Thread Content
Issues related to pressure vessel design 01: Questions regarding the qualification requirements for designers, reviewers, validators, and approvers at various levels, as specified in Annex C of TSG 07-2019, which outlines the conditions for licensing pressure vessel design. Question: I. Article C2.1.1.2: When a manufacturing unit designs the pressure vessels it produces itself, it must have personnel who meet the requirements stipulated in Article C1.2 of this annex. Article 6 of Document No. 【2019】32 issued by the Market Supervision Bureau’s Special Division on Pressure Vessel Regulation: Regarding manufacturing units that are not engaged in pressure vessel design and only design pressure vessel products for their own companies, during the manufacturing review, the appraisal agency shall assess the design capabilities of such units; if they meet the requirements of the new licensing rules, a manufacturing license will be issued to them ; If the capability to design the manufactured product is available, there is no need to indicate it on the manufacturing certificate ; The review of the manufacturing unit’s design capabilities is conducted during the acquisition of manufacturing permits (for renewal or addition of services), and it is not handled separately for additional services. Question: 1: For manufacturing units that design pressure vessels only for their own organization, do the design, verification, review, and approval personnel at all levels need to meet the requirements regarding relevant work experience and performance specified in Annex C1.2.1 for personnel at each level? In many manufacturing plants these days, since the company does not possess a design license, after the design, verification, review, and approval personnel at various levels within the company complete the design documents, these documents are sent to an external entity with the necessary design license to prepare them. In this case, the design, verification, review, and approval personnel at all levels within the company lack the relevant work experience and achievements. This does not meet the qualification requirements for personnel specified in Appendix C. 2: If it is necessary to meet the requirements regarding relevant work experience and performance for designers, reviewers, validators, and approvers at various levels as specified in the qualification criteria in Annex C1.2.1, then how does the certification and evaluation body determine such work experience and performance for these personnel when processing re-certification? Answer 1: Yes, it is necessary. Article C2.1.1.2 of the \"Rules for Licensing Production and Filling Units of Special Equipment\" stipulates that the personnel requirements must meet those specified in Article C1.2, including performance requirements ; 2. The design experience and achievements are confirmed by the appraisal and evaluation agency based on the relevant materials provided by the design unit. Department responding: Special Equipment Safety Supervision Bureau Date: 2019-08-28 02 Explanation regarding the \"Rules for Licensing of Special Equipment Production and Filling Units\" Question: Dear leaders of the General Administration, hello: Our company’s headquarters is located in an office building in Beijing; we do not have any factories. The company holds a license for pressure vessel design, and the personnel responsible for the design work work here; this license is set to expire in 2022. The subsidiary is located in Hebei Province and has manufacturing plants as well as office facilities; it holds a license for manufacturing pressure vessels (excluding design work). The personnel responsible for the manufacturing process work there, and this license is valid until 2021. In 2021, our company planned to combine the design license and manufacturing license in accordance with the \"Rules for Licensing Special Equipment Production and Filling Units\" in order to reapply for production license qualifications. However, there is one issue: all the resources of our headquarters in Beijing, including employee contracts and social security arrangements, are based in Beijing, and we do not want to relocate to Hebei Province due to this consolidation. There are 3 questions: 1. Can our company, in 2021, apply to Hebei Province for production license qualifications (including design and manufacturing) under the name of its headquarters in Beijing, in order to take advantage of the resources available at the subsidiary’s manufacturing facility? 2. Can our company, in 2021, apply to Hebei Province for production license qualifications (including design and manufacturing) under the name of its subsidiary in Hebei, by taking advantage of the resources available at our headquarters in Beijing? 3. Can our company, in the name of its Beijing head office, apply to the **General Administration for production license qualifications (including design and manufacturing) in 2021, in order to take advantage of the resource capabilities of the subsidiary’s manufacturing facilities? Please answer each one separately, thank you. Answer: Section 2.2.4 of TSG 07-2019 specifies the requirements for condition sharing. Department responding: Special Equipment Safety Supervision Bureau Date: 2020-05-25 Question: Re-question: Although it is explained in clause 2.2.4 on condition sharing of TSG 07-2019, different people still have varying interpretations when faced with specific issues, which inevitably leads to confusion. Can the leaders of the General Administration directly answer my 3 questions one by one, yes or no? so that our company can proceed with the license renewal process as soon as possible. Thank you once again. Answer: 1. In accordance with Paragraph 1 of Article 2.2.4.2 of the \"Rules for Licensing Special Equipment Production and Filling Units,\" a company may use its subsidiaries that possess manufacturing capabilities as the manufacturing location, and obtain the licenses in the name of the company. 2. When a subsidiary applies for a license independently, the company’s resource capabilities do not permit sharing. 3. For those applying for permission in Hebei Province, refer to 3.2.2 of TSG 07-2019, or consult the market supervision and administration department of Hebei Province. Department in charge of response: Special Equipment Safety Supervision Bureau