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.

 

[KevinNZ]

We have had a requirement in New Zealand for most pressure vessels to be certified (Design Verified, DV) by a 3rd party. The 3rd party has qualifications and experience assessed and recognised by a Government Agency. This would be similar to the ASME code designer qualification requirements but does require the DVer to be a 3rd party.

There are also some offshore companies recognised for DV.

Imported equipment has to have DV. Importers do get caught out when they do not know about the regulations and can not get respective DV. Just U stamp or CE is not enough.

 

[TGS4]

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.

Your description of responsible charge is excessively narrow. You are using just the US NSPE definition. If you were to, however, use the definition from one of the Canadian jurisdictions, say Alberta (APEGA) or British Columbia (EGBC), there is a process for taking responsible charge by performing a thorough review without being intimately involved in the design and development.

Nevertheless, in order to satisfy the App 47 requirements, you will need to hire someone who does meet the requirements of a Certifying Engineer if you do not have someone on staff that meets that definition. There's no way around that.

However, you can have an Engineer (per 47-2(b)) or Designer (Per 47-2(c)) be in responsible charge, provided that you do not engage in the activities listed in Table 47-5-1, unless you are able to demonstrate the additional qualifications in 47-5(b) - as noted by OnG_Engr.

 

[Morcuse]

You could submit request for interpretation, asking that a new record be opened.

We are trying to pass an item record to address this in one jurisdiction, but of course that this affects users on a global basis.

 

[GD2]

IdanPv,

It's quite interesting situation. Do you not have engineering authority in your country that authorizes to perform engineering work?
By the way, who in your company certifies the 'Certificate of Compliance of the Manufacturer's Design Report' and his qualification? By definition, his position is a 'responsible charge'.

It can be a common problem for engineers and designers in your country now. Contact your country engineering authority and ask them how they want to mitigate the new ASME requirement.

GDD
Canada

 

[GD2]

IdanPV,

I looked at MA 47 more closely. Looks like ASME focusses more on the qualification of a 'Certifying Engineer'. To my understanding a certifying engineer is responsible for certifying and signing off the Data Report or the Compliance of the Manufacturer's Data Report.

This said, not everyone on the organization who is involved in the design and analyses is required to qualify to meet ASME's requirement.
It's normal in a multi-discipline office where many engineers and designers are involved in the deigned fabrication of a pressure vessel. It is up to the company to assign the work to individuals based on their qualification and experience.

ASME have laid out qualifications required for designers and engineers but it is common to also see new graduates doing design work.
It's all normal in a real world.

What now ASME has put in place a more focused qualification required for the Certifying Engineers. Options are given how to becomes a certifying engineer.

The Certifying engineer takes the responsibility on behalf of the Manufacturer (in other words the entire design team) of complying with all of the applicable requirements of the Code assuring that work done by others also complies.
Because a single certifying engineer may not be competent to review and approve all design work, ASME gives option for certifying and signing off the Data Reports by more than one certifying engineers.

With your current role, are you certifying the Data Reports?


GDD
Canada

 

[IdanPV]

GD2 -
I do have engineering authority in my country, but it doesn't part of any of the organizations described in 47-2(a)(1)(-b) to (-d).
As I said, becoming a Certifying Engineer in my country will not satisfy the requirements of 47-2(a)(1).

As far as I understand the "Responsible Charge" shall be actively engaged in the engineering process of the pressure vessel which will be stamp with the "U" designator, my qualifications are satisfying each and every requirements in MA 47 besides fatigue assessment.
As for the fatigue assessment requirement, I am preforming those assessment in order to obtain CRN and because of the nature of the pressure vessel I design, my company uses an engineering office in Canada and a Professional Engineer from this office (which is registered in one of the Provinces in Canada) is approving and signing my FEA reports and my fatigue assessments but I am not sure that satisfy the requirement in 47-5(b)(2)(-b).

ASME requirements regarding the qualification of 'Certifying Engineer' are well described in 47-2(a)(1), and for my understanding, there is no waver to those requirements.
An Engineer from country which is not US/Canada and not part of IPEA/APEC/FEANI won't be able to become 'Certifying Engineer' with the current Code requirements

Does the Code required that the MDR will be signed by a "Certifying Engineer" which meet the requirements in 47-2(a)(1)? that might cause a lot of problems to countries which are not part of U.S/Canada or part of the organizations described in 47-2(a)(1)(-b) to (-d).
I didn't find any Code requirement regarding that.

