2021 Section VIII, Div. 1 Mandatory Appendix 47

[QDS2]

Good evening.

Per the recent IHS Markit 2021 ASME BPV Code Fact Book there are significant changes coming to the 2021 Ed. of Section VIII, Div. 1 – specifically Mandatory Appendix 47.

“Added new Mandatory Appendix 47 to prescribe minimum competence requirements for performing design activities, as well as qualification and certification requirements for design personnel.”

Additionally, Div. 2 has been revised as well:

“Revised Annex 2-B and 2-J to allow engineers to provide Code services, in addition to Certifying Engineers and Designers. Educational requirements for engineers and Designers, have also been added. These changes aligns the requirements of Appendix 47 of Section VIII, Division 1.”

Questions/concerns:
1. How is “minimum competence” defined?
2. What is the qualification requirement for a designer? (Associate’s, Bachelor’s, etc.)
3. What is the certification requirement for a designer? (accredited training, additional certification beyond qualification, etc.)

I have not been able to find information regarding these additions/changes. Any clarification is appreciated.

Thank you in advance.

 

[TGS4]

Please read the Appendix. After you have done so, please feel free to come back with specific questions. Most of your questions will likely be answered by reading the book.

 

[dig1]

QDS2,
We haven't received the 2021 edition yet so I can't comment intelligently; I'm assuming it may be similar to Div. 2 Annexes 2-B and 2-J. On another note, hopefully Div. 1 Appendix NN will become mandatory in the next couple of edition; it seems that many users/specifiers are becoming less specific in the RFQs.

 

[TGS4]

dig1 - don't make such assumptions. In this case, you would be incorrect - obtain the 2021 Edition and read it for yourself.

And, do you mean Appendix NN "Nonmandatory Appendix NN Guidance to the Responsibilities of the User and Designated Agent", or do you mean Appendix KK "Nonmandatory Appendix KK Guide to Preparing User's Design Requirements"?

 

[dig1]

I preordered in the winter from IHS and it hasn’t shipped yet. I’d love to obtain it so I don’t have to assume.

No I did mean NN; users or their agents often do a poor job in indicating to the fabricator what they want.

 

[TGS4]

As a fabricator, you could always require Appendix KK to be filled out. That might help...

 

[OnG_Engr]

TGS4,

You're right about "read the Code", but I have to sympathize with people's eagerness to find out what's in #47. If the new Div 1 requirements are anything like the 2019 Div 2 ones, the designers & engineers who have the education and experience just got a boost to their street value. Those who don't, not so good. Small shops too cheap/poor to pay for skill are going to have to find something else to do or close their doors. I would expect many employers would not want their skilled people to know what's in the new Code due to the greater bargaining leverage it gives them, but I could be wrong. I've actually brought this up to Sales to see if there's an angle we can work this. Big shops will have the talent, but big shops also have big capital which needs big jobs. I expect the smaller shops will have problems with talent.

Or maybe not.

 

[IdanPV]

Hello All,

I want to add few more questions to the thread,
My company holds a "U" Certificate of Authorization from ASME and we perform design activities in-house, our product require fatigue assessment, and until now I've made those assessments in accordance with ASME VIII-1, App. 46 & ASME VIII-2, Part 5.
The new App.47 of the 2021 Edition requires that fatigue assessments shall be made be an individual which is working under the responsible charge of a Certifying Engineer (per 47-5(2)(-b)).

I am not a Certifying Engineer and I am wonder what will happen now.
1. Shall I become a Certifying Engineer?
2. Shall my company hire a Certifying Engineer just for fatigue assessments?
3. What about previous fatigue assessments I made using the 2019 Edition?
4. 47-2(a)(1) stated that Certifying Engineer shall be "Chartered, Registered, or Licensed in accordance with on or more of the following..."
What if non of the options is relevant for me?

Thanks!

 

[TGS4]

IdanPV - this is a question that you should discuss with your AI.

 

[Morcuse]

47-2(a)(1) does not provide enough room for all jurisdictions. This should definitely be looked into.

Yes, you need to hire a Certifying Engineer for fatigue assessments now.

 

[GD2]

IdanPV,
Different countries call it differently. For example, in US PE, Canada P.Eng are all registered engineers They are the authority to approve and sign a piece of engineering drawing and document. A non-registered engineer/technologist can work under a registered engineer but the register engineer takes the ownership by signing and stamping it. If something goes wrong later, the registered engineer can be sued and loose his practice license.

ASME now has shifted the responsibility/ownership to an professional licensed engineer.

Check your country definition and requirement for a chartered/registered/licensed engineer. If your company don't have one, they either recruit one or engage a third party.

GDD
Canada

 

[XL83NL]

@TGS4: out of interest, what would you consider to become a practical solution for European stamp holders when they need to comply with App 47? I know this is guessing here perhaps (since you might be more familiar with US/Ca), and since the 2021 edition isn't live yet - so time will tell.

