Questions in the Draft for Comments on Licensing Rules for Special Equipment Production Units
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This post was last edited by zjq1962 on 2019-2-20 09:34. The draft for comments from special equipment production units does not clearly stipulate the conditions for a manufacturing unit to be qualified for design at the same time. It only clearly stipulates the requirements for the person responsible for the design. There are clear regulations on the qualifications required of pressure vessel design units. The questions are: 1. Are the qualification requirements for design units in the rules only for professional design units or are the same requirements for manufacturing units with design qualifications? Do design personnel in manufacturing units not need to be full-time? 2. In the future, will the design of manufacturing units without design qualifications be subcontracted to professional design units?
The draft does not define the design capabilities of manufacturing units. If the design capabilities of manufacturing units are considered in accordance with the regulations of professional design units, there will be 10 full-time designers. It is estimated that most manufacturing units cannot afford to support so many people and can only outsource to qualified professional design units.
I feel that the manufacturing unit can design its own containers within the scope of the unit's license with the manufacturing license. Otherwise, the items on the manufacturing unit's manufacturing certificate will become particularly complicated. The more integrated they are, the less understandable they will be, and the meaning of reform will be lost.
It makes sense. This situation should be considered, not only to allow enterprises to meet production needs, but also to reduce the burden on enterprises.
According to my understanding, the design units in the rules are for professional design institutes. The problem is that the rules do not specify how to determine the design qualifications of manufacturing units. The key is personnel conditions.
The original intention of the reform is to merge the two certificates into one, so that manufacturing units no longer need to obtain design certificates separately.
If a manufacturing unit can design by itself with a manufacturing certificate, then the manufacturing unit's design certificate may have to be given up. Otherwise, the requirements for personnel requirements are too high. How many manufacturing units can achieve a Class D design certificate that requires more than 10 people? Professional design institutes are not inferior to these people.
The manufacturing unit no longer needs to obtain a separate design certificate. As long as the conditions are met, it can design its own pressure vessels. It is not clear what conditions need to be met, but one thing is for sure. It is impossible to meet the same conditions as a professional design unit.
My understanding is that the manufacturing unit does not accept external design projects and does not need to obtain a design license. If it is manufactured by itself, it can be designed by itself. But if you design for external use, you need to meet the conditions of 10 designers.
My understanding is that the manufacturing unit does not accept external design projects and does not need to obtain a design license. If it is manufactured by itself, it can be designed by itself. But if you design for external use, you need to meet the conditions of 10 designers.
That's the feeling, otherwise what's the point of the reform?