Regarding the design, manufacturing, supervision, and inspection of skid-mounted equipment, take a look at the official answers and our own thoughts

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According to the provisions of General Administration of Quality Supervision, Inspection and Quarantine Special Letter [2016] No. 46, in Chapter 6 on operation and management of the Guidelines for Safety Technical Inspections of Fixed Pressure Vessels (TSG 21-2016), Article 2 states as follows: 2. Registration for the use of skid-mounted pressure equipment systems or mechanical equipment systems (hereinafter referred to as “equipment systems”). (1) Pressure vessels and pressure pipelines installed in “equipment systems” shall be designed and manufactured by units with the appropriate qualifications, and shall undergo manufacturing supervision and inspection in accordance with the relevant safety technical specifications. (2) For an “equipment system” that includes pressure vessels or pressure pipelines, the manufacturing unit must hold a pressure vessel manufacturing license, a pressure pipeline component manufacturing license, or a pressure pipeline installation license corresponding to the relevant category; the system shall undergo manufacturing supervision inspections (for those pressure pipeline components for which manufacturing supervision inspections are not specified in the safety technical regulations, the requirements for installation supervision inspections may be applied as a reference). (3) The pressure pipelines in the “equipment system” can be treated as auxiliary devices of pressure vessels and registered for use in accordance with the regulations applicable to pressure vessels ； For those that are only pressure pipelines, registration for use shall be carried out in accordance with the regulations for pressure pipelines. (4) The “equipment system” shall be subject to direct application by the user unit for registration of use (except for simple pressure vessels and pressure vessels falling within the scope of 1.4 of these regulations), and there is no need to submit notifications for the installation of pressure vessels or pressure pipelines, nor to conduct installation inspections. Provisions of Document No. 32 [2019] of the State Administration for Market Regulation. Image. Implementation Opinions of the General Office of the State Administration for Market Regulation regarding matters related to administrative licensing for special equipment (Document No. 32 [2019] of the State Administration for Market Regulation), Chapter 1, Article 6: Licensing for pressure vessel design. After June 1, 2019, when pressure vessel manufacturing units submit applications for obtaining (renewal or addition of items to) manufacturing permits, they must specify in the application whether they design pressure vessels. For manufacturing units that are not engaged in the design of pressure vessels and only design pressure vessel products for their own company, during the manufacturing review, the assessment agency shall verify or evaluate the design capabilities of the applying unit; if those capabilities meet the requirements of the new licensing rules, a manufacturing license will be issued ； Those with the capability to design the products they manufacture need not have this noted on their manufacturing certificates ； If the capability to design the manufactured product is not available, the manufacturing certificate shall indicate “design outsourced”” ； For those that do not fully possess the design capabilities for the manufactured products, the manufacturing certificate shall specify the limitations applicable to those products. The review of the manufacturing unit’s design capabilities is conducted during the issuance of manufacturing permits (for renewal or addition of services), and it is not handled separately for additional services. Pressure vessel design organizations that obtain certification after June 1, 2019 (for renewal or addition of services), or manufacturing organizations that need to provide pressure vessel design services to external parties, shall submit a separate application for pressure vessel design approval to the General Administration. A pressure vessel manufacturing unit that applies for a design license separately is equivalent to a design unit; this is unrelated to the items specified in its manufacturing license, and the statement “Design license obtained separately” shall be indicated on the manufacturing certificate it receives. Pressure vessel manufacturing units that possess the capability to design pressure vessels or have obtained a separate design license for such vessels can design pressure vessels of the same manufacturing class as well as industrial pipelines connected to those vessels (with the exception of flammable, explosive, and toxic media). For manufacturing entities that currently hold both a design license and a manufacturing license with different validity periods, if they design only pressure vessels to be manufactured by themselves, they may apply to the original licensing authority to change the validity period of their design license to match that of their manufacturing license. Provisions of Document No. 849 [2019] issued by the Special Equipment Administration under the Market Regulation Bureau: Pictures. 