Design Registration – Registration Process Improvements

28 June 2016

Reference #:  IB-BP- 2016-02

Subject: Improving Design Registration Service for Clients that Follow the Administrative Process

BC Safety Authority (BCSA) continues to make improvements to its registration process to provide:

  • effective oversight for the Province, and
  • efficient processing for applicants.

As an applicant for design registration, you have a duty to ensure your design meets application requirements, complies with appropriate technical codes and standards and is safe for use in BC. 

A recent review of design registration applications has identified numerous instances of the following:

  • No declarations of compliance and safety as required by the application form.
  • Declarations of compliance and safety not being made by qualified persons.
  • Drawings and calculations not signed/stamped by qualified persons.
  • Drawings and calculations signed/stamped by different persons.
  • No calculations.
  • Calculations not matching or no apparent relation to drawings/design.
  • Design work being split between qualified persons and no qualified person taking overall accountability.
  • Application and design work not being represented by a qualified person. 

BCSA suspects that some applicants are relying on BCSA for a portion of their quality management process.

  • BCSA has been told by some applicants that they prefer to send draft material in the event that BCSA discovers mistakes in their design work. The applicants indicate that this enables them to incorporate corrections prior to signing / stamping for their client.
  • BCSA has had to coach some applicants as to the basic components of an engineering design and the appropriate technical standards.
  • BCSA has been told by some applicants that even though their designs are exempt from registration, they prefer to apply so that they can have specific written confirmation other than the posted guidance material on the BCSA website. 

BCSA has not planned for the basic design registration process to be any service other than that of regulatory oversight. BCSA does offer a design registration consultation service for clients that may not be ready to register their designs and take accountability for compliance and safety. 

BCSA will be making changes to its application process to better serve applicants that:

  • complete their work in a manner consistent with good engineering/industry practice, and
  • properly demonstrate compliance and accountability for their work in the application process. 

Effective immediately, the following changes are made to the design registration process: 

Incomplete Applications

  • Applications made with incomplete application forms (i.e. no declaration of compliance) or the use of obsolete application forms will be screened and returned to the applicant. Applicants will need to resubmit when ready and cannot hold a place in queue.
  • Incomplete applications (i.e. missing/incorrect calculations, missing/incomplete/un-notarized statutory declaration) will be screened out of the application process and returned to the applicant. Applicants may be subject to the applicable administrative cancellation fee and cannot hold a place in queue. 

Accountability not Assumed

  • Applications where drawings and calculations are not signed (or stamped) by a qualified person may be screened out of the process or delayed. Applicants may need to resubmit when ready and may be subject to an applicable cancellation fee. BCSA may not adhere to process targets for turn-around times where applicants have not documented accountability for their work.
  • Applications where declarations, drawings and calculations are not signed (or stamped) by the same qualified person may be delayed in some circumstances. BCSA may not adhere to process targets for turn-around times for applications where a risk of quality mistakes between qualified persons is increased. 

Corrections and Additions Following Design Review

  • Clerical or minor changes not being sufficiently addressed in the subsequent revision will be charged a complex or exceptional design registration fee.
    • Clerical and minor changes are those that clarify a designer’s intent but otherwise would have little to no effect on the configuration of the built product or its safe use.
    • Significant changes being required will be charged a complex or exceptional design registration fee.
      • Significant changes are those that result from an error or omission in the design work and without the change, may result with a hazard or non-compliance to the code or standard. 

Exempt from Registration

Repeat Occurrence of Errors / Omissions

  • Applicants that demonstrate a repeated behaviour of the same errors or omissions may have their applications cancelled if the same errors / omissions are discovered on subsequent applications. Applicants may be subject to the applicable administrative cancellation fee and cannot hold a place in queue. 

The biggest factor affecting the timeliness of registrations is the quality of the application and design. In order to promote a timely and efficient registration of your design, please remember to do the following:

  • Use the latest application form.
  • Complete all sections of the application form.
  • Sign/stamp the declaration of compliance and safety by a qualified person.
  • Submit only completed work.
  • Ensure all drawings, calculations and materials necessary to demonstrate compliance are included in your application.
  • Ensure all drawings, calculations and design work are signed/stamped by the same qualified person. 

BCSA trusts that applicants understand that the above changes will help to improve the process for those that are qualified and take accountability for their work and their application.

 

Jeff Coleman, P. Eng.
Provincial Safety Manager, Engineering and Incident Investigations

References: 
Power Engineer, Boiler Pressure Vessel and Refrigeration Safety Regulations Sections:  82, 84 and 85
Application form reference and form number and web site link to the application form