 

[XL83NL]

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.

Thanks Trevor.

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

 

[micXS]

Hello everybody,

it seems to be a common understanding, that in case of fatigue the responsible charge has to be taken by a certifying engineer. However, I don´t think so since you don´t have to fulfill paragraphs 47-5(a) and (b) at the same time.

Therefore it´s possible that a certifying engineer (without responsible charge) will be engaged in fatigue desing activities (47-5(a)), while an engineer (qualified according to 47-2 (b)) is in responsible charge.

Idan: maybe this makes it a little bit easier. You don´t need to contract a certifying engineer from abroad for responsible charge, only to be involved in the fatigue design activity.

Any comments?

 

[IdanPV]

Hello micXS, thank you for your comment.

Even if I need to contract a certifying engineer only for the fatigue design activity, it add an extra costs which put this new appendix discriminatory for some manufacturers.

It seems that the committee has not take everything into account when formulated this Appendix.

 

[JD-JP]

May I come in?

My company is planning a Joint Review soon next year.
I'm impatient because the new version has been applied soon.
And I will talk to AI soon.

Until now, in ASME VIII-2, it was necessary to obtain approval from a Registered Professional Engineer after performing analysis of
Para 5 etc. I believe that ASME VIII-1 MA 47 Certifying Engineer are equivalent to this RPE. What do you think about the issue?

If so, most U2 manufacturers do not have RPE, so I think they will still be outsourced.

Therefore, when performing numerical analysis or fatigue analysis with ASME VIII-1, have an
outsourced certifying engineer approve it as a document created by an ordinary engineer or designer as in the VIII-2.

This is made possible by VIII-1 MA47-2, which means that CE participates in the design activities by MA47-5 (a).
And as shown in MA47-5 (b), engineers and designers appointed by the company
can perform analysis work if the requirements are met.

I believe that we have built a system in which professional engineers authorize the results of
analyzes conducted by general companies.
And I think it is to integrate VIII-1 and VIII-2 in the future.

 

[knstar]

Idan

I think you can keep the fatigue away from ASME design report. so that you can prove the vessel is ok for fatigue and you also need not to follow the app. 47. but you should to talk with the user at first.

 

[IdanPV]

Unfortunately this is not an option,
The nature of the pressure vessel I design require fatigue assessment and the A.I want to see this kind of assessment.

 

[subqa]

And I think it is to integrate VIII-1 and VIII-2 in the future.

This is 100% true. They are slowly trying to bring Div 1 and Div 2 closer together so when they combine the two it will be less painful.

 

[XL83NL]

Source?

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

 

[subqa]

I don't have any official documented source, just what I've been told by code committee members over the past few years. I don't think you'll get any other source on the topic until they just do it in 2023 or 2025 or whenever.

 

[XL83NL]

Fair. Makes sense.

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

 

[IdanPV]

Now, when we more than 3 month after the date that the 2021 Edition became mandatory,
can someone audit experiences from ASME Joint Reviews with the new requirements?

Thanks,

 

[Resegone]

Good Morning, I have a question about the Appendix 47

I' am a certified Engineer from my country Authority, Italy, and I respect all the minimum requirement present in Appendix 47.

Based on above, my actual company proposed me as Designer from ASME Project U-STAMP.

I works in an Oil & Gas Company, and the pressure vessel that i design, works with high explosive fluid as VGO, HCGO, Diesel, ecc and with severe condition.

In case of an accident who will pay? Based on Appendix 47 my name and my signature will compare in calculation and in the cross sectional drawing, if anything happens I'll risk to response about my duty?

If in future i will change the company, what happens if an accident will occur on one vessel that i have projected? Also in this case who will pay?

Does it mean that I need an assicuration all by myself?

I have not yet decided if accept or not

 

[dig1]

Hello Resegone,

I would discuss this with a lawyer in Italy. If the vessels are exported to another Country discuss this with your lawyer as well. I do not want to speculate how Italian law works and give you advice from the United States which may not be applicable.

BR,

Patrick