1. Components such as temperature and pressure reduction devices, flow meters (casings), prefabricated pipe sections used in pipelines within the scope of power station boilers, as well as pipe fittings (including elbows, tees, reducers, etc.) must be manufactured either by units engaged in the production of pressure pipeline components or by boiler manufacturing units at an appropriate level that are capable of producing boilers connected to such pipelines ； Pressure pipeline components such as steel pipes, valves, and compensators used in the pipelines within the power plant boiler are manufactured by the manufacturers of such pressure pipeline components. II. Component assemblies such as temperature and pressure reduction devices, flow meters (housings), and prefabricated pipe sections used in the pipes within the power plant boiler area shall undergo manufacturing supervision inspections in accordance with the \"Rules for Supervision and Inspection of Boilers\", and type tests are not required ； Steel pipes, valves, compensators, and other pressure pipeline components used in pipelines within the scope of power plant boilers shall undergo type tests in accordance with the relevant requirements for pressure pipeline components; there is no need to conduct manufacturing supervision and inspection as per the requirements for boiler components ； Fittings used in the pipes within the scope of power station boilers are subject to manufacturing supervision and inspection as boiler components, or to type testing as pressure pipeline elements. Imported pressure pipeline components used in the pipelines within the power plant boiler shall comply with the aforementioned requirements, and manufacturing supervision inspections or type tests shall be carried out. Compilation of questions from the General Administration’s public feedback section – Images Q: We are a company based in Zibo, Shandong, that specializes in the production of vacuum pumps, compressors, and complete sets of systems for these devices. Our compressor units are designed in accordance with the API681 standard; they consist mainly of purchased components such as welded chassis (supports), motors, separators, heat exchangers, and couplings. The compressors themselves have their key parts manufactured internally and the units are assembled there as well. The piping systems, including suction and discharge pipes as well as water supply pipes, are welded by us using flanges, pipe fittings, valves, elbows, tees, etc. Finally, all these components and piping systems are assembled on a skid within the factory to form a complete unit. We know the definition of the equipment itself; it is quite clear in the case of boilers, pressure vessels, etc. A: Please determine whether it belongs to pressure pipelines based on the Catalogue of Special Equipment ； If the said pipeline belongs to the pipelines of the equipment itself, it is not included in the management of pressure pipelines. Skid-mounted pressure-bearing equipment systems that include pressure vessel and pressure pipeline components shall also meet the requirements of \"Special Quality Inspection Letter [2016] No. 46\". Q: 1. Regarding the issue mentioned in Article 8 of the document \"Quality Inspection Special Letter No. 31 (2013)\) concerning the installation of mobile skid-mounted boilers, our factory has now designed a skid-mounted organic heat carrier boiler. The boiler body and its auxiliary equipment (expansion tanks, oil storage tanks, oil injection pumps, etc.) are all integrated into one chassis. When shipped, the components that are too tall for normal transportation must be disassembled at the flange connections for transport; once they arrive at the customer’s site, the relevant pipelines are then connected together, with connections being made solely via flanges. Is supervision and inspection required in this situation? II. The drawing review agency raised the following question for us: After the connection at the flange is completed on-site by the customer, will a hydraulic test still be carried out? Who controls and supervises this hydraulic test? This question poses a problem for us and the reviewing authorities, and it becomes an obstacle to the subsequent drawing design and review processes. We kindly request experts to answer the above questions so that we can proceed with the subsequent work with the reviewing authority. Thank you! A:1. Not required ； 2. A hydraulic test is required. Q: The “Rules for the Use of Special Equipment” stipulate: “2.13 After special equipment is relocated, the user entity shall go through procedures to update the registration details for its use. In the case of overall relocation, the user unit shall conduct its own inspection ； In the case of removal and reinstallation, the user entity shall select a unit that holds the appropriate permits to carry out the installation. In accordance with the requirements of relevant safety technical specifications, if inspection is necessary after disassembly and relocation, an application for inspection should be submitted to a special equipment inspection agency. ” In light of the meaning of paragraph 2.13 of the Rules, the following questions are raised: 1. Does equipment that is to be relocated as a whole require installation by a company with the appropriate qualifications? 