The Compass

This is a Technical Bulletin published by

Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

Applying the rules of Appendix 47, Section VIII, Division 1 (2021 Edition)
1. All Section VIII, Division 1 Manufacturers shall designate one or more individuals to be in
“responsible charge” of design activities as described in the QC System:
a. A controlled document listing the designated person(s) is required
b. The controlled document shall be referenced within the “Design” controls of the QC System.
c. The designated individual(s) shall be listed by title on the Organizational Chart
d. The Statement of Authority and Responsibility in the QC System may require rewording to
address the designation of persons in responsible charge
2. The person in responsible charge may be a design services contractor per 47-2
a. A letter of appointment of responsible charge shall be issued to the contractor
b. The contractor shall accept their appointment to this responsibility
c. The contractor shall meet the qualifications and documentation requirements for
designation regardless of the duration of their design service activities
3. The person(s) in responsible charge (PRC) shall be qualified to perform their assigned design
activities and those for which they are designated to be in responsible charge
a. Qualifications are dependent upon the “complexity” of the vessel design and the fabrication
operations, and are specified for different levels of activity
b. Qualification requirements per the rules in 47-2:
i. Certifying Engineer:
1. Chartered, Registered, or Licensed Professional Engineer, and
2. 4 of more years of experience in pressure vessel design
ii. Engineer
1. 4-year Engineering Degree from an accredited University, and
2. 4 or more years of experience in pressure vessel design
iii. Designer
1. 2-year Technical or Associates Degree from an accredited University, and
2. 6 or more years of experience in pressure vessel design; or
3. 10 or more years of experience in pressure vessel design in lieu of 1. & 2.
above
c. Qualification requirements per the alternative rules in 47-3
i. No alternative requirements are given for a Certifying Engineer
ii. Engineer shall meet:
1. The same education requirements as 47-2, and
2. The minimum required experience determined by the Manufacturer
iii. Designer shall meet:
1. The same education requirements as 47-2 with the minimum required
experience determined by the Manufacturer, or
2. Only the minimum required experience determined by the Manufacturer

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 The Compass
This is a Technical Bulletin published by
Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

d. Qualification requirements per the rules in 47-4 for design staff who are working under the
supervision of someone in responsible charge but are not qualified at one of the levels
described above,
i. Knowledge of the design requirements of this Division
ii. Knowledge of the Manufacturer’s QC System
iii. Training commensurate with their assigned activities
iv. Have a documented record containing objective evidence of meeting the
qualifications for the experience, training, and knowledge obtained
v. Documented permission to perform design activities under these provisions
e. Qualification requirements per 47-5 for advanced design activities of Table 47-5-1
i. No additional requirements for a Certifying Engineer
ii. Engineers or Designers shall have
1. 2 or more years of experience in the specified design activity
2. Suitable training in the use of software (as applicable)
3. Supervision of their work by the person in responsible charge (Fatigue)
f. Persons designated as being in responsible charge shall also meet the body of knowledge
requirements per 47-6(b):
i. Basic capabilities
ii. Technical capabilities
iii. Professional practices
4. Description of qualification requirements and documentation in the “Design” controls section of the
QC System shall include:
a. Qualification requirements deemed necessary by the Manufacturer, following the rules of:
i. Either 47-2 or 47-3 for Certifying Engineer, Engineer, or Designer
ii. 47-4 for other design staff working under supervision
iii. 47-5 for additional qualifications when applicable
b. Documentation of the qualifications for the individual(s) employed in design activities as
described in 47-6(a):
i. Minimum qualifications for the design of their products
ii. Ensuring the qualification requirements are met
iii. Set requirements for frequency of activity to remain proficient
c. Documentation of the body of knowledge requirements in 47-6(b) for individuals designated
as being in responsible charge when qualified under the alternative rules of 47-3:
i. Basic capabilities
ii. Technical capabilities
iii. Professional practices

The rules of Appendix 47 give the Manufacturer a lot of freedom in developing design competency
requirements that are custom tailored to meet the needs of their intended scope of manufacturing
activities.
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 The Compass
This is a Technical Bulletin published by
Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

