ASME International Update
The following presentation was delivered at the 80th General Meeting Monday afternoon session, May 9rd, by Joseph S. Brzuszkiewicz. It has been edited for content and phrasing. A slide presentation of his address can be accessed here.
Joseph S. Brzuszkiewicz is the project engineering administrator for the American Society of Mechanical Engineers (ASME). He has been involved in the standards process in the Pressure Technology Department of ASME’s Standards and Certification Sector for 32 years. In his current assignment, he is responsible for all administrative matters involving the Boiler and Pressure Vessel Code. His experience includes the development of new standards from white papers to the maintenance of well-established standards.
Mr. Brzuszkiewicz : Today I'm going to give an international update and also provide some historical perspective. Essentially I would like to cover six points. 1) International Trade; 2) National Board and ASME, Circa 1921; 3) An International Standard? 4) Consent Decree –1972; 5) Global Expansion; and 6) the Future.
Where international trade is concerned, people look at the current process of globalization as something that might be an isolated incident of the 20th and 21st centuries. Actually from an historical perspective, in the 17th century there was a lot of international trade spurred by mainly technological advances. But the technological advances at that time weren't the high-tech and internet-oriented advances of today, but simple things like improving shipbuilding navigation.
These people had a tough time positioning themselves at any point on the globe, so the breakthrough in navigation spurred sailing around the world. The big players at that time were the Netherlands, France, and England. One of the first multinational corporations was actually the Dutch East India Company based in the Netherlands. But it was much more than a simple company; they almost acted like a nation upon themselves. They had the ability to coin money, settle any type of dispute, negotiate trade treaties, and they had the full strength of the Dutch government behind them. And with all these breakthroughs, they existed in a society their ancestors couldn't imagine. So when we speak about globalization, we have to look at it in an historical perspective. The major goods traded back then were herbs, clothes, and tobacco. Now fast forward to 2011 and consider some of our top trade commodities today. The first are mineral fuels (oils and distillation products). The second is electrical (electronic equipment). The third is machinery (nuclear reactors and boilers). Those commodities are running neck and neck for first place. We are talking global trade, so for those top three, we are looking at between 1.5 and 1.6 trillion dollars' worth of trading in each of those particular three aspects of top trade commodities.
The fourth top trade commodity is vehicles (other than railways and tramways), and that amounts to about $800 billion. And then we have pharmaceutical products. On an around-the-world basis, that amounts to about $400 billion in trade for a year. This trading represents challenges for the U.S. If we go back a very short period to the year 2000, we find that 35 percent of the world's imports originated or landed in the United States. If we come forward to 2011, that number drops to only 11 percent. Even though it's only 11 percent of the pie, the pie has gotten much larger. So we have a situation where the aggregate total may be about the same, but our portion of that global pie is shrinking to about 11 percent.
Another change is in our trading partners. The U.S. was once South Korea's largest trading partner; we are now fourth. We are surpassed by the European Union (EU), China, and Japan. China now exports more goods to Brazil and Chile than the U.S. So again this is a trend. If the future is going to trend the same way, we may have to rethink certain policies. But I'm not an economist, so we will leave that for smarter people.
The National Board and ASME, Circa 1921
The year 1921 is a very important date for both the National Board and ASME. That was the date National Board had their 1st General Meeting. It was in Detroit in early February of 1921. It was also the first joint meeting with ASME. We had a number of important ASME code members meet with National Board, and they emphasized the development of the code and encouraged participation of the people with the National Board. One gentleman, Charles Gorton, was the American Uniform Boiler Law Society chairman, and he noticed (and reported) at the first General Session that he had recently toured the country and found a boiler on a ship on the West Coast with 22 individual state stamps. He suggested one goal should be to try and look into one stamp.
At the first General Meeting, there were really three goals. First was to establish uniform stamping requirements, second was registration of equipment, and third was examination for the qualification of inspectors. The National Board Web site posted a very interesting article taken from the 1921 Power magazine. It's a four-page article containing the constitution and bylaws. It's interesting from an historical perspective, so I would like to quote a few excerpts. The first is from Article 2, Section 1, in regards to uniform stamping requirements:
“Unless otherwise exempted, any steam boiler or other pressure vessel built after July 1st, 1921, may be used within the jurisdiction of any member of this Board which has been distinctly stamped with the ASME symbol.”
This firmly established the ASME symbol to be universally recognized throughout the states (by the companies and jurisdictions who were members of the National Board). Article 2, Section 3, covered data reports. It says:
“The manufacturer of each steam boiler, stamped as herein provided, shall file with this Board a detailed data report in duplicate, on forms furnished by the Secretary-Treasurer, accompanied by a filing fee of two dollars.”
Two dollars bought you a lot in 1921.
The third goal was the examination and qualification of inspectors. Again, this was another very important missing piece until the National Board passed their bylaws. In their bylaws, Article 3, Section 1, it says:
“No person shall inspect any steam boiler, or any pressure vessel, during construction and upon completion, and witness the stamping of it with a fac simile approved by the Board, unless he has a certificate of competency as well as a commission authorizing him to do so as hereinafter provided.”
Those were three very important goals established in 1921 at the first General Meeting.
An International Standard?
You may ask what this has to do with “globalization.” I will get to that in a moment. But first, the cover of the ASME code book says, “2010 ASME Boiler and Pressure Vessel Code," and beneath it says, "An International Code." One question I get from people unfamiliar with our requirements is, “Is this an ISO standard [International Organization for Standardization]?” And the answer is No, we are not trying to imply ASME is approved as an ISO standard. So why do we bother putting "An International Code" on the cover? It's a de facto international code. We have fabricators around the world. And it is also the basis of many companies' specifications. If you look to international oil companies, a lot of times they will base their contracts on specifications that require use of the ASME code. It could be a stamped vessel or may not be a stamped vessel, but again, ASME is called for in that specification and contract. With regulators, there are countries around the world who have seen the ASME code, not necessarily as meeting their requirements, but as a means towards meeting their pressure vessel regulations. So even though they may not directly accept ASME, they say you can use ASME as a basis for that particular code, but you may have to jump through extra hoops.
