1660238357887 Dirk

Regulations: Avoid Snags on Foreign Projects

Jan. 3, 2017
Equipment selection can raise some under-appreciated problems

[pullquote]I remember being annoyed at the time: our customer’s process engineer belatedly told us we’d need Canadian Registration Numbers (CRNs) for our skids being shipped to Canada. Provinces issue these for pipe, fittings, pumps and other rotating equipment, and especially for tanks and pressure vessels. A CRN is essential because it means the design has been accepted for use in the province.

This revelation occurred late in the game; much of the equipment already had been ordered and the skids were due for shipping in five months. I had two thoughts: Why didn’t he say something sooner, and why didn’t his company arrange for the registration?

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I must admit that my plate was full at the time with all the other screw-ups this project engineer dumped in my lap. After a few moments of panic, I came up with a workable solution that turned out to be mostly successful: stick to major manufacturers that frequently do business internationally. I’d been doing that already, largely from habit. I say mostly successful because my solution wasn’t perfect: at the last minute we had to substitute items from vendors that already had CRNs — and pay them a fee. Of course, this extra cost wasn’t included in our bid package.

Typically, import certificates take 6–8 weeks in Canada: Provincial Contacts and Requirements.

That’s just Canada. Other countries have their own specific certificates and standards. If you’re an engineering-procurement-construction (EPC) firm building a plant in, say Saudi Arabia, you hire someone on the ground there — often called a customs broker — to take care of things like: meeting pressure test requirements, managing local construction companies, securing building permits, handling shipping to the site, and even arranging visas for commissioning personnel. That’s what International Steel Services, Inc. (ISSI) did when I worked for them.

The picture isn’t complete, though. Surprises can occur. When ISSI built a plant in Montataire, France, we ordered a burner pressure control valve that didn’t meet European Union standards. One of our engineers thought modifying the valve in a shop would do the trick. “Nau,” as no is pronounced in French, declared the French inspector, who red-tagged us. We had to rush in a valve that met France’s environmental regulations. At the time, I wondered why ISSI alone was responsible.

Importing hose and other specialty items into Canada (and many other countries) is particularly troublesome. In the end, we went with a vendor that made hose in Canada. Choosing a vendor that manufactures in the country you’re building in often is worthwhile. However, this option poses its own problems. When I worked at ISSI, we spent a lot of time both in our Pittsburgh office and the one in India unraveling two problems with local vendors: 1) why a fiberglass tank mysteriously exploded; and 2) why carbon/carbon heat exchangers failed hydrostatic testing. In the first case, the Indian vendor didn’t use the correct material and procedure and didn’t apply the necessary exterior coating to the fiberglass. Of course, the Indian government said its manufacturer wasn’t at fault! In the second, the vendor claimed the exchanger was damaged during shipping.

When a foreign project involves imported equipment or goods, the local operating company should make engineers, and perhaps lawyers, available when situations arise. After all, it directly suffers if equipment is stuck, or worse yet, rejected by customs. This is especially true of assembled pipe requiring pressure testing. Of course, it wouldn’t have hurt to have an import/export specialist managing the problem with our skids.

Now, let’s briefly consider imports into the U.S. Equipment arriving, say, from China, must meet the relevant ASME Code and other applicable standards to be used in U.S. plants. (Such compliance also is required when American companies are exporting goods that are specified according to U.S. standards.) Imports from China have been coming under closer scrutiny lately because of mechanical failures of pipe and structural steel. On one job, an “inspected” ball valve failed testing because the ball was missing; yet, the vendor’s inspection tag was tied to the valve.

In the end, cooperation between the operating company and the EPC firm to manage shipments is the best course of action.

DIRK WILLARD is a Chemical Processing contributing editor. He recently won recognition for his Field Notes column from theASBPE. Chemical Processing is proud to have him on board. You can e-mail him at [email protected]
About the Author

Dirk Willard | Contributing Editor

DIRK WILLARD is a Chemical Processing Contributing Editor.

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