These rules are intended to accommodate the broad diversity of vessel manufacturing scopes in this
industry, because there is no “one size fits all” solution for meeting these requirements. A simple
pressure vessel Manufacturer may only require a Designer designated as being in responsible charge for
the limited scope of production they perform. He could be supervising any number of lesser-qualified
individuals performing basic design activities. Another simple pressure vessel Manufacturer may not
have any design staff members and may subcontract all of his design activities to a design services
contractor designated as being in “responsible charge” by appointment. Manufacturers having a
broader scope of construction complexity and designs may need a Certifying Engineer.

Some of the main questions that raised about compliance with the design competency rules in
Mandatory Appendix 47 are as follows:

1. What is the basic requirement for Manufacturers to meet to comply with the rules of Appendix
47 for design competency?

In 47-1(a): “A designer, engineer, or Certifying Engineer designated by the Manufacturer shall be

in responsible charge of the design of a pressure vessel that is certified by that Manufacturer.”

The person(s) in “responsible charge” shall be “designated” by the Manufacturer. The

designated persons shall be given sufficient authority and responsibility to perform design
activities in the “Design” section of the QC System, usually by their title, such as “Designer”,
“Engineer”, or “Certifying Engineer” as appropriate. The phrase “responsible charge” means he
individual(s) are personally accountable to ensure the design of a pressure vessel certified by
the Manufacturer meets the code, follows sound engineering design principles for those aspects
not directly addressed by the code, and will operate safely in the intended service.

NSPE Statement No. 10-1778 states: "The professional engineer in Responsible Charge is
actively engaged in the engineering process, from conception to completion. Engineering
decisions must be personally made by the professional engineer or by others over which the
professional engineer provides supervisory direction and control authority. Reviewing drawings
or documents after preparation without involvement in the design and development process
does not satisfy the definition of Responsible Charge."

2. How should the Manufacturer “designate” individual(s) for being in “responsible charge”?

In paragraph 47-2: “The Manufacturer shall maintain a controlled document, referenced in the
Quality Control System, identifying the persons that may exercise control of design work
performed by others.”

An example sentence for how this could be addressed in the “Design” section of the QC
System: “Preparation of the design calculations for pressure vessels shall be performed under
the supervision and control of the person(s) listed in a document titled ‘Persons Designated in
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 The Compass
This is a Technical Bulletin published by
Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

Responsible Charge’.” The title “Persons Designated in Responsible Charge” is merely a

suggestion, and not a code requirement.

The title “Person(s) in Responsible Charge of Design Activity” shall also be included in the
Organization Chart of the QC System.

3. What qualification criteria should the Manufacturer apply when designating persons to be in
“responsible charge” of design activities?

In 47-1(b): “The person in responsible charge of design activities shall be experienced as

described in the use of this Division.”

In 47-1(c): “The qualifications and experience required of the person in responsible charge of
design activities will depend on the design complexity of the pressure vessel and the nature of
the individual’s experience.”

The designated person(s) has levels of responsibility assigned that are commensurate with their
qualifications. For example, simple pressure vessel design could assigned to a Designer, a heat
exchanger design to an Engineer, and a fatigue analysis for a pressure vessel in cyclic service to a
Certifying Engineer. A single Manufacturer could have any one or some combination of all three
of these kinds of design staff members designated as being in “responsible charge” for different
activities. In some cases, the designated person(s) may be a contractor.

In 47-2: “One or more persons within the Manufacturer’s organization shall be qualified to
perform design work or exercise control of design work performed by others in accordance with
the requirements of this Appendix for all design activities performed or certified by the
Manufacturer”.

Paragraphs 47-2(a), (b), and (c) provide specific education and experience qualification criteria
for a Certifying Engineer, Engineer, and Designer as described above.

In 47-2(d): ”As an alternative to the requirements in (a), (b), or (c), the Manufacturer may follow
the requirements of ASME Section VIII, Division 2, Part 2.” This may be a good option if the
Manufacturer has Certificates of Authorization to certify pressure vessels under both Division 1
and Division 2.

