Issues related to the retention of technical documents during the \"design service life\"
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The major pressure vessel regulations stipulate that: 1. The retention period for design documents shall be no less than the design service life of the pressure vessel. 2. The retention period for the factory delivery documents or completion documents of pressure vessels shall be no less than the design service life of the pressure vessels. For example, consider a pressure vessel whose design date (the date on which the drawings were signed) was October 1, 2008, with a designed service life of 10 years. Due to various reasons such as project delays, manufacturing of this equipment began in 2013, and it was completed and delivered on October 1 of that year. However, because of issues related to investment, etc., the equipment was finally put into use on October 1, 2018. Here comes the question: 1. By the time this equipment is put into use, the drawings prepared by the design firm have reached the end of their useful life – is it possible to destroy those drawings? That is, for the design agency, should the retention period for drawings start from the date of signing? 2. For the manufacturing unit, should the retention date of the drawings be calculated from the date of shipment, or from the date on which the drawing design was finalized? I think for manufacturing units, the expiration date of the data should be taken as the starting point for the retention period, right? 3. For this equipment, in accordance with the requirements for its use and management under relevant regulations, equipment that has reached its designed service life is sent to a special equipment inspection agency qualified to conduct inspections. According to the reply from the General Administration, it should be calculated starting from the date of commissioning. Is it a bit confusing when analyzed in this way?
I wonder how the safety and technical supervision departments in various regions carry this out? Is it calculated from the date of commissioning, or from the date of manufacture of the equipment?
Based on the literal meaning of the design service life, it should refer to the period after the item is put into use, and can be calculated based on the date of registration. The difficulty lies in the fact that the design agency cannot know when the equipment will be put into use. Unless proper tracking is in place, which design firm would do such a thing?
Yes, I think the same. How can the design team know when this equipment will be manufactured and put into use? In other words, the design team would prefer to finish the design today so that it reaches the end of its useful life the very next day!
The design date, the date of manufacture and release, and the date of commissioning generally do not differ much. Otherwise, the validity of the design documents should be checked during manufacturing, and a special equipment inspection agency with the appropriate qualifications should be commissioned to conduct inspections when it is put into use.