CRN REGISTRATION SERVICES

EngRx is one of Canada’s largest registrants of pressure equipment.

EngRx has received thousands of CRN’s over the years and knows every Provincial Pressure Equipment Authority Office across Canada.  We have relationships with many of the CRN review engineers working within these offices. Our pressure equipment submission CRN application packages have gained a solid reputation for completeness and accuracy so as to shorten the processing time for clients to receive a CRN.

Pressure equipment needs to be registered by Canadian Provincial Regulators generally known as Provincial Pressure Equipment Authorities. Physical offices exist for each province and territory that are responsible to manage the documented safe design of pressure equipment that is in operation within its jurisdiction boundary. Provinces enact their Pressure Equipment Authorities through various laws such as “Safety Codes Act” or “Pressure Equipment Regulations” to become law with the jurisdiction.

The Pressure Equipment Authority Offices employ groups of administrative and technical personnel to receive, review, register and archive applications for CRN. These offices also have other related responsibilities such as registration of pressure equipment manufacturing and inspection quality control programs, control of pressure equipment welder and power engineer/operator programs.

As far as provinces, Alberta has the largest infrastructure of pressure equipment in Canada. Alberta Boiler Safety Authority (ABSA) oversees the CRN process in Alberta. ABSA’s mission is as follows:

ABSA, as a regulatory authority in Alberta, works with our stakeholders to ensure that pressure equipment is designed, constructed, installed, operated, maintained and decommissioned in a manner that protects public safety.

Since the CRN (Canadian Registration Number) process is specific to Canada and each province has created a slightly different process to obtain a CRN, there is a lot of confusion and misunderstanding about the path forward to obtain a CRN specific to a province.

Also a common question arises, what equipment requires registration and what equipment does not require registration? It is important to realize that the Pressure Equipment Authority offices themselves operate under an internal quality program and therefore follow procedures that are defined and repeatable.

EngRx CRN submission packages are routed through an internal review process that is designed to ensure a high quality of submission in respect to compliance to code. Execution of a CRN application is greatly hampered if a design package is incomplete or inaccurate. EngRx has both experience and relationships within the provincial Pressure Equipment authority offices to handle some of the most difficult and obscure design registration requests.

We have professional engineering credentials (P. Eng) in many of the Canadian provinces. Some provinces require the application of a local P. Eng stamp in the CRN application package. In other cases, such as a submission of pressure equipment justified by Finite Element Analysis (FEA) according to ASME Section VIII Division 2 rather than traditional calculations, the stamp of a recognized professional engineer is required. EngRx is competent in the use of FEA to justify the design of pressure equipment to ASME Section VIII Division 2.

Provinces generally have an application process that usually requires that the engineering design submission is accompanied with a set of current Provincial Pressure Equipment Authority forms.

• EngRx will complete and review forms along with engineering design work to ensure CRN acceptance is gained in an expedient timeline.
• EngRx will assist the client in determining the right path to follow in gathering and assembling the engineering design submission packages.

The initial review and screening work by EngRx will result in a positive outcome of a reduced CRN application package effort and reduced CRN processing time. For example, the CRN submission package will be different for Custom Pressure Fittings compared to Pressure Fittings made to a recognized Code or Standard as shown in the following example.

 

Common Custom Pressure Fitting CRN Submission Packages includes the following completed documents:

• Letter outlining the specific nature of the design request package including required timeline for registration and scope of the product application
• Pressure Equipment Authority Application Form
• Statutory Declaration
• Engineering Design Package including drawings and calculations or Proof Test Results along with the necessary complete technical information such but not limited to: NDE, materials and product markings.
• Proof of Manufacturing and Inspection under an audited quality control program

 

 

However, if the pressure fittings requiring CRN is designed to a recognized code such as RFWN flanges to ASME B16.5, CSA B51 provides alternative application submission contents to obtain the CRN when compared to the custom fitting requirements. For best understanding, here is a snip of the related CSA B51 code paragraph:

So, the engineering design package requirements become greatly simplified to demonstrating compliance to the dimensional design and materials information to the specific code. In these cases, the CRN submission package calculations or proof testing is not required as the code specifies both the dimensional and pressure/temperature according to the materials specification. In this case the application package would be simplified to the completion and submission of the following:

• Letter outlining the specific nature of the design request package including required timeline for registration and scope of the product application
• Pressure Equipment Authority Application Form
• Statutory Declaration
• Materials that demonstrating the products and related code
• Proof of Manufacturing and Inspection under an audited quality control program

 

As this pressure fitting example clearly shows, the expertise that EngRx has gained in obtaining CRN’s will save the client time and deliver the CRN at reduced processing costs. Although you may have found the CRN application processing time to be excessively long and arduous, it is also true that if the application package is complete and accurate, the CRN file will move along much quicker without questions and delays.

After the CRN package has been reviewed by the Pressure Equipment Authority engineer, one of the last steps in their internal process will be to apply a CRN to the design which in effect provides authorization for the use and operation of the specific pressure equipment in the province or territory. The CRN will have an expiry date which will need to be monitored and possibly renewed by the pressure equipment owner. EngRx offers services specific to the application of a renewal CRN. Although the application package is quite similar to a new CRN, code requirements change and must be considered in the renewal application. If additional provincial jurisdictions are required by the CRN owner, EngRx will submit the CRN application package including the original CRN to the new province(s) who will review and apply a CRN suffix identifying the acceptance of the CRN within their province.

If the design of pressure equipment that has a CRN is changed, a new submission of the CRN is required if the design change includes revised calculations or affects the pressure containing ability of the equipment. Normally, EngRx will submit the changes along with the original CRN for the Pressure Equipment Authority’s full consideration of the scope. The owner of the CRN must therefore remain mindful when revising design drawings to ensure that the revisions would be either allowable under the existing CRN or necessitate the submission of a revised or new CRN. EngRx provides technical services that will result the correct path taken in respect to pressure equipment design changes within a CRN.

Some quick specific points that EngRx will consider in developing and submitting a CRN package:

• Consideration of cases where multiple engineering designs can reside within one CRN
• Use of a catalogue type design allowing more flexibility for optional features
• Pressure piping registration by physical installation location and multiple addresses will result in multiple CRN’s
• Submissions tailored to CRN processing requirements specific to each province
• Application of P. Eng stamp to the appropriate parts of the submission package
• Hot Tapping packages developed to regulations of the Provincial Pressure Equipment Authorities

 

Some Provincial Pressure Equipment Authorities offer expedited services for CRN processing through a expedited services request. So in these cases, services charged at different costs reflect either “regular time” or “expedited time” options. As well, some jurisdiction offices have now implemented electronic web portals that have somewhat streamlined the submission process. EngRx is sure to consider within the client’s needs, the timeline required for the CRN when preparing the submission package. As well, EngRx offers their own expedited services related to engineering work required in preparing CRN design engineering work. EngRx stays informed of CRN lead times and together with the client, plans the appropriate level of CRN services.

When considering the CRN requirements for internationally manufactured pressure equipment (outside of Canada), EngRx will work with the client to ensure the name of the authorized inspection agency that is employed when the Pressure Equipment or pressure vessel is to be manufactured will be acceptable by the Provincial Pressure Equipment Authority. Also, it is critical that acceptance and CRN registration will be obtained before construction begins. It will be at the Manufacturer’s risk if construction is commenced prior to receiving design CRN. The CRN owner will be responsible to correct any design deficiencies that are identified during the subsequent design registration process in this case. Contact EngRx early in the design process to discuss your international pressure equipment projects requiring CRN.

EngRx will assist in design Repairs and Alterations to pressure equipment and ensure that the CRN is successfully received. According to CSA B51, repairs and alterations must not be made to pressure-retaining components of a boiler, pressure vessel, fired-heater pressure coil, or piping without the prior agreement of the Provincial Pressure Equipment Authority in whose jurisdiction the component is installed. There are alternative courses of action that may be available depending on the Repair and Alteration required, so contact EngRx to discuss the best path forward when Repairs and Alterations to pressure equipment arise.