In Europe, many of the stamp holders/companies I know have their own (just like any other company) in-house trained & experienced engineers in charge of pressure vessel design. Would such shops need to have their engineers be qualified as either a Certifying Engineer (per 47-2(a)), an Engineer (per 47-2(b)), or as a Designer (per 47-2(c))? What I'm not getting is what App. 47 requires from these 3: can a company choose what they think they require, based on their complexity, per their controlled document referenced in their QCS? For sake of simplicity, let's keep 47-5 out of the question for now.

Huub
- You never get what you expect, you only get what you inspect.

 

[TGS4]

There were a number of European manufacturers participating in the discussions that lead to Appendix 47. I believe that the approach that you described is what most manufacturers are going to follow. Hopefully the European NoBo's will be able to assist the manufacturers.

 

[IdanPV]

TGS4 - Will do, but before that I wanted to get some information.
Moreover, I am not sure if he got the answers.

GD2 -

but the register engineer takes the ownership by signing and stamping it

As per NSPE Position Statement No. 10-1778:

Reviewing drawings or documents after preparation without involvement in the design and development process does not satisfy the definition of Responsible Charge.

App. 47, 47-2(a)(1) gives several options to become "Certifying Engineer"
(-a) Professional Engineer in U.S or Canada - not applicable for me.
(-b) Professional Engineer by an authorized member of IPEA - not applicable for me.
(-c) an authorized member of APEC - not applicable for me.
(-d) an authorized member of FEANI - not applicable for me.
I'm sure I'm not the only one dealing with this kind of situation and I am wonder what other engineers\companies are going to do now.

 

[GD2]

IdanPV,
Let's get it straight.
Appendix 47 is mandatory which means it's now a part of code compliance.
A professional engineer/licensed engineer now must authenticate your reports.
Your company neither have a professional engineer nor you are working under the direct supervision of a professional engineer.
NSPE Position Statement No. 10-1778 definition bar any professional engineer to authenticate your work.
Solution:
1. Go to your state Licensing Board/regulatory site for professional engineers. Professional engineers practice is regulated by a self-regulatory body. In US, it's called Licensing Board. Each state will have its own body.
2. Almost all regulatory bodies has some means of practice to allow relying on the works of others and outsourcing.
Example: a Canadian engineering company in Alberta outsource some engineering work from US but NOT under direct supervision. The state regulator stipulates that the work must be authenticated by an Alberta Professional Engineer.

To overcome this situation, the state regulator gives guidelines on how to rely on work by others through a thorough review process.

This is a common problem in the engineering industry and there is a remedy to it. Engineering products can be sourced from Europe, Japan, South Korea etc. by another country or engineering entity.
3. Going forward, your company will require is use the service of a professional engineer to be in compliance with the Code - whether in-house or by outsourcing.

By the way, which state are you practicing?



GDD
Canada

 

[IdanPV]

GD2 - everything is clear, but what if my country is not part of IPEA/APEC/FEANI and I am not from the US or CANADA?
I can become a professional engineer in my country but it will not help with App.47 requirements as my country is not part of any association described in 47-2(a)

 

[GD2]

IdanPV,
It seems you are spreading your wings all over.
You say you are not from US, then how does NSPE bothers you. It's an US organization.
You say you can become a professional engineer in your country. If you can, then better be it.

By the way, do you design the vessels to be used in your country only? If yes, then you satisfy Appendix 47 as you will be the professional engineer.

If your design is for another country, then it will be responsibility of the engineer of that country who had outsourced it.

GDD
Canada

 

[IdanPV]

GD2 -
NSPE bothers me because this the way ASME define the term "Responsible Charge". And it doesn't mater if the "Responsible Charge" is located in the US or in another country.

I can become a professional engineer in my country but it won't satisfied the requirement of 47-2(a)(1) which stated that a a "Certifying Engineer shall be Chartered, Registered, or Licensed in accordance with on or more of the following..."
So, I am not from the US or Canada and I can't register as a professional engineer there.
My country is not part of the IPEA so it doesn't relevant for me.
My country is not part of the APEC and not part of the FEANI.

Hiring someone who will authenticate my design won't satisfy the requirements of App.47 because each manufacturer shall designate a "Responsible Charge" and Reviewing drawings or documents after preparation without involvement in the design and development process does not satisfy the definition of Responsible Charge.

I know that for Canada the design need to be authenticate by a P.Eng but this has nothing to do with App.47.

 

[OnG_Engr]

IdanPV,

I was out of town last week, so wasn't able to reply earlier.

As I read 47-5, you're going to need to have PE or equivalent in the loop if you're doing Div 2 fatigue analysis. To the best of my knowledge the only thing from Part 5 that doesn't require a Certifying Engineer is screening for fatigue, though 47-5(b)(1) seems to say otherwise for Numerical Analysis. Maybe someone want's to comment on that?

If you're just doing Div 1 and keep to Part 4 when using Ap 46, I don't see the need for a Certifying Engineer. Thoughts, GD2?

Look forward to reading community feedback.

 

[IdanPV]

OnG_Engr - Thank you for your comment.
I am looking forward for feedback as well.
Thanks again