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1. Question: Inquiry regarding matters related to the inspection of special equipment. In accordance with relevant standards and regulations such as the \"Safety Technical Inspection Regulations for Fixed Pressure Vessels\", the \"Safety Technical Inspection Regulations for Pressure Pipelines\", the \"Guidelines for Risk-Based Inspection of Pressure Systems\", and the \"Evaluation of Safe Use Management for Pressure Equipment Systems\", risk-based inspection (RBI) of pressure pipelines and pressure vessels has been carried out. The on-site inspection of the installation has been completed, and a inspection approval report has been obtained. Consultations regarding the next inspection work are as follows: 1. RBI was commissioned for the inspection of pressure pipelines and pressure vessels on the first occasion; can RBI be used again for the next inspection? 2. Before the first RBI inspection, an evaluation of the safe operation management of the pressure equipment system was conducted; if RBI inspection is permitted in the future, is it still necessary to carry out a safety management evaluation prior to conducting the RBI risk assessment? 1. It’s possible ； 2. There is no need to conduct a safety management assessment again. Question 2: Converting a tank container into a fixed storage tank. Our unit has a tank container that is classified as a mobile pressure vessel; it is now fixed to the ground and used as a fixed pressure vessel storage tank. No changes have been made to the tank itself, and neither the medium nor the operating parameters have changed. May I ask, 1. Does this count as a renovation? Does it require the design firm to redesign it? 2. If it is a renovation and no changes have been made, is supervision and inspection still required? What items are inspected under supervision? 3. If supervision and inspection are not carried out, is it sufficient to provide only the original factory documents and inspection reports in order to register the pressure vessel? Looking forward to your reply. It can be modified to a fixed-pressure vessel in accordance with Article 7.5 of Amendment No. 2 to the Mobile Regulations. Question 3: Permit for manufacturing aluminum plate-fin heat exchanger cores. A company manufactures aluminum plate-fin heat exchangers, whose core channels are composed of fin plates and sealed at the ends by brazing; the medium flowing within these cores is liquid oxygen. The company plans to purchase the finished core products from subcontractors. Does the core manufacturer need to hold a corresponding license for manufacturing pressure vessels, and is supervision and inspection required for its manufacturing process? Manufacturers of aluminum plate-fin heat exchangers shall obtain the corresponding production licenses in accordance with the requirements of the \"Regulations on Solid and Liquid Pressure Vessels\" and the \"Rules for Licensing Production and Filling Units of Special Equipment\". The supervision and inspection of the manufacturing process shall be carried out in line with the provisions of the \"Regulations on Solid and Liquid Pressure Vessels\"; however, according to C2.1.5 of the \"Rules for Licensing Production and Filling Units of Special Equipment\", the core components with welds are not allowed to be outsourced. Answer to 4 questions regarding the qualification of manufacturing plants for welding spherical tanks. Our company originally had a certification for manufacturing spherical tanks, with a note indicating that it included the manufacturing of shell plates. This certification was renewed in September 2016, and we also obtained certifications for A1 and A2 classes of manufacturing. At that time, since the regulations were revised, shell plates without welds no longer required supervision during production; therefore, the manufacturing license issued to us included categories A1 and A2, with category A3 specifying on-site welding of spherical tanks. We consulted experts on site, who stated that no qualification is needed for manufacturing shell plates. However, the clients overseeing the production of the tanks we manufacture claim that we only have the qualification for on-site welding, and that we lack the qualifications for pressing shell plates at home or welding the end plates to the pipes. They ask us to provide relevant regulatory provisions that clarify that no such qualification is required. I cannot find any explicit clauses stating this; after all, the end plates do need to be welded. Can the qualification for on-site welding be included within the qualification for welding inside the manufacturing plant? I earnestly request the leadership of the General Administration to help clarify this matter. Thank you! According to Document No. 46 [2016] of the Quality Inspection Special Correspondence, the manufacturing of spherical shell plates has been removed from the licensing items for Class A3 pressure vessel manufacturing; the qualification for spherical tank manufacturing is now uniformly described as “on-site assembly and welding of spherical storage tanks”. If your company still has the capability to manufacture shell plates, you can weld them at the manufacturing plant. Answer to 5 questions regarding the requirements for the manufacture of special equipment abroad. In response to questions about these requirements, your authority stated that imported pressure pipeline components must meet the provisions of the \"Announcement by the State Administration for Market Regulation on Matters Related to Administrative Licenses for Special Equipment\" (No. 3, 2019) and the \"Announcement by the General Administration of Quality Supervision, Inspection and Quarantine on Matters Related to Licenses for the Manufacture of Pressure-Supporting Special Equipment\" (No. 151, 2012). In accordance with the provisions of the \"Announcement by the General Administration of Quality Supervision, Inspection and Quarantine on Matters Concerning the Licensing for the Manufacture of Pressure-Specific Equipment\" (No. 151, 2012), only the manufacturers of boilers, pressure vessels, gas cylinders and their safety accessories as well as safety protection devices (including safety valves, rupture discs, and cylinder valves) – as well as those who manufacture safety valves and rupture discs for pressure pipelines – are required to obtain a license for the manufacture of special equipment. Other imported pressure pipeline components are not required; only a type test is needed upon first import. In accordance with the provisions of the “Announcement of the State Administration for Market Regulation on Matters Concerning Administrative Licenses for Special Equipment” (No. 3, 2019), overseas manufacturing of special equipment includes: boilers, pressure vessels, gas cylinders, safety accessories (safety valves, rupture disc devices, emergency shut-off valves, cylinder valves), and pressure pipeline components (pressure pipeline pipes and pressure pipeline valves). Based on the above two documents, can it be concluded that: 1. Boilers, pressure vessels, gas cylinders, and safety accessories (safety valves, rupture disc devices, emergency shut-off valves, gas cylinder valves) must undergo the certification processes required for the manufacture of special equipment in accordance with domestic regulations. Those that require type testing must first obtain a type test report. Foreign manufacturers need to allow evaluation agencies commissioned by the quality inspection authorities to conduct on-site inspections at their production sites; only after the General Administration for Market Regulation issues a license for the manufacture of special equipment can such products be imported. 