API 6A's Problem 1

[Rizkyffq]

Hello all,

I have read API 6A 21st edition, and i found a little problem with this standard.
In Annex F for API 6A 21st edition, validation test procedure for PR1 already removed while in API 6A 20th edition PR1 still exist.
The problem is when we have validation test of PR1 using Annex F that still using 20th edition and after that API raised their 6A to 21st edition and removed PR1 in their Annex F, and then is our validation test that already referred to the 20th edition still valid or not ?

I mean, as i know if the standard already raised the edition so the previous one is obviously cannot to be used again right ?
Despite in 21st edition there is a statement about this issue:

But as statement above, clearly it states only for "PR2" not PR1,so is it meaning that PR1 is not be accepted as valid test anymore ? or is there any alternatives to make our PR1 test that we have done becomes accordance with Annex F 21st Edition ?

Hopefully someone that expertise on API 6A may give me little enlightenment on this issue.
Thanks in advance

 

[jmec87]

Short answer: If you previously validated the equipment to Annex F PR1, then it still meets API 6A 21st Edition (just not Annex F, which is not required anyway).

Long answer:
Annex F was not normative (required) in the 20th Edition and is not normative in the 21st Edition. You do not have to validate to Annex F for the equipment to meet API 6A. You only have to validate to Annex F "if specified by the manufacturer or purchaser" (5.5 and F.1.1.1).

20th Edition Annex F PR1 was not very rigorous - no temperature cycling or endurance cycling was required, and pressure cycle requirements were between 0 and 3, depending on the type of equipment (see API 6A 20th Edition Table F.24). Validation to Annex F PR1 could allow a company to advertise "validated to Annex F" and could confuse purchasers who naively assumed that Annex F referred to the stringent requirements of Annex F PR2.

API 6A 21st Edition has a requirement in 5.5 that "Manufacturers shall document their design validation procedures and the results of design validation." This is the only normative validation requirement in 6A. There are also performance requirements (PR) for equipment to be "designed to perform" the number of cycles in the relevant part of Section 14, but the number of cycles is either 3, 1, or Not Applicable for PR1 equipment. Assuming no errors by the writers, the Annex F PR1 pressure cycle requirements would have matched the PR-specific cycle requirements in the equipment-specific sections of 6A, so meeting Annex PR1 was one way to validate that the design met the PR1 cycle requirements.

Note that "cycle" is not defined in 6A, so it is up to you to define what constitutes a cycle. As well, there is not an explicit requirement to validate through testing that equipment can perform the required number of cycles, but there is a reasonable argument that it is implicitly required and you may receive an audit finding if you haven't done it.

 

[Rizkyffq]

Thanks jmec87 for the response,

Due we are preparing to our design file and confusing on this one, many thanks sir.
But more question sir,
So as your explanation above, that Annex F is not a "must" requirement to validate our design except manufacturer or purchaser specified it, in other means this is optional. And as you said that the only normative talks about validation in 6A is only in section 14, which is about cyclic test and this test up to us to make the procedure but still makes sense accordance with PR1 requirement in section 14. but in

https://mycommittees.api.org/standards/techinterp/epequip/Shared Documents/6a.pdf

Query number 30 of API 20th edition,

Sentence with red underline, that cyclic test is design requirement which not necessarily validation test requirement, i kinda confused with this sentence, it means that cyclic is not a validation test that may validate our design ? so what test then we must use to be our validation test ?

Hopefully you may answer this, many thanks in advance sir

 

[jmec87]

The interpretation matches what I said: the only normative validation requirement in 6A is in 5.5 that "Manufacturers shall document their design validation procedures and the results of design validation." The PR requirements for a number of cycles is a "design requirement" but not a validation test requirement.

Sentence with red underline, that cyclic test is design requirement which not necessarily validation test requirement, i kinda confused with this sentence, it means that cyclic is not a validation test that may validate our design ? so what test then we must use to be our validation test ?

It means that testing is not necessarily required to meet this requirement. You could rely on other evidence (documented field history, simulations, or whatever you can convince an auditor is reasonable) to show that your equipment can perform the required number of cycles. It does not prevent you from testing the specified number of cycles to validate that your design met this requirement. You determine what testing you need to validate your design.

Usually, testing for 3 cycles at MAWP is the easiest and least controversial way to demonstrate that you've fulfilled the performance requirement for PR1.

 

[Rizkyffq]

Many thanks jmec7 to spent your value time to responded my question.

So as your explanation, that when we do 3 cycles for our equipment with MAWP/Rated Working Pressure and Temperature which we determined accordance with our own procedure then it may become validation test ?

BTW back to the issue, we already done a validation test accordance with PR1 Annex F when API 6A still 20th edition, now we are creating design file when API 6A already became 21st edition. Obviously if we now apply for certification, the Auditor now will be using API 6A 21st edition as their reference to auditing us.
When we stated in our design validation that we have done validation test using Annex F refers API 6A 20th edition (also we attached objective evidence of test result) but auditor is using 21st edition, does it make a potential to be finding ?

i mean, 20th edition is not prevail now but still in our design validation we stated 20th edition in it, do we need make other document like gap analysis between 20th and 21st to argue Auditor that our validation test still met with API 6A 21st edition ?

 

[jmec87]

So as your explanation, that when we do 3 cycles for our equipment with MAWP/Rated Working Pressure and Temperature which we determined accordance with our own procedure then it may become validation test ?

Yes.

When we stated in our design validation that we have done validation test using Annex F refers API 6A 20th edition (also we attached objective evidence of test result) but auditor is using 21st edition, does it make a potential to be finding ?

i mean, 20th edition is not prevail now but still in our design validation we stated 20th edition in it, do we need make other document like gap analysis between 20th and 21st to argue Auditor that our validation test still met with API 6A 21st edition ?

If you accurately describe how the testing done to API 6A Annex F 20th Edition meets API 6A 21st Edition, you should not receive a finding.

 

[Rizkyffq]

Many thanks jmec87 for your response, now we have clear information about design validation.
Case Closed