does ASME provide design-only certification of VIII-1 to a company? 1

[YuJie_PV]

hi all,

the salesman of my company checks with me if design-only certification is available under ASME VIIII-1.
many years ago, i accidentally heard that ASME would provide design-only certification to a company?
what is the current status? is design-only certification for ASME VIII-1 available now?

Thanks in advance

 

[TGS4]

No. Only manufacturers are certified. Manufacturers can outsource design work - See Appendix 47. Note that Appendix 47 will be modified in the 2025 Edition. An early-implementation Code Case is available for manufacturers - Code Case 3100.

 

[IdanPV]

@TGS4, can you give some information regarding the modification of Appendix 47?

 

[TGS4]

Attached is the text of Code Case 3100 (it has been Board-approved, so it good-to-use).

For the new Appendix 47, basically re-number paragraphs (a) through (c) in the Code Case with 47-1, 47-2, and 47-3. And the (1) through (5) subparagraphs in the Code Case will be subparagraphs (a) through (e), etc.

 

[IdanPV]

Thank you

 

[YuJie_PV]

@TGS4， IdanPV,​

i am clear, thank you for your reply.

 

[hugo50ml]

On the other hand, can a company that only has sales, design, and quality abilities and no manufacturing capability acquire the ASME VIII-1 U Stamp Certificate?

 

[YuJie_PV]

@hugo50ml, i think it's not available, just my opinion.

 

[TGS4]

@hugo50ml - no. Only manufacturers can be issued stamps.

 

[hugo50ml]

@YuJie_PV
@TGS4

Dear all,

As far as I know, some companies don't have manufacturing ability. The key is QCS and whether the QCS effectively meets all of ASME's requirements.
Even though the manufacturing is performed by others, not the Stamp Holder, if the Holder's QCS perfectly works for the manufacturer, it can be.

"ASME Accreditation/Certification Agreement" includes the sentence below.

"The organization listed on this Application for Accreditation/Certification (the “Applicant”) performs or subcontracts the design, fabrication, production, testing, assembly, construction and/or installation of items, or provides a service to the aforementioned activities, at the address given, and makes this application to The American Society of Mechanical Engineers (ASME) for the appropriate Certificate of Authorization or other conformity assessment certificate, which, if applicable, permits the use of the Single Certification Mark. The Applicant: ....(omitted)"


Clearly, I hope it shouldn't be available.
This is because, on paper, any documents for ASME requirements can be very easily fabricated and cooked up like all the requirements of ASME are perfectly met, but I think it is very close to a fantasy novel that cannot actually work. I think this is only an expedient to exploit the ambiguity of the Code, and it violates the intent of ASME certification.


It's akin to two companies agreeing to share ASME certificates, effectively halving the cost of qualification, review, and acquisition. This could lead to a significant decline in quality and an overall disastrous situation.

 

[hugo50ml]

In this situation, the stamp holder clearly and inevitably lacks any rights or responsibilities to control the resources of the manufacturer, such as personnel or machinery.
Obviously, they will say, "It's possible, we have done that".

The stamp holder does not pay the salaries or incentives of the individuals involved in manufacturing, nor do they have the authority to impose disciplinary actions or to promote or demote staff. The stamp holder does not use and pay the maintenance costs directly for the facilities and machines. Consequently, these individuals are not obligated to follow the stamp holder's instructions.

Additionally, the manufacturer’s priority tasks do not always align with the orders from the stamp holder.

Of course, they'll act like that during the survey at a moment. It is impossible for visitors such as Authorized Inspectors or investigators to judge if the system is working well or not. Absolutely, it will be a disaster if it is allowed.

Therefore, I strongly believe this represents an unrealistic scenario..

Subcontracting can only be allowed in very simple, short, unavoidable, isolated, and occasionally performed tasks such as non-destructive testing (NDE), heat treatment, and forming, among others.
To allow subcontracting on all the products to any applicants who have no production capability should not be allowed.
Not ASME, NB, AIA, and AI only, but all of us also should know that it is not normal to subcontract conforming to ASME. Perfectly controlling another company is not possible. They look at different directions from each other.

