Sometimes I come across some items as I do work for clients that are priceless in helping us make our case for safety and this one is a “feather in our [hard] hat”. Apparently some employers in the state of California decided that using pressure vessels built to some code other than ASME Section VIII was a means to “save money” or for some other crazy reason. The state of CA took issue with this practice and issued a memo way back in 2006 explaining how these businesses could get an official exemption from CAL-OSHA to use a “non-coded” pressure vessel. Their request for information to determine if such a vessel could be used safely speaks volumes to “pressure vessel safety” and provides us some excellent insight into what goes into a pressure vessel safety management program…
Here is the list of requested information an employer would have to submit in order for CAL-OSHA to allow the non-coded vessel to be used:
When making a request to use non-code boilers or pressure vessels, the employer shall submit the following documentation as applicable in the English language and units:
1. A list of all existing or proposed design and service conditions, including:
Maximum allowable working pressure and temperature, internal and external loading, corrosion and erosion allowance, heat treatment, special service requirements or service restrictions, etc.
Design, materials, construction, inspection, testing, non-destructive examination and certification shall be based on requirements from the applicable ASME Code Section, as follows:
NOTE: I am only referring to PRESSURE VESSELS in this post, but the letter also applies to BOILERS.
- Power Boilers, Section I
- Materials Specifications, Section II
- Nuclear Power Plant Components, Section all, Division 1 and 2
- Heating Boilers, Section IV
- Non-Destructive Examination, Section V
- Pressure Vessels, Section VIII, Division 1 and 2
- Welding and Brazing Qualifications, Section IX
- Fiberglass-Reinforced Plastic Pressure Vessels, Section X
- Power Piping, ASME B31.1
- Safety Standard for Pressure Vessels for Human Occupancy, ASME PVHO-
- If the design was not based on ASME Code rules, provide a copy of the design rules used and show how they are equivalent.
2. A complete set of design drawings showing construction and weld joint details including internal and external attachments.
3. The original code of construction shall be used to establish the allowable stresses and joint efficiencies when calculating the maximum allowable working pressure of a vessel.
4. A list of all pressure boundary materials or those materials subjects to stress due to pressure and attachments including material thickness. This list shall include
the material specification and should conform to the applicable Code specification. If the material is of a specification other than referenced in the applicable ASME Code section, submit a copy and indicate how it is considered equivalent. The stress values used in all design calculations shall not exceed the maximum allowable stress values permitted for materials in the applicable Code section.
5. Documentation of any original mill identification and location of such identification.
6. Manufacturers material test reports and/or material traceability including reports of any tests required by the applicable Code section.
7. Welding or brazing procedure specifications and welder or brazer performance qualification records.
8. Non-destructive examination procedures and results or examinations.
9. Record or pressure test or proof test.
10. Documentation showing that the quality control or quality assurance program used by the Manufacturer is equivalent to that required by the ASME Code.
11. Identification to the Inspection Agency whose personnel performed inspections and certified the Manufacturer’s Data Report or equivalent certification.
12. Evidence of qualification or certification of the Inspection Agency by a Jurisdictional Authority.
13. Certification by the Inspection Agency that all inspectors making inspections of the vessel meet the qualifications required by the Jurisdictional Authority. The individual names and commission numbers, if any, shall be provided. The system of supervisory control of such inspectors shall be included.
14. Documentation of inspection during fabrication by the Manufacturer and the Inspection Agency.
15. A report of internal and external inspection by a Certified Inspector employed by the Division.
16. A facsimile of the Manufacturers nameplate or stamping.
17. Manufacturer’s Data Report or equivalent document certified by the Manufacturer and the Inspector employed by the Inspection Agency.
18. A copy of any code or standard used for design or construction.
For boilers or pressure vessels that have been in service, additional tests or examinations may be required including a report of ultrasonic examination that lists the thickness of all pressure-containing materials and the location of such measurements.
When the above information is received, it will be reviewed to determine if the boiler or pressure vessel can be accepted as meeting the requirements of the Safety Orders. A Certified Inspector employed by the Division shall inspect the boiler or pressure vessel at the place of installation to verify that the above requirements have been complied with and to verify identification.
Charges will be made for the review and inspections conducted by Division personnel per California Code or Regulations, Title 8, Division l, Chapter 3.2 (CAL/OSHA) Article 5 Section 344.
So when a business thinks they can slide around basic pressure vessel standards that have been in place for over 100 years and used a vessel built to some lesser code – THINK AGAIN! By the time we gather this info, even if we can, and submit it to CAL-OSHA, the cost of a vessel built to ASME code is a much better deal than you can imagine!
CLICK HERE for the entire 2006 letter