2. Is it necessary to inform the local regulatory authorities and go through installation supervision and inspection for equipment that is relocated as a whole during the relocation process? Looking forward to a reply, thank you! A: Overall relocation should not involve the reinstallation of the equipment; there is no need for a license for the installation of special equipment, no requirement to submit a construction notification, and no need for installation supervision inspections. However, in accordance with the relevant provisions of the \"Rules for the Management of the Use of Special Equipment\", procedures for making changes due to relocation must be followed. Q: A boiler manufacturing company wishes to produce skid-mounted boilers, which consist of a boiler system assembled on a chassis or frame. For boilers of the WNS4-1.25-Y(Q) model, whose drawings have already undergone design verification, if these boiler systems are assembled on a single chassis or frame to create mobile skid-mounted boilers, do the boiler drawings need to go through design verification again? A: If there are no changes to the design documents within the previous scope of verification, it is not necessary. Q: On March 5, 2020, we consulted an expert from the Regulatory Affairs Department regarding the qualification requirements mentioned in the previous message. That expert replied to us by phone as follows: 1. Given that your company already has a license for manufacturing pressure vessels, you do not need to obtain additional qualifications when producing the piping systems connected to those pressure vessels as part of compressor units. The items excluded in parentheses within the permission rules have nothing to do with skid-mounted equipment systems; it can be understood that what is stated in the permission rules refers to those that are excluded and are unrelated to skid mounting. Please ask the expert from the Special Unit’s Management Department to confirm the above opinions in this message system. I would like to express my sincere gratitude to the expert leaders from the Regulatory Affairs Department, as well as once again to the expert who provided us with guidance on March 5th this year! A:1. In accordance with \"Special Quality Inspection Letter [2016] No. 46\", for \"equipment systems\" that include pressure vessels or pressure pipelines, the manufacturing unit must possess either a pressure vessel manufacturing license, a pressure pipeline component manufacturing license, or a pressure pipeline installation license – any one of these three is sufficient. 2. The design of skid-mounted pressure-bearing equipment systems shall be carried out in accordance with the provisions set out in the \"Announcement by the State Administration for Market Regulation on Matters Concerning Administrative Licenses for Special Equipment\" (No. 3, 2019) and item 6 of \"Market Regulation for Special Equipment [2019] No. 32\“. Q: Leadership of the General Administration: When skid-mounted system equipment is manufactured and leaves the factory, is it necessary for it to be inspected by the local special equipment supervision and inspection agency? Thank you. A: In accordance with the requirements of item (vi) in “Special Quality Inspection Letter [2016] No. 46”, skid-mounted pressure equipment systems must undergo manufacturing supervision inspection. Q: Inquiry to **General Administration leadership: 1) Are import flow meters currently required to have a manufacturing license for pressure pipeline components? 2) Is manufacturing supervision required for imported skid-mounted equipment systems that contain pressure vessels or pressure pipelines? What qualifications are required for foreign design firms? What qualifications are required for the manufacturing unit? Is process monitoring required? A: 1. Imported flow meters (casings) must meet the requirements set out in the \"Announcement by the General Administration of Quality Supervision, Inspection and Quarantine regarding Licensing for the Manufacturing of Pressure-bearing Special Equipment\" (No. 151, 2012). Flow meters (casings) used on pipelines within the boiler system must comply with the requirements specified in Document No. 849 issued by the Market Regulation and Special Equipment Department. 2. The skid-mounted pressure-bearing equipment system shall comply with the provisions of Special Quality Inspection Letter [2016] No. 46; the pressure vessels and pressure pipeline components installed in the system shall meet the corresponding requirements. 