These subcontracting activities must be strictly and clearly limited by ASME, NB, AIA, and AI.

It is important to note that the Quality Controller, Authorized Inspector, and anyone involved in the inspection is not perfect. The quality of work performed by all the individuals associated with ASME construction must generally be held to a higher level.

 

[YuJie_PV]

As far as I know, some companies don't have manufacturing ability. The key is QCS and whether the QCS effectively meets all of ASME's requirements.
Even though the manufacturing is performed by others, not the Stamp Holder, if the Holder's QCS perfectly works for the manufacturer, it can be.

@hugo50ml， the company applying for ASME STAMP have to prove its ability on manufacturing. According to my experience, a sample vessel shall be fabricated during joint review by ASME.​

the manufacturer holding the stamp may subcontract some parts, which is allowed by ASME code. please refer to UG-11 in case of VIII-1 vessel. as if the parts are subcontracted to others , all the responsibilities are still the stamp holder's.​

 

[hugo50ml]

@YuJie_PV

Your explanations are correct, but they differ from my perspective.

The relevant argument is UW-26(d), not UG-11. UG-11 addresses "Parts" only.

Let me bluntly explain how others have obtained ASME Certification without any manufacturing capability:

1. Find a cooperative manufacturer who:
- Does not have an ASME certificate
- Has manufacturing capabilities

2. The rest of the process is similar to the ASME accreditation process, but you need to focus on UW-26(d) and the following points:

- Your Quality Control System (QCS) and Manual must include an agreement, duly signed by you and your subcontractor, saying that you have complete and exclusive administrative and technical supervision of all welders.

- Your QCS and Manual must also include an agreement, duly signed by you and your subcontractor, saying that you have the authority to assign and remove welders at your discretion, without the involvement of any other organization, including the subcontractor.

Again, the above can very simply be cooked up by two companies. It must be a fantasy novel.

Of course, you need to consult with an Authorized Inspection Agency (AIA) and Authorized Inspector (AI) initially.

Some people from these agencies may claim that it's impossible. In my opinion, they're just avoiding the issue, as this case is quite rare.

Others might suggest hiding the subcontractor and simply stating that the work is part of your company. Such an action should not be condoned.

However, I have seen companies obtain ASME Certification without manufacturing capabilities by following the above process.

I'm looking for someone from the AIA or AI community who can provide evidence to explain why this approach isn't possible. The closest evidence I've found is Question 3 of Interpretation No. IX-92-81, but we can find its avoidance method easily.

 

[YuJie_PV]

I have seen companies obtain ASME Certification without manufacturing capabilities by following the above process.

@hugo50ml, i think that's fraud. ​

i‘ve examined UW-26(d) you mentioned, which intends that the welder doesn't necessarily be employed by the manufacturer directly. such practice, saving labor cost, isn't rare per my experience. such practice still require the manufacturer's ability on manufacturing. ​

i've an analogy. Apple may subcontract its production of IPHONE to china's Foxconn, but Apple's understanding of manufacturing is indispensable。

 

[hugo50ml]

@hugo50ml, i think that's fraud. ​

i‘ve examined UW-26(d) you mentioned, which intends that the welder doesn't necessarily be employed by the manufacturer directly. such practice, saving labor cost, isn't rare per my experience. such practice still require the manufacturer's ability on manufacturing. ​

i've an analogy. Apple may subcontract its production of IPHONE to china's Foxconn, but Apple's understanding of manufacturing is indispensable。

@YuJie_PV

Good discussion.

Why do you believe that this is fraud? I believe you agree that welders might be employees from other companies, and you mentioned that this is common.

If not the welders and welding, what may we think ASME requires from applicants regarding their manufacturing capabilities?

Is it required to own any specific machines based on the size to be treated? Is a rental factory not allowed?

May we think understanding of manufacturing is necessary? May it do enough?
If it is, may we think your company can do it?

As far as I know, certifications like CE and RoHS for products such as the iPhone are product-based; they focus on the results of product tests and evaluations of harmfulness.

In contrast, ASME emphasizes the reliability of the entire "process, from design to marking". This includes the fabrication process, systems of quality control, and the qualifications of the workers, among other factors.