ASME Code calculations to be made ONLY by specifically qualified personnel as from 2022
Michael Frohnert
Authorized Inspector Supervisor / Authorized Nuclear Inspector at CIS GmbH - Consulting Inspection Services
The consequences of the new Appendix 47 of ASME Code Section VIII, Division 1, 2021 Edition for individuals involved in design activities of pressure-containing components.
As you all know, qualification is a matter of course for welders and NDE personnel in the ASME Code. No seam shall be welded by personnel who are not qualified to ASME Code Section IX, and no nondestructive examination shall be performed by personnel not qualified to the required specification. If any work is carried out nevertheless, the weld seam must be removed or the examination repeated.
Design Personnel
So far so good, but what about design calculations? In ASME Code Section VIII, Division 1 - the standard set of rules for pressure vessels - there were previously no criteria for personnel doing this kind of work. Generally, the manufacturer of the pressure vessel had a calculation available and their Authorized Inspector verified that it existed. In the best case, the AI also made a random check to see whether all pressure-retaining parts were included in the calculation. A detailed preliminary verification, as we know it from the Pressure Equipment Directive, was carried out in very few cases only, as this was not required. ASME Code Section VIII, Division 1 lays the responsibility for the correctness of the calculation in the hands of the manufacturer - where they get the calculation from is up to them.
In the 2021 edition of ASME Code Section VIII, Division 1, the new Appendix 47 introduces rules for this previously neglected field. Since this is a "Mandatory Appendix", the rules are obligatory and must be complied with as of the effective date of Edition 2021 on January 1, 2022.
MANDATORY APPENDIX 47 - REQUIREMENTS FOR PRESSURE VESSEL DESIGNERS
In a nutshell, its contents can be described as follows:
The term "Responsible Charge" is newly introduced. The necessary qualifications of the individuals who are in "Responsible Charge" and those who perform design activities are described here. The manufacturer must qualify and appoint one or more individuals for "Responsible Charge". In addition, they must specify in their "Quality Control Program" which qualifications their individuals engaged in design activities must have.
Responsible Charge
To define “Responsible Charge”, Section VIII, Division 1 refers to Statement No. 1778 of the National Society of Professional Engineers. There it is explicitly stated that the mere review of the required documents after completion is not sufficient. Rather, "Responsible Charge" means direct control and supervision of engineering from receiving an order to performing a pressure test. The person with "Responsible Charge" is thus responsible for all engineering decisions. Among others this, of course, covers the following aspects: calculation, drawing, bill of materials and therefore also includes e.g. material selection.
The following three individuals are described, of whom at least one must exist to assume "Responsible Charge":
Certifying Engineer: The "Certifying Engineer" must either be a Registered Professional Engineer in a state of the USA or a Canadian province or be registered with one of the three international engineering organizations IPEA, APEC or FEANI. For Europe, this makes the European Federation of National Engineering Associations (FEANI) the most likely option. It is further required that this person has at least 4 years of experience in pressure vessel design.
Engineer: The "Engineer" must have completed a 4-year full-time course of study and also have 4 years of experience in pressure vessel design - this actually makes him a "Certifying Engineer" without "Certifying".
Designer: The "Designer" must have completed a 2-year course of study and at least 6 years of experience in pressure vessel design. Without studying this person needs at least 10 years of experience.
Alternative qualifications for engineers and designers in "Responsible Charge": The manufacturer can deviate from the prescribed years of experience for the "engineer" and "designer" if they describe this in their quality manual. This includes e.g. detailed requirements for basic mathematical knowledge, technical capability and professional practice. Consequently, this means that the manufacturer establishes their own training program.
New Manufacturer′s Duties
One or more "Certifying Engineers", "Engineers" or "Designers" - either employed directly by the manufacturer or subcontracted - are appointed to be in "Responsible Charge". They can supervise individuals who perform design activities or also perform those activities themselves. Caution: If an FE analysis is performed or if fatigue, seismic loads, paragraph U-2(g) or a quick-actuating closure come into play, the individual in "Responsible Charge" must provide evidence of additional qualifications. Please be aware that the Code distinguishes here between quick-actuating and quick-opening closures. Moreover, for fatigue assessment, a "Certifying Engineer" is absolutely essential – just having an "Engineer" or "Designer" is not sufficient.
