FAQ: Australian Pressure Vessel Registration
Over the years there have been many changes in the way the various State Work Health and Safety Authorities around Australia have determined when and how a pressure vessel must be registered. As a result, there is often confusion. Over the past 12 months a great deal has been accomplished in harmonising the various States. The following frequently asked questions may assist in helping that understanding. The following Frequently Asked Questions are given on good faith and based on the understanding FEC has acquired:
1. Do all States in Australia have the same Rules for Registration of pressure equipment?
All States, with the exception of Western Australia and Victoria, have the same registration requirements. Fortunately the registration requirements for Victoria differ little and indeed for the purposes of registration can be deemed the same as the other States. As such only Western Australia (WA) differs sufficiently to prompt additional considerations. WA will only accept designs that comply with the Pressure equipment design Codes AS1210, ASME BPV Code Section VIII or the British Code BS5500. All other States will accept design codes published by recognised standards organisations.
2. When does a pressure vessel need to be registered?
The governing Australian Standard that dictates this issue is AS4343. Here an attempt is made to quantify the risk associated with the pressure vessel. If AS4343 is applied correctly and results in a hazard rating of A, B, C or D, the pressure vessel must be registered as a design. In addition, if it results in a hazard rating of A, B or C, the vessel must be plant registered before it can be used. All States agree on this principle.
3. What is the difference between registering a design and registering an item of plant?
This is often a point of confusion. Before an item of plant can be registered, the design should be first registered. It is possible to have one design registered and many vessels fabricated using that one design. Once fabricated and before being placed into operation, the item of plant must be plant registered. Design registration requires a designer and a Verifier to sign off on the design as being safe. Plant registration requires a competent person (e.g. an appropriately qualified pressure vessel inspector) to have inspected the vessel and make a declaration that the plant is safe to operate. The competent person must have inspected the plant to certify that the plant has been maintained in accordance with the instructions of the designer, manufacturer and relevant Australian Standards, codes of practice and legislation.
4. What is the difference between a Designer and a Verifier?
A purpose of having both a Designer and a Verifier is to ensure that there has been a deliberate effort to make sure nothing has been overlooked in the design process. In that regard, there is little difference between a Designer and a Verifier; both are experienced pressure vessel designers. The Verifier is the final check over the design and as such there is an expectation that the Verifier is appropriately experienced (see Note 8). Again to ensure that the process is as comprehensive as possible, the Verifier must have had no input into the initial design activity. This ensures the review by the Verifier is carried out without prior assumptions or prejudices. It is possible for the Designer and Verifier to be in the same employ, but the company must have a JAS/ANZ accredited Quality Assurance system that specifically deals with procedures to ensure independence of the Designer and Verifier.
5. Do all pressure vessels need to be designed in accord with AS1210?
While this was once the case, it is no longer required. Aside from Western Australia, strictly speaking the pressure vessel can be designed in accord with good engineering principles. In the case of WA, the design must be carried out either in accord with AS1210, ASME BPV Code Section VIII, Divisions 1 or 2 or the British Standard, BS5500. For all other States, appreciating that both the Designer and Verifier need to agree, the expectation is that a recognised appropriate International Design Code will be used. It is also an expectation that the International Design Code be available in the english language mainly to permit the State Authorities the opportunity to carry out a design audit if they so wish.
6. Is it permissible to mix Design Codes and their Associated Fabrication Code?
While this is untested, the State Acts and Regulations do not mandate how a vessel is designed and hence fabricated. However, if it is declared that a vessel is designed to a particular Code such as AS1210, it must also be fabricated to the associated fabrication Codes which in the case of AS1210 will be AS4458, AS3992 and AS4037.
7. Does a Pressure Vessel that has been designed to ASME BPVC Section VIII require a U-Stamp for use in Australia?
The use of a U-stamp is only an issue at the time of plant registration. It is not an issue at the design registration stage as the U-stamp is a physical stamp that is applied to a vessel at the completion of fabrication. Only the State of Victoria will permit the plant to operate without having a U-stamp. All other States require the full compliance to the design and fabrication Code. The ASME BPVC Section VIII specifically demands the application of the U-stamp and as such in States other than Victoria a U-stamp is required.
8. Does the designer or the Verifier need to be Australian or based in Australia?
No. Neither the Designer nor the Verifier need to be Australians or based in Australia. On the other hand, one needs to appreciate the legal implications of neither the Designer and/or Verifier having a presence in Australia in the event of litigation action. The legislation does impose a duty on the Design Verifier and hence it is preferable that the Verifier be based in Australia. Queensland Workplace Health and Safety has recently (3rd October 2014) imposed the requirement for a Design Verifier to be an RPEQ.
9. Can the applicant be the Designer or the Verifier?
While it is permissible for the Designer to be the applicant for Design Registration, it is not permissible for the Verifier to become the applicant.
10. Does the Applicant need to be Australian or based in Australia?
The Applicant’s office must be in the State to which the design or plant registration is being registered. This is a sensible ruling as it ensures the registration of design and plant are distributed throughout all States.
11. If a design is registered in one State, will it be recognised by all other States?
Yes. Any pressure vessel design registered in any State will be recognised by all other States. There is no exception to this amongst States. However, there is a difficulty due to Western Australia (WA). Although it will recognise the design registration, it will not recognise the plant registration if the design and fabrication is to any other Code than AS1210, ASME BPVC Section VIII or BS5500. There is no simple "work around" to this dilemma and the applicant must simply be aware.
Plant Registration QLD: http://www.deir.qld.gov.au/workplace/training/registrations/plant/index.htm
Plant Design Registration QLD: http://www.deir.qld.gov.au/workplace/licensingregistrations/plantdesign/index.htm
The answers to these frequently asked questions are provided on good faith and to the best knowledge of FE Consultants Pty Ltd at the time of publication. These answers further cover technical issues in a general way and are intended for information purposes only and should not be regarded as technical advice. In all cases, registration requirements are the responsibility of the relevant States or Territory Government body. If in doubt, particular queries should be referred to the relevant governing body. Further advice should be obtained before taking action on any issue dealt with in this publication.
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