In 47-3(a): “In lieu of the requirements of 47-2(b) or 47-2(c), the Manufacturer may implement
the following alternative qualifications for the engineer or designer in responsible charge for
design activities”.

The Manufacturer has the option of applying alternative experience criteria they feel is
appropriate for an Engineer or Designer designated as being in responsible as set forth in 47-3.

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 The Compass
This is a Technical Bulletin published by
Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

However, the Certifying Engineer shall meet the requirements of either 47-2(a) or (d). There are
no alternative qualifications for a Certifying Engineer.

Notice the second sentence of 47-2: “The qualification requirements shall also apply to
designers, engineers, and Certifying Engineers who are engaged by the Manufacturer by
contract or agreement for their services in the design of pressure vessels.” As mentioned above,
this clearly allows the designated person in “responsible charge” to be a design services
contractor. It is NOT mandatory for the person in “responsible charge” to be an employee of the
Manufacturer.

In addition to listing a design services contractor as “designated” in the manner described

above, a letter of appointment shall be issued by the Manufacturer designating the design
services contractor in writing as being in “responsible charge” of design activities to whatever
level or extent the Manufacturer requires. This appointment is similar to appointing an NDE
contractor as a Level III examiner acting on behalf of the Manufacturer for NDE activities. The
same person issuing the Statement of Authority and Responsibility in the QC System issues an
appointment letter with their signature and date. The design services contractor shall counter
sign and date the appointment letter acknowledging and accepting this appointment.

Keep in mind that a design services contractor in “responsible charge” could possibly be the only
person in responsible charge in some cases. In other cases, the contractor may be
supplementing the existing designated design staff. For example, the Manufacturer’s design
staff does most of their own design work. When a special project requires a fatigue analysis that
is beyond the design staff’s capabilities, it becomes necessary to engage a design services
contractor. The fact that the contractor is only involved for a limited time and scope on a single
project does not exempt them from meeting the Appendix 47 requirements for designation and
qualification.

The Manufacturer may specify different levels of qualification and responsibility. For example,
the Manufacturer may require a Certifying Engineer when applying design by analysis (DBA), or
may subcontract this activity to a design services contractor. Simple pressure vessels designed
by rules and formulas may only require a Designer in responsible charge, but they could be
assigned to an individual under the supervision of a Designer who is in responsible charge.
Whether the person designated with “responsible charge” should be a “Designer”, “Engineer”,
or “Certifying Engineer” is dependent upon the design “complexity” of the pressure vessel(s) to
be certified and the Manufacturer’s fabrication operations. This is a matter of the
Manufacturer’s judgement. Endnotes 72 and 73 clarify the word “complexity”:

Endnote 72: “The complexity of the work includes factors such as design simplicity versus
complexity, the types of materials and welding procedures used, the thickness of materials, the
types of nondestructive examinations applied, and whether heat treatments are applied.”

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 The Compass
This is a Technical Bulletin published by
Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

Endnote 73: “The size and complexity of the organization includes factors such as the number of
employees, the experience level of employees, the number of Code items produced, and
whether the factors defining the complexity of the work cover a wide or narrow range.

There are also rules for “individuals” performing design activities who do not meet the
qualifications for “Designer” or “Engineer” who are working under the supervision of a person
designated as being in “responsible charge”.

In 47-4: “Individuals engaged in design activity while under the responsible charge of an
individual described in 47-2 shall:
(a) be qualified to meet the following minimum requirements by the Manufacturer as
described in its Quality Control System:
(1) have knowledge of the design requirements of this Division for the
application of the Certification Mark with the appropriate designator
(2) have knowledge of the Manufacturer’s or Assembler’s quality System
(3) have training commensurate with the scope, complexity, criticality, or special
nature of the design activities to which oversight is to be provided
(b) maintain a documented record containing objective evidence of meeting the
qualifications for the experience and training obtained
(c) be permitted to engage in any design activity required by this Division or any
supplemental User’s Design Requirements provided on Form UD-R-1 or Form UD-R-
2 (or equivalent document).”