2. For other pressure pipeline components, a type test is only required upon initial import, and no manufacturing license is needed. 1. Type testing is not a prerequisite for obtaining permission from the manufacturing unit. Boilers, pressure vessels, gas cylinders, and safety accessories imported from abroad (safety valves, rupture disc devices, emergency shut-off valves, gas cylinder valves) must have manufacturing permits, and products that require type testing must undergo such testing ； 2. Our bureau is formulating implementation guidelines for the licensing of the manufacture of imported pressure pipeline pipes and valves; for details, please consult the Special Equipment Licensing Office of the General Administration. Currently, pressure pipeline components that have undergone type testing in accordance with the “Announcement of the General Administration of Quality Supervision, Inspection and Quarantine on Matters Concerning Manufacturing Permits for Pressure-bearing Special Equipment” (No. 151, 2012) can be sold normally. Answer to Question 6 of the image: Issues related to personnel involved in the renewal of permits for pressure pipeline components. I would like to inquire about the regulations regarding personnel in the context of renewing permits for such components. This year we need to carry out this renewal process, and we plan to apply under the name of the head company. Our employees are those of the wholly-owned subsidiary; their salaries and insurance benefits are all provided by the subsidiary. Both the head company and the subsidiary have their own business licenses, but they are operated by the same legal person. I would like to ask whether, in accordance with clause 2.2.4.2 of the Special Equipment Safety Technical Regulations regarding companies and subsidiaries, it is possible to share personnel resources. Do the employees of the subsidiary need to have their insurance, contracts, and employment status transferred to the head company? When the company applies for a license, with the consent of its subsidiary, the subsidiary may be specified as the manufacturing address in the license. The licensing conditions stipulated in Annexes B to L of TSG 07-2019 permit such sharing, but the subsidiary shall not apply for a license separately. Answer to 7 questions: Issues related to the substitution of materials and design changes for pressure pipeline components. 1. TSG 21-2016 2.1.5 On material substitution, it is stipulated that any substitution of materials for pressure components must be approved in writing by the original design entity in advance. Some design firms indicate in their design documents that the machining thinning is not taken into account when specifying the heads [such as EHA 1200×12(11.7)], and at the same time state in the technical requirements that the amount of machining thinning shall be determined by the manufacturing unit, or that the dimensions of the heads to be used in production shall be decided by the manufacturing unit. In my opinion, these technical requirements indicate that the design unit agrees that, provided the thickness after compression molding is greater than the required thickness, there is no need to go through additional procedures for substituting the head material thickness; thus, these technical requirements represent the design unit’s written approval for changing the thickness of the materials used for the head. Please specify whether a material substitution procedure is required for using an alternative thickness of end cap material in the aforementioned situation 2. Written approval from the design unit for material substitutions and design changes; in my opinion, such written approval includes the signatures of the relevant design personnel at the design unit or the seal of the design unit. It is not necessary to be a design seal or a design change seal. Please specify. 1. During the manufacturing process of pressure vessels, if the specifications of the materials used do not conform to the design requirements, procedures for design modification or substitution of materials must be carried out ； 2. Design changes shall be handled in accordance with Article 4.1.7 of the Solid Content Regulations, and the approval documents should generally bear the seal of the design unit. Answer 8 questions regarding the requirements for on-site welding of large containers. According to the new licensing regulations, “Note C-8: Units that engage in the on-site fabrication of extra-large medium and low-pressure non-spherical pressure vessels must not only possess the appropriate manufacturing qualifications but also meet the basic requirements as well as the specific conditions applicable to spherical tanks (A3). Condition A3 is to be verified by the supervising inspection agency. ”How to understand it? Are there additional licensing requirements for the on-site sectional welding of containers? What are the specific permissions and review processes? The licensing requirements for Class A3 are specified in Article C2.2.3 of the \"Rules for Licensing Special Equipment Production and Filling Units\"; for detailed procedures, please consult the provincial market supervision authorities. Units engaged in the on-site fabrication of ultra-large medium and low-pressure aspherical pressure vessels must meet the licensing requirements specified in the basic conditions for Class A3 as well as the specific conditions. Answer 9 questions regarding the prefabrication of pressure pipeline factories: Pressure pipelines are prefabricated by manufacturers, involving processes such as bending, welding, and heat treatment. I understand that this activity falls under pressure pipeline installation, and accordingly requires appropriate qualifications as well as supervision and inspection. Is this correct? Are there any relevant regulations to support this? Factory-prepared pipe sections are simply pipe components that are manufactured by the production unit in a factory, where the pressure pipeline elements are welded and assembled according to the construction drawings before being shipped as complete units; they do not include the pipe prefabrication carried out by the installation unit at the construction site. Factory-prepared pipe sections are a type of component assembly device, and component assembly devices belong to pressure pipeline components. The component assembly device shall obtain a manufacturing license for pressure pipeline components in accordance with the requirements of TSG 07-2019. Currently, component assembly devices do not require manufacturing supervision inspections. Answer Source: Special Equipment Safety Supervision Bureau