5.2. Quality Control (QC) Program
The new manufacturer’s QC Program shall acknowledge the original source of the design, design drawings and design calculations. The new manufacturer shall ensure that their registered QC Program is suitable for the intended manufacturing activities of the registered design(s).
5.3. Name change on Documents
The design drawings and design calculations shall be revised to reflect the name of the new manufacturer. Where the design is proven by proof tests (e.g. cast sectional boilers or any pressure part), the proof test records shall not be modified. Please refer to applicable code section (e.g. UG-101(a)4 for pressure vessels or parts thereof).
5.4. Submission of Revised Documents
The new manufacturer shall submit copies of all revised design drawings and designs calculations to Codes & Standards Compliance for the purpose of a CRN file update. TSASK demand service protocols shall apply.
6. Special Case for ASME Section I Boilers
Per Paragraph PG-104.1 (Note 1), an Engineering Contractor organization with or without fabricating facilities may be deemed the manufacturer and so able to apply and obtain a CRN in its name.
7. Special Cases for Fittings
Clause 4.2.5 of CSA B51-14 allows organizations other than the manufacturer to take responsibility for designs and obtain design registration. The manufacturer(s) shall be identified at the time of design registration and proof of their Quality Control Program(s) provided. Addition or removal of manufacturer(s) from the CRN file shall be treated as in 5.4.
8. Additional Information & Questions
If possible, applicants should contact their Design Reviewer directly with questions. Be sure to include the TSASK reference number or provide enough detail that the Design Reviewer will know which CRN registration is being referenced.
For all other design inquiries, please contact TSASK Codes & Standards Compliance:
- By email at CodesandStandards@tsask.ca;
- By phone at (866) 530-8599. Please ask to speak to either a TSASK Design Reviewer or the Manager, Codes & Standards Compliance; or
- Visit the TSASK website at www.tsask.ca for more information.
9. Effective Date of Policy Paper
The requirements of Policy Paper TSASK-2016-11-01 Changing the Manufacturer of Record on a Canadian Registration Number supersedes all previous TSASK documents on this topic. Policy Paper TSASK-2016-11-01 Changing the Manufacturer of Record on a Canadian Registration Number shall be effective 2016 November 9th.