Are CRN Numbers Needed?

Is CRN number certification /registration needed?

Opinions and answers depend on perspective, but public safety should always be of paramount significance! Heres Cammar
Corporations view on some answers:

Some applicants answer no!

They incorrectly seem to suggest that the CRN number registration application process is necessarily:
an inconvenient, troubling, confusing, contradictory series of hurdles; and
fraught with problems that are the fault of regulators, or the CRN system itself.Though potentially loud, this perspective is relatively
insignificant since getting a CRN number can indeed be a smooth process, is the responsibility of the applicant, and convenience
should never outweigh public safety! Applicants should consider that, in reality:
A regulators intense attention to an application, is a warning sign! What might be viewed as inconsistency or obstruction by some, is
likely an indication of a regulators reasonable interest. Posting police at everyones door cant be justified since it would be too
expensive, and people are responsible for their own safety and behavior. But police are usually present when needed. Similarly, the
degree of detail that regulators use to look at applications is often dictated by economics and reason.
A CRN number is not a statement of responsibility. Though regulators help to ensure public safety in good faith, they are not
responsible for pressure equipment safety; owners and end users of pressure equipment are. Registration does not represent a hurdle
to overcome, but a minimal bump on the ground to fly over. Quality should exceed regulatory requirements.
Applications that exceed all regulatory requirements are registered, with minimal delay. Though different regulators have slightly
different requirements based on collective experience accumulated in their provinces, if a
design exceeds the most stringent of these, then all requirements are satisfied. That said, duplication of design
reviews that preface CRN number registration should be unnecessary. Obstacles associated with repetition, delays, duplicate fees, etc.
should be minimized. To enhance economic benefits and greater inter-provincial cooperation,
perhaps there is a way to improve the CRN number process while maintaining or enhancing safety. Inter-provincial harmonization
should be seriously considered, and further thoughts and developments relating to harmonization efforts might well be posted under
separate cover! Others seem to answer yes. But their tacit support for third
party (regulator) review seems to be over rated!
One regulator recently published a new optional / alternative concept seemingly with the intention to develop a registration program
based on audit principles instead of proactive third party detailed examinations of each design, to thereby grant CRN numbers to
accredited provincial vessel manufacturers that have an accredited employee! Also, if previously registered in any another province, its
reported that designs are to be registered in some instances with just proper paperwork! And some regulators have indicated that for
some categories of fittings, registration is not even required!
These steps seem to be a response to the volume of received applications for registration, and somewhat regardless of the
percentages that do not pass initial reviews. Some of these deficient design applications likely came from manufacturers already
accredited with certificates of authorization permits!
Published reports show that more than 50% of the 10,000+ applications for registration received in 2014 by one province were deficient
in one manner or another. But its unclear how new programs like the one noted above,
without a proactive third party detailed examination of each design, can properly contribute to the remedy of this statistic.
A proactive third party detailed examination of each design at least adds some independent assurance that minimum regulatory
requirements are met for each specific design, and also requires revisions to deficiencies before operation. Without a thorough third

party examination of each design, registrations would seem to be less meaningful than they used to be.
Other questions that remain to be answered include:
Will consequences of retroactive audits after registration or operation benefit society more than proactive third party detailed
examinations of each design before registration and operation?
Are out of province or foreign manufacturers treated fairly by the new program?
And, are other regulators going to follow suit, by honoring design registrations that were part of an audit program, with reciprocal
registrations?
These developments seem to question whether a CRN number system, based on third party detailed reviews of each design, is still
considered necessary by some regulators or even viable!

Still, other Canadians would clearly answer yes! CRN

numbers are needed! Public safety is paramount and, without third party detailed examinations of each design, legislated factors of
safety would not be independently confirmed before operation, and safety could thereby be reduced.
Pressure equipment can be extremely dangerous, serious stuff. Stored energy calculations show that just one small refrigerator sized
vessel with 230 psig of air pressure has the same stored energy as about 1 lb of dynamite!
A sudden failure of the vessel would result in quite a release of energy! But of course many vessels in use are much larger, with internal
pressures and volumes far in excess of this.
Public safety is very important, and factors of safety should be respected and confirmed. Thanks to accumulated collective experience,
the implementation of pressure equipment codes and standards, and third party oversight of their use, Canada has benefited from few
pressure equipment related fatalities.
Absence of third party reviews in other nations is no reason to discontinue the system here. Current legislation echoes this view.
Provincial legislation stipulates that registration is required even before pressure equipment is constructed!
Practicality intervenes though, and un-pressurized modern art that merely looks like pressure equipment, is just art. Repairs or
alterations to registered pressure equipment must be agreed to by provincial authorities before they
commence. Unless exempt from registration, pressure equipment must currently be registered to legally operate in Canada.
Canadian registration numbers (CRNs) are archived, and link to those responsible for designs: the owners and end users.And the law
has teeth. For example, potential penalties in Alberta under the Pressure Equipment Safety regulation and Safety Codes Act have
somewhat recently been increased to $100,000 CAD and 6 months in prison for the first offence, and $500,000 CAD and 12 months in
prison for a second or consecutive offence.
Additional penalties are available for each additional day that the offence continues! So, this is very serious stuff.
CRN numbers are currently necessary to help ensure safety per the behest of provincial governments and, by extension, in response to
the desire of Canadians. Canadians have democratically empowered their governments to provide protection, and to help ensure
safety.
And Cammar Corporation believes that the public deserves nothing less.
Cammar Corporation will help you get, renew, revise or alter a CRN for your businesss success in Canada. With years of experience in
both the regulatory side as well as in helping industry, we are well positioned to get you the results you need. For more information,
visit: http://cammarcorporation.com/