3. Imported pressure vessels, pressure pipeline pipes, and pressure pipeline valves must have the corresponding manufacturing permits. Currently, the manufacturing licensing for pressure pipeline pipes and valves manufactured abroad is in a transitional phase; those pressure pipeline pipes and valves that have undergone type testing in accordance with the \"Announcement by the General Administration of Quality Supervision, Inspection and Quarantine on Matters Related to Manufacturing Licensing for Pressure-bearing Special Equipment\" (No. 151, 2012) can be sold normally. The duration of the transition period will be announced separately by the General Administration. Other imported pressure pipeline components shall undergo type testing in accordance with the requirements of the \"Announcement by the General Administration of Quality Supervision, Inspection and Quarantine on Matters Concerning the Licensing for the Manufacture of Pressure-bearing Special Equipment\" (No. 151, 2012). The Pressure Pipeline official WeChat account will publish information regarding Document No. 151 of 2012 from time to time; feel free to follow it. Q: 1. Our company holds a license for pressure pipeline design, but we do not have pipeline stress analysis software. The pipelines in the skid-mounted compressor unit products that we intend to develop and design require pipeline stress analysis. Therefore, we would like to ask the officials at the Special Equipment Bureau whether our employees can rent pipeline stress analysis software from other companies to carry out this design work ； If it’s not possible to rent it, can the pipeline stress analysis be outsourced separately? A: The design unit for pressure pipelines shall meet the licensing requirements specified in E1 of TSG 07-2019. Q: I am a frontline worker. While carrying out inspections for the safety of special equipment, I discovered that a pressure vessel manufacturing company (which holds a license to manufacture pressure vessels) was producing a skid-mounted pressure-bearing equipment system, but it was unable to provide the design drawings for this system – which should have been prepared by a unit with the appropriate design qualifications (i.e., process design drawings for pressure pipelines). May I ask whether this enterprise is engaged in the production of special equipment without obtaining a design permit, and whether it falls under Article 74 of the Special Equipment Law? A: In accordance with Special Quality Inspection Letter No. [2016] 46, pressure vessels and pressure pipelines installed in “equipment systems” shall be designed and manufactured by units with the appropriate qualifications, and shall undergo manufacturing supervision inspections in line with the relevant safety technical specifications. In accordance with Announcement No. 3 of 2019, pressure vessel manufacturers may design and install pressure vessels of the same manufacturing grade as those they produce, as well as industrial pipelines connected to such pressure vessels (except for those handling flammable, explosive, or toxic materials, and without restrictions on length or diameter). If a design unit fails to obtain a design permit, it may be dealt with in accordance with Article 74 of the Special Equipment Safety Law. Q: Hello, our company is a manufacturer of skid-mounted products, and our qualifications and requirements meet those specified in Special Circular on Quality Inspection [2016] No. 46. Due to insufficient production capacity, we would like to entrust another company to manufacture our products on our behalf. The entrusted company also meets the relevant qualifications and requirements outlined in that circular, and it will label the products with our company’s name; the product documentation will be prepared in our company’s name as well. Our company will carry out full oversight and supervision throughout the manufacturing process. Is this approach feasible? Are there any relevant regulations to regulate and guide such commissioned processing? A: No. Q: The vehicle-mounted calibration jacks and integrated automatic well selection metering devices produced by our company. The main components include: Class D pressure vessels, manifold valves, various types of valves, pipe fittings, seamless steel pipes, as well as various instruments for measuring temperature, pressure, and flow. Key technical parameters: pressure 2.5 Mpa, medium crude oil, pipe diameter (150 mm > DN > 32 mm); each pipeline is less than 3 meters in length, and the entire assembly is placed within a steel structure enclosure that is 7 meters long, 3 meters wide, and 3.2 meters high ； Primary purpose: To enable online single-well metering during oil field transportation and collection. Question 1: Our company has obtained manufacturing licenses for pressure vessels of grades D1 and D2. Can we carry out the pipeline installation for such skid-mounted equipment? Question 2: Apart from the need for supervised inspection of pressure vessels ； Is supervision and inspection required for the pipeline installation process within this skid-mounted unit? A: For skid-mounted pressure equipment systems, please comply with the relevant requirements specified in Quality Inspection Special Letter [2016] No. 46. Q: Dear leaders of the General Administration, hello! Our company is a manufacturer of natural gas compressors; the compressor skid includes pressure vessels as well as the connecting pressure pipelines. In accordance with