On the design of pressure vessel regulations in the new licensing rules of TSG07-2019
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Under the new licensing rules of TSG07-2019, the design of pressure vessels is divided into three categories: analytical design, design according to the rules for fixed pressure vessels, and design according to the rules for mobile pressure vessels. The design rules for fixed pressure vessels include the existing categories A1, A2, A3, A4, D1, and D2. However, what should those entities that previously held design licenses in these categories do to apply for renewed licenses? For example, what should entities that previously held A1, A2, or D level design licenses do?
Personal understanding: For design firms whose original license levels were A1, A2, or A3, they can apply for a renewal after the expiration date, and will be assessed in accordance with the new rules； For the original design units of A1 and A2, they can apply for certificate renewal and additional items upon expiration, and be evaluated in accordance with the new rules ； For existing Class D design firms that wish to obtain a design license in accordance with the new rules, they must submit an application for certification to the General Administration.
Under the new rules, those who obtain a separate design approval for fixed pressure vessels must include A1, A2, and A3 all at once; if these items were missing before, how can they be added without including them? The threshold for design licenses has risen.
According to the note in Table C-1 of Permitting Rule C1.3 for those engaged in the design of spherical vessels and ultra-high pressure vessels, the storage vessels in the design documents should be spherical vessels, while the reaction vessels should be ultra-high pressure vessels. Can this sentence be understood as meaning that it is not necessary to provide it if one does not engage in the design of spherical vessels and ultra-high pressure vessels?
Personal understanding: For design firms whose original license levels were A1, A2, or A3, they can apply for a renewal after the expiration date, and will be assessed in accordance with the new rules； For the original design units of A1 and A2, they can apply for certificate renewal and additional items upon expiration, and be evaluated in accordance with the new rules ； For existing Class D design firms that wish to obtain a design license in accordance with the new rules, they must submit an application for certification to the General Administration
In my opinion, for A6 ultra-high pressure vessels, if such vessels are not to be designed, then the design documents provided need not include information related to ultra-high pressure vessels; otherwise, the reaction vessels in the four sets of drawings should be of ultra-high pressure type. For spherical storage tanks, it’s a bit confusing: since the design firm must possess qualifications for A1, A2, and A3, and A3 refers to spherical tanks, then obtaining the design certification already grants the right to design such tanks. Why is this requirement still specified? There is also the issue of the design of A4 non-metallic pressure vessels.
So, the new licensing rules aren’t explained clearly enough.
The design of A4 non-metallic pressure vessels should be certified separately or included.
The scenario of designing for separate certification should be included; only when the manufacturing unit designs containers specifically for its own production can A4 be reviewed and confirmed separately during the manufacturing certification renewal process