The design certificate has expired, and I don’t plan to renew it. What should I do with the drawings?
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Hello everyone. I have a question: Our company is manufacturing a batch of containers. Initially, we expected to complete the work before the design certificate of the certifying agency expired (our company has a design department, but no design certificate; the certifying agency’s design certificate expired on December 31, 2010). However, due to various reasons, the work still isn’t finished. Now that the agency’s design certificate has expired, there are problems during the renewal process as well. It seems that getting a new stamp from them is out of the question for now. Has anyone encountered a similar situation before? Do we need to find another agency with design qualifications to redraw the plans? Some colleagues suggested moving up the production date—that is, preparing all documents to comply with relevant regulations before showing them to the inspection personnel. But that’s no longer possible; the dates indicated on the X-ray films can’t be changed. Please share your opinions on how to handle this situation
As long as the design date is before the 31st, that’s fine. It doesn’t matter whether manufacturing is completed before the design certificate expires. As long as it is manufactured by a qualified party.
The design date must be before the expiration date; it’s just a requirement specified in the regulations that designs that have expired cannot be used for container manufacturing. Check clause 3.2.1 of the regulations. Besides, someone from the boiler inspection agency came by yesterday, and when I asked them, they said that expired drawings cannot be used, which means it’s necessary to find another company to carry out the redesign. The Inspection Institute stated: Equipment must be manufactured within the validity period of the design stamp; otherwise, no supervision and inspection certificate will be issued. I’m torn.
From your description, it seems that the initial design drawings are valid, but the production time might be a bit longer. If issues are found in the drawings during the manufacturing process and they need to be updated, by then the validity period of those design drawings will have expired. If this is the case, it’s entirely acceptable to have the original design firm produce and stamp the drawings, provided that the signing date is before the expiration date. The invalidation of the design permission stamp means that the validity period of the design date has expired.
Reply to 5# Wen Bing: That’s right, it means exactly that. It was the prolonged manufacturing period that caused the seal to become invalid. The design date indicated on the blueprint is September 2010; it wasn’t after the seal expired. It’s just that now the seal has expired, yet the product is still less than 50% complete. The inspection agency said that the equipment must leave the factory before the design approval seal expires, which means that once the seal expires, the drawings become invalid and no inspection certificates will be issued anymore.
This is not how we stipulate it; as long as the design drawings are valid, manufacturing can be delayed. I think I’ll send a message to the General Administration of Quality Supervision to ask.
As long as the drawings are issued within their valid period, they can be used for manufacturing. If there are issues during manufacturing, as long as it’s not a problem with the drawings themselves, modifications can be made in accordance with the regulations. If the problem lies with the drawings themselves, then it is necessary to find another design firm to redo the design
The date of submission for inspection of the drawing processes just needs to fall within the validity period of the design certificate. This is how we do it here. There’s no reason for your boiler inspection agency to be so inflexible about this.
According to the original poster, there is no issue with the design drawings; one can refer to Questions 3-6 in the answers to questions provided in the \"Safety Technical Inspection Regulations for Fixed Pressure Vessels\"
I have also been involved in manufacturing inspection work. Our general principle for handling such matters is that as long as the entire design process is completed before the expiration of the design qualification, it is considered legal and valid; generally, it’s sufficient to ensure that the dates of the various signatures on the design are within the valid period. If all the design work is completed within its valid period, then the remaining manufacturing process has nothing to do with whether the design approval is still valid, unless there are design changes. So it must be that the local inspection personnel have a misunderstanding. Or is it due to some other factor? It’s unknown then