Special Quality Inspection Letter No. 46 (2016) and Special Quality Inspection Letter No. 32 (2012), our understanding is that the pressure pipelines on the compressor skid are auxiliary equipment for pressure vessels; in line with Letter No. 32 (2012), one must possess either the appropriate qualifications for designing pressure pipelines or those for designing pressure vessels – either of these is sufficient. The compressor skid (including pressure vessels and pressure pipelines on the skid) must be inspected at the place of manufacture. Is the above understanding correct? A:1. The skid-mounted pressure-bearing equipment system shall be implemented in accordance with the requirements of Special Quality Inspection Letter No. 46 ； 2. Generally, inspection is carried out at the place of manufacture. Q: May I ask that for the manifold in a skid-mounted pressure reduction unit, whose pressure, medium, and geometric dimensions (inner diameter, volume) all comply with the provisions of the \"Catalogue of Special Equipment\", and which is welded together from seamless steel pipes, tees, elbows, end caps, etc., is it necessary to obtain a separate pressure vessel manufacturing license to produce such a manifold? A: Please refer to Quality Inspection Special Letter No. 46, II(VI)2.2, for the requirements regarding “equipment systems”. Q: Hello! Our company is a manufacturer of skid-mounted pressure equipment systems, with natural gas as the medium used in these systems. These systems include fixed-pressure vessels as well as component assemblies. We have obtained a license for the design of pressure vessels (fixed-pressure vessels and other high-pressure vessels, category A2, limited to single-layer structures), a license for the manufacture of pressure vessels (fixed-pressure vessels and other high-pressure vessels, category A2, limited to single-layer structures), and a license for the manufacture of pipeline components (component assemblies, limited to class B gas pressure regulators and prefabricated pipe sections). In accordance with Special Quality Inspection Document No. [2012] 32 (Notice on Issues Related to the Safety Supervision of Pressure Equipment), may our company design pipes for the component assembly units in skid-mounted pressure equipment systems? Thank you! A: Please comply with the requirements outlined in Section II, (VI) of Special Quality Inspection Letter [2016] No. 46, and Section III of Special Quality Inspection Letter [2012] No. 32. A component assembly device refers to a device that is formed by combining pressure pipeline components such as pipes, pipe fittings, valves, flanges, compensators, and sealing elements to achieve a certain function; it includes wellhead devices and production trees, throttle and kill manifolds, gas pressure regulation devices, temperature and pressure reduction devices, flame arresters, flow meters (housings), and prefabricated pipe sections manufactured in factories. Component assembly devices belong to pressure pipeline components and are part of the pressure pipeline. The design unit for pressure pipelines in skid-mounted pressure equipment systems must possess the appropriate qualifications for designing such pipelines. Q: Dear leaders of the General Administration, hello. 1. In accordance with the requirements set out in Quality Inspection Special Letter No. 46 (2016), our company holds GC1 and GD1 qualifications for boiler installation, modification, maintenance, as well as pressure pipeline installation. Are we eligible to install skid-mounted equipment systems that include pressure vessels? (The pressure vessels are manufactured and inspected by units with the appropriate qualifications; our company is responsible for the installation of pressure pipelines as well as the assembly of jacking blocks.) ) 2. Can the pressure pipelines installed by our unit in the aforementioned equipment system be treated as auxiliary devices to pressure vessels and thus exempt from further inspection? 3. Document No. 3 «Special Quality Inspection Letter (2016) 46» does not specify whether the supervision and inspection for the installation of pressure pipelines in skid-mounted equipment systems shall be carried out by the quality inspection authorities in the location where the equipment is manufactured, or by those in the location where it is used A:1. For a “equipment system” that includes pressure vessels or pressure pipelines, the manufacturer must hold a pressure vessel manufacturing license, a pressure pipeline component manufacturing license, or a pressure pipeline installation license of the appropriate level – any one of these three is sufficient. 2. The system undergoes manufacturing supervision inspection (for pressure pipeline components for which manufacturing supervision inspection is not specified in the safety technical specifications, the requirements for installation supervision inspection may be referred to). 