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Individuals performing design activities under the supervision of the individual in “Responsible Charge” must also be adequately qualified. This means, among other things, they must:
Written evidence of experience and training is mandatory.
Thus, a calculation provided by the user or prepared by a third-party engineering company is ONLY acceptable if the pressure vessel manufacturer can prove to the Authorised Inspector that the above personnel qualification requirements are fulfilled. A certificate obtained after attending a training course such as the CIS GmbH design workshop, from ASME or an ASME Authorized Training Provider, could be a good basis to comply with items 1 and 3. It may already be sufficient, if this is described accordingly in the manufacturer's quality manual.
Inspector′s Duties
Unfortunately, the Authorized Inspector has no discretionary power in this respect, he only checks Code conformity: If there is no written evidence that individual X performing the calculation has knowledge of the design rules of Section VIII, Division1, has received training in this regard and has read and understood the manufacturer's quality manual, he cannot accept your pressure vessels. Even "Nonconformity Report", which is a deviation report with subsequent acceptance, is no way out here. An individual performing design activities without qualification is like a welder without qualification: the seam has to be removed and re-welded by a qualified welder - the calculation has to be rejected and re-done by a qualified individual. In fact, it may often get worse: While a welder can be qualified on his first weld, a design individual cannot be qualified with his first calculation, as a result the Manufacturer′s Data Report cannot be signed.
Previous Calculations
The common low-cost practice of simply using existing calculations for identical vessels built in earlier years, provided the Code formulas have not changed, is also a rather complicated issue. Since vessels must always be manufactured according to the current quality manual (which requires qualified personnel as of January 1st), evidence is needed that the individual who performed the calculation had already met the necessary requirements at that time. In many cases, it will actually be more complicated to provide written evidence of this than to prepare a new calculation.
New Calculations
This also applies to pressure vessel calculations for current orders according to the old 2019 Code edition, if the calculation is made after January 1st. From that date on, the new requirements for design personnel will have to be incorporated into the quality manual and, as previously mentioned, work must always be carried out according to the current edition of this manual.
What needs to be done?
This means for the manufacturer:
For individuals engaged in design activity, e.g. those carrying out calculations:
These rules have essentially been taken over from ASME Code Section VIII, Division 2, and a little simplified. Manufacturers with authorization for this Division have therefore already implemented the requirements and only need to extend them to Division 1. Manufacturers who have so far only built according to Division 1 must act very soon if they have not yet initiated anything - otherwise no new ASME Code stamped pressure vessels can leave the company.
As is so often the case with the ASME Code: It's all very simple provided you know how to act. For more information, see the new edition of the ASME Code, contact your Authorized Inspection Agency, or contact the author directly.
Mechanical Engineer at Nargan Co.
2 年Great article. I have a question. As per this article , an engineer who is not qualified cannot prepare calculations but the requirement of being qualified is having experience in pressure vessel design . How can it be possible?
Manufacturing Engineering Department Manager
2 年Do I Need to Hire Someone New If No One In My Organization Meets the Requirements of 47-2-a for Responsible Charge?
Consultant at A German Based Inspection/Certification Company
2 年Thanks for posting, useful now that we are revising the PSME Code
Consulting Engineer
2 年Appendix 47 is such incredible overreach by the Committee. The legal requirements for such work are already mandated in every single US state engineering law. I believe the same is true in most countries as well. If there are conflicts between the Code and State laws, state law necessarily governs. This has been true since forever. State laws have required adhering to standards of engineering practice since Hector was a pup. Appendi 47 is horribly redundant--like wearing 2 wristwatches. Instead of trying to redesign every engineering office in the country all Appendix need do is mandate that Code design is engineering practice as defined by law and that design documents--drawings, calculations, test reports and engineering work product to be done and sealed under the direct supervision of an engineer registered in the state where the work is performed. The Boiler Code is already the de facto standard of care. Appendix 47 needs the be replaced by a couple of paragraph in the scope of the Code. Appendix 47 is as redundant as wearing two wristwatches.
Mechanical Engineer | Static Equipment Design | M.Tech | UPDA - MME Certified.
3 年Thanks for sharing, Well presented!