The individuals shall meet these minimum “qualifications” described in the Manufacturer’s QC
System. There must be documentation for the qualifications if these individuals as described by
the QC System. Written “permission” for these individuals to engage in design activities under
such supervision is required. Having a controlled document that designates individuals who have
been qualified at this lower level for design activities under supervision is a good suggestion.

Additional qualifications are required for persons performing specialized design activities
listed in Table 47-5-1. Under the rules of paragraph 47-5(a), a Certifying Engineer either
performing or overseeing these design activities in “responsible charge” is considered fully
qualified and is not required to meet any additional qualification requirements other than those
given in 47-2(a). Designers and Engineers performing or overseeing these activities in
“responsible charge” shall meet the additional qualification requirements of 47-5(b).

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 The Compass
This is a Technical Bulletin published by
Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

In 47-5(b): “Engineers and designers who engage in or are in responsible charge of any of the
design activities listed in Table 47-5-1 shall have evidence [see 47-4(b)] of additional
qualifications as follows:
(1) Numerical Analysis
(-a) 2 years or more of experience performing design analysis
(-b) have received instruction in the use and understanding of any numerical
analysis computer programs from one of the following:
(-1) the developer of the computer program (e.g., the software vendor)
(-2) a training course acceptable to or licensed by the developer
(-3) a Certifying Engineer with requisite knowledge of the computer
program and qualifications to train others on its use
(2) Fatigue Assessments
(-a) 2 years or more of experience performing fatigue assessments
(-b) the individual is working under the responsible charge of a Certifying
Engineer
(3) Other Design Activities: 2 years or more of experience performing seismic reactions,
designing quick-actuating closures, or being engaged in U-2(g) design activities”

4. What are the Manufacturer’s responsibilities for documenting the qualifications of individuals
performing design activities?

In 47-6:
(a) “The Manufacturer who employs the designer, engineer, or Certifying Engineer shall

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 The Compass
This is a Technical Bulletin published by
Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

(1) identify the minimum qualifications required for design of their products
(2) ensure the required qualifications have been met
(3) set requirements for frequency of activity engagement to maintain the required
qualifications
(4) describe the requirements in the Quality Control System
(b) When the Manufacturer is establishing requirements for the person in responsible charge of
design activities under 47-3, it should consider the following body of knowledge elements for
this person:
(1) Basic Capability: mathematics
(2) Technical Capability
(-a) manufacturing
(-b) design
(-c) engineering science
(-d) engineering tools
(-e) quality control and quality assurance
(-f) technical breadth
(-g) technical depth
(3) Professional Practice
(-a) communication
(-b) legal aspects of engineering
(-c) continuing education”

5. Is a Manufacturer required to have an individual qualified as a Certifying Engineer?

Based upon 47-5(b)(2), a fatigue analysis appears to be the only design activity that absolutely
requires a Certifying Engineer to be involved, either performing the analysis or supervising their
performance by others as the individual in “responsible charge”. For all other design activities, a
Certifying Engineer is not required if the qualification requirements for an Engineer or Designer
along with any additional qualification requirements of 47-5 are met (when applicable), and the
individual is designated as being in “responsible charge” under the Manufacturer’s QC System
provisions.

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 The Compass
This is a Technical Bulletin published by
Bureau Veritas Inspection & Insurance

Volume 42, October 25, 2021

Disclaimers:
The contents of this publication represents Bureau Veritas’ opinion and is not intended to be an
official interpretation of the ASME Code. Every effort was made to be accurate. However, we
caution Code users to always refer to the actual Code rules that apply and to use this document
as a supplementary tool to the Code. Formal interpretation can only be made by ASME. It
should be noted that it is always the Certificate Holder’s responsibility to comply with the Code.
Please contact Bureau Veritas’ Technical Services staff if further background information is
desired for this subject.

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resulting from, or in any way connected to the use of the information contained in this
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