3. Manufacturing supervision inspections shall be carried out at the place of manufacture, and these inspections must take place during the production process of the skid-mounted pressure equipment system. Q: Does an overseas company need to obtain a manufacturing license in our country to assemble pressure pipelines into skid-mounted modules (excluding pressure vessels)? If so, what is the license? Installation of pressure pipelines or assembly of pressure pipeline components? If the company already holds a pressure vessel manufacturing license in our country, can it also manufacture the aforementioned pipeline modules without additional licenses? A: Please determine whether it refers to a component assembly unit or a skid-mounted pressure-bearing equipment system based on the product standards. To manufacture a component assembly unit, a license for manufacturing pressure pipeline components is required, while skid-mounted pressure-bearing equipment systems must meet the requirements specified in Quality Inspection Special Letter [2016] No. 46. Q: Special Quality Inspection Letter No. 【2016】46 requires that “equipment systems” containing pressure vessels or pressure pipelines undergo manufacturing supervision inspections. 1. A certain “equipment system” currently contains multiple pipelines, but only one or a few of them fall under the category of pressure pipelines as defined in the Catalogue of Special Equipment of the People’s Republic of China; the remaining pipelines are not considered pressure pipelines. Therefore, when conducting manufacturing supervision inspections on the pressure pipelines within this “equipment system”, should inspections be carried out only on those pipelines that meet the definition of pressure pipelines? 2. After the “equipment system” is assembled in a skid format and passes the inspection, is it permissible to disassemble it? Currently, there is one such skid-mounted system, and the containers as well as some of the pipes in this system are too tall; therefore, they need to be disassembled and transported to the site before being reassembled. Is this approach appropriate? A:1. Pipelines that fall outside the scope of the \"Catalogue of Special Equipment\" are not considered special equipment and therefore do not require supervision and inspection ； 2. Generally, transportation should be done as a whole; in cases involving welding or similar processes, on-site installation supervision and inspection should be carried out. Quality Inspection Special Letter [2016] No. 46 requires that “equipment systems” containing pressure vessels or pressure pipelines undergo manufacturing supervision inspections. Q: 1. A certain “equipment system” contains multiple pipelines, but only one or a few of them fall under the category of pressure pipelines as defined in the Catalogue of Special Equipment of the People’s Republic of China; the other pipelines are not considered pressure pipelines. When conducting manufacturing supervision inspections on the pressure pipelines within this “equipment system”, should inspections be carried out only on those pipelines that meet the definition of pressure pipelines? 2. After the “equipment system” is assembled in a skid format and passes the inspection, is it permissible to disassemble it? Currently, there is one such skid-mounted system, and the containers as well as some of the pipes in this system are too tall; therefore, they need to be disassembled and transported to the site before being reassembled. Is this approach appropriate? A:1. Pipelines that fall outside the scope of the \"Catalogue of Special Equipment\" are not considered special equipment and therefore do not require supervision and inspection ； 2. Generally, transportation should be done as a whole; in cases involving welding or similar processes, on-site installation supervision and inspection should be carried out. Q: What qualifications (licenses) should a unit have to carry out 1. the production and manufacturing of skid-mounted modules (including tasks such as the prefabrication of pressure pipelines, the installation of pipeline containers, and valve installation, which do not constitute independent functional equipment)? 2. Can units with qualifications for pressure pipeline installation manufacture such skid-mounted modules in any location? 3. What production licenses are required for foreign manufacturers to produce such skid-mounted modules? A: 1, 2. Please follow the requirements outlined in item (VI) of the document \"Quality Inspection Special Letter [2016] No. 46\" ； 3. Please comply with the requirements set out in General Administration Announcement No. 151 of 2012. Q: In the Implementation Opinions of the Special Equipment Bureau of the General Administration of Quality Supervision, Inspection and Quarantine regarding the \"Safety Technical Inspection Regulations for Fixed Pressure Vessels\" (TSG 21-2016) (Quality Supervision Special Letter [2016] No. 46), the skid-mounted pressure-bearing equipment systems or mechanical equipment systems (hereinafter referred to as \"equipment systems\") mentioned there – are their definitions or terminological explanations provided in any safety technical specifications or standards for special equipment? Are there any restrictions on the number of pressure vessels and the length of pressure pipelines in the equipment system? If the safety technical specifications or standards