Recently we came across a project where questions arose concerning the welders on the job. The Welding Procedure Specification (WPS) was well written and listed the welders who would be making the welds on the piping being installed. But when asked to see the welders "certification records", those records were older than six (6) months. Some welders last certification was over 5 years and only one, the newest hire for this project, had a certification within the past six (6) months. Sadly, the project manager and superintendent both were aware of these deficiencies and their defense... "XXX never used to ask for all this documentation" - hence we thought we could get away with it!  On another sad note, XXX was more upset when they found out they had been paying for certified welders but all but one of the welders doing the actual work were not certified (i.e. the contractor was making some serious margins on their billable rates) than the fact that about 30% of their pipe installation was not going to be compliant with their chosen RAGAGEP (ASME B31.3)

There may come a day when one of our pressure relief valves will need some type of work done on it and when that day comes we need to ensure the contractor/shop doing the work holds an "VR Stamp" from The National Board of Boiler and Pressure Vessel Inspectors.  The "VR" stands for "valve repair" and anyone who makes repairs to pressure relief valves MUST have a current "VR Stamp".

The National Board offers the Certificate of Authorization and VR Stamp for the repair of pressure relief valves. Requirements are described in NB-514, Accreditation of VR Repair Organizations. Organizations seeking a National Board VR Certificate of Authorization must complete NB-550, Application for National Board VR Certificate of Authorization to Repair Pressure Relief Valves, NB-552, Control Sheet, NB-564, Terms and Conditions and:

  1. have a written quality system that complies with the requirements of the current edition of the National Board Inspection Code (NBIC) and includes the expected scope of activities,
  2. have the current edition of all parts of the NBIC. Organizations have the option of using either a printed version or an electronic version, including a subscription from a National Board licensed reseller, to fulfill this requirement; and,
  3. have available a copy of the code of construction appropriate for the intended scope of work.

Prior to issuance of a National Board VR Certificate of Authorization, the organization and its facilities are subject to a review of its quality system. An important part of that review will be the witnessing of the repair of several sample pressure relief valves.  An independent test for operation and capacity of these sample pressure relief valves will be conducted at a National Board-accepted laboratory. The test is to verify the repaired valves meet applicable ASME Code requirements for performance and relieving capacity.

  • The National Board Testing Laboratory is available to perform this testing, along with several other major valve manufacturers which operate National Board-accepted testing laboratories.
  • A National Board representative will witness the valve testing.



There may come a day when one of our pressure vessels will need some type of work done on it and when that day comes we need to ensure the contractor doing the work holds an "R Stamp" from The National Board of Boiler and Pressure Vessel Inspectors.  The "R" stands for "repair" and anyone who makes repairs OR alters a boiler, pressure vessel, and other pressure-retaining item MUST have a current "R Stamp".  

The National Board offers the Certificate of Authorization and R symbol stamp for the repair and/or alteration of boilers, pressure vessels, and other pressure-retaining items. Requirements are described in NB-415, Accreditation of R Repair Organizations.

Organizations seeking a National Board R Certificate of Authorization must complete NB-12, Application for the National Board R Certificate of Authorization and:

The National Board Inspection Code (NBIC) is issued every two years and this year's edition (2017) is now organized into four (4) parts. It is developed to maintain the integrity of pressure-retaining items by providing rules for installation (Part 1), and after the items have been placed into service, by providing rules for inspection (Part 2) and repair and alteration (Part 3), thereby ensuring these items may continue to be used safely. A NEW Part 4 has been added to integrate the requirements for pressure relief devices. And because of this NEW Part 4, the NBIC has provided a really nice "cheat sheet" that shows us the items that are in Parts 1, 2, and 3 and then ALSO referenced in the NEW PART 4.  CLICK HERE for the NBIC Cheat Sheet.  CLICK HERE to buy the 2017 NBIC Edition.

I may have been quick to "pat myself on my back" last week with my post titled "It took two (2) years, but HFO-1234yf is now a NFPA Flammable "4", as this morning I learned from another client dealing with this refrigerant that their manufacturer also updated their SDS and guess what... that manufacturer went from a NFPA Flammable "4" down to a Flammable "2".  So hence my title of this post..Who's on first, What's on second, I Don't Know is on third - with EPA's R-134a refrigerant replacement.  The rollout of this new refrigerant has been nothing short of a complete cluster _______ and it is occurring in an industry (e.g. automobile manufacturing) that is new to OSHA's process safety standard.  So here is where we stand today (there are no guarantees for next week!)...

I have joked about this topic in other posts, as we have been battling the idea that our new refrigerant for vehicle air conditioners is a Category 1 Flammable Gas.  This conversion from R-134a has been a bumpy one to say the least, but in jest I share with you EPA's "use conditions" and for an agency that certainly played along with industry, they sure did have some requirements that sound a lot like a PSM covered process...

HFO–1234yf MVAC systems must adhere to all of the safety requirements of SAE 1 J639 (adopted 2011), including:

  1. requirements for a flammable refrigerant warning label,
  2. high-pressure compressor cutoff switch,
  3. pressure relief devices, and
  4. unique fittings.

For connections with refrigerant containers of 20 lbs or greater, use fittings consistent with SAE J2844 (adopted 2011).

NOTE:  the fittings will be quick-connect fittings, different from those for any other refrigerant

Manufacturers must conduct Failure Mode and Effect Analysis (FMEA) as provided in SAE J1739 (adopted 2009). Manufacturers must keep the FMEA on file for at least three years from the date of creation.

EPA in their own words:

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