for special equipment do not define or provide an explanation for this term, please ask experts to help explain what is meant by “equipment system”. A: Pressure pipeline components, movable skids are installed and connected to equipment and structures such as pressure vessels or mechanical machines, thereby forming a system with certain functions, and constituting a skid-mounted pressure-bearing equipment system or a mechanical machinery system. Q: I encountered a problem during the supervision and inspection of pressure vessel manufacturing: in the process of manufacturing a skid-mounted pressure equipment system, the pressure vessel manufacturer designed three pressure vessels with different functions (evaporator, heat exchanger, separator) on a single drawing, and manufactured all three vessels along with the skid-mounted equipment at the same time. When providing the documentation for delivery, only one set of technical documents and one nameplate were supplied. Is this approach reasonable? If it is unreasonable, do the three containers require separate design, manufacturing supervision and inspection, followed by supervision and inspection of the skid-mounted equipment? Thank you, looking forward to a reply! A: Pressure vessels in skid-mounted equipment shall be manufactured and subject to supervision inspections in accordance with the requirements of the Code for Fixed Pressure Vessels. The skid-mounted equipment system can be registered for use by the user entity in accordance with the requirements set forth in the Document on Quality Inspection and Special Issues [2016] No. 46. Induction and Reflection Images: (1) Pressure pipeline components, movable skids are installed and connected to equipment and structures such as pressure vessels or mechanical machines, thereby forming systems with specific functions; these constitute skid-mounted pressure equipment systems or mechanical machine systems. (2) In accordance with Announcement No. 3 of 2019, pressure vessel manufacturing units may design and install pressure vessels of the same manufacturing class as well as industrial pipelines connected to such pressure vessels (except for pipelines transporting flammable, explosive, or toxic media; there are no restrictions regarding length or diameter). (3) For pry block equipment that has already undergone design verification, only the base needs to be integrated; if the design scope remains unchanged, no re-design verification is required. (4) For “equipment systems” containing pressure vessels or pressure pipelines, the manufacturing unit must hold a pressure vessel manufacturing license, a manufacturing license for pressure pipeline components, or a pressure pipeline installation license at the appropriate level; possessing any one of these licenses is sufficient. (5) For pry bar equipment that has already undergone supervised inspection during the manufacturing process, when it is assembled at the site using only flange connections, a pressure test is required, but no further supervised inspection is necessary. If welding or similar processes are involved, on-site installation supervision and inspection should be carried out. (6) The overall relocation shall not involve the reinstallation of the equipment; no license for the installation of special equipment is required, no notification for construction is necessary, and no installation supervision inspection is needed. However, a relocation change procedure must be carried out in accordance with the relevant provisions of the \"Rules for the Use and Management of Special Equipment\". (7) Foreign manufacturers producing skid-mounted modules must comply with the requirements of General Administration Announcement No. 151 of 2012. (8) Our final opinion: Despite the existing regulations issued by the General Administration, we still believe that the production (design, manufacturing, installation) and supervision of pipelines within skid-mounted equipment and boilers should be based on the principle of seeking truth from facts. In other words, there are theoretical similarities in the production of pressure vessels and pressure pipelines, but there are also differences. For skids that do not include complex valves and control systems/long-distance pipelines, it is appropriate to manufacture and regulate the pipelines within them as pressure vessels. However, in situations such as the long-distance installation of inter-stage pipes in multi-stage large reciprocating compressor systems, as well as the main steam pipes, reheat steam pipes, and superheated steam pipes in large boilers, the safe operation of these pipes depends not only on their strength but also on the design scheme, stress analysis, and support arrangements. Moreover, the rationality of the overall design is closely related to the comprehensive experience of designers in civil engineering, HVAC, and installation – a capability that it is difficult for most manufacturers of pressure vessels/units and boilers to possess. Based on my experience working with a few of the leading companies in China, such capabilities are essentially absent, let alone in the many small and medium-sized enterprises.