An example would be the Pressure Equipment Directive (PED) [of the European Union]. We publish guides for Section 1 and Section 8 that provide a model and show how each of the basic principles of the PED is covered by both Section 1 and Section 8. There are two ISO standards available: ISO 16528-1 Boilers and Pressure Vessels, Part 1: Performance Requirements; and ISO 16528-2 Boilers and Pressure Vessels, Part 2: Procedures for Fulfilling the Requirements of ISO 16528-1.
Stuart Cameron wrote an article in ISO Focus detailing the development of those first two ISO documents. He said in an ideal world there would be a single comprehensive ISO standard for pressure vessels. He points out a number of reasons why we probably would see that, and one is the differences in our regional design and fabrication practices.
Some requirements in the European code have a completely different philosophy when it comes to design and materials that do not agree with the philosophy the ASME code is based upon, so that would be one particular sticking point that would prevent a comprehensive ISO standard. There are also differences in regional regulatory practices. So what might be considered a UG 90 (c) (2) type shop where no inspection is required for every vessel that might be applicable for certain aspects of certain codes where they have less stringent inspection requirements, whereas if you built that same ASME vessel that goes with the ASME code, you would have to follow those strict guidelines in the ASME code.
ISO Part 1 is referred to as a performance-based standard covering pressure equipment. It is performance based in that it provides a set of criteria saying it must meet that criterion. It doesn't tell you how to go about meeting the criteria; whereas the ASME code is referred to as a prescriptive code or a prescriptive standard. We give definite requirements. We don't say, “build a vessel with a 3.5 design margin.” You must meet our welding requirements. You must meet our nondestructive examination (NDE) requirements. There is a whole structure built up; whereas Part 1 is a performance-based standard. It may say you have to meet a particular criterion, but it doesn’t tell you how to meet it. So a number of different standards could be qualifying in accordance with it.
Then there is Part 2, which provides the forms and procedures standards-developing organizations use to provide the documentation for acceptance. So besides meeting basic criterion in Part 1, they ask you to show the documentation. You provide documentation on a series of forms. There are certain failure modes that you have to address in Part 1. A spiral fracture, delta fracture, excessive deformation, and elastic and plastic instability, and there are other technical requirements regarding materials designed in fabrication. Part 2 provides a checklist. So you would go to what's required for meeting the material requirements, then you go back to your code and complete the check list. There has to be a one-to-one correspondence showing the ASME standard or the EN standard or the British standard meets that particular set of requirements. Following acceptance, there is a registration site where you can go onto the ISO standards web page and see what particular standards have now been accepted. In terms of ASME, I believe we have Sections 1, 4, and 8 accepted under that list.
In 1970 the Department of Justice filed an antitrust suit against ASME. The charges were not based on technical requirements, but that the ASME accreditation program was only offered in the U.S. and Canada, and this constituted a nontechnical barrier to trade. When charges were brought by the Department of Justice, they said ASME conspired to discriminate against and exclude from sale from the United States qualified boilers and pressure vessels manufactured outside the U.S. and Canada. It wasn't that the ASME code wasn't technically sound; it was considered a nontariff barrier. Even though there weren't tariffs imposed on equipment brought into this country, they felt it constituted a barrier to trade that you have to have the ASME mark to install a vessel in one of our states, but yet the only way you could get that certificate of authorization is to actually be located in the U.S. and Canada.
The initial response from ASME was we certainly appreciate this, but at the time we felt it would meet with a lot of difficulty in order to travel around the world to do shop inspections and so on. But the government didn't buy that. They said, Well, you know, you still have to come to a way to get around that nontechnical – that nontariff barrier. So a consent decree was negotiated between ASME and the Department of Justice between 1970 and 1972, and was completed in October of 1972. In part, the consent decree says ASME agrees to put into effect a fair and reasonable and nondiscriminatory procedure enabling foreign manufacturers who meet the requirements of the ASME code to qualify for and receive ASME certificates of authorization and symbol stamps on an equal basis with domestic manufacturers.
Essentially this agreement opened our accreditation program to anyone around the world who applied for it. Up until 1972, there were only manufacturers in the U.S. and Canada, so this was quite a breakthrough. It also provided for the global expansion of ASME accreditation. The consent decree also created an agreement that vessels manufactured in foreign countries and imported into the U.S. had to be registered with the National Board. If you go back to 1972 and look at the number of companies that applied for certification and the number of vessels registered at the time, the decree had very minimal impact. Even though prior to 1972 we didn't allow for international certification, we still had a situation where government more or less forced us into a globalization process.
It probably would have happened eventually, but this push might have been a good thing. You have to remember, as part of this 1972 consent decree, we get back to those 1921 principles that still apply –
uniform stamping requirements, registration of equipment, and examination for the qualification of inspectors. So even though a vessel was imported into this country (manufactured in Korea or Germany and installed in New Jersey or Texas), they still met the uniform stamping requirements, still had to be registered, and the inspection of the vessel was done by a National Board qualified person.
Prior to our signing the consent decree, we only had manufacturers in the U.S. and Canada. In 2010, the international certificate holders represented the majority. There are now more certificate holders outside the U.S. and Canada than are within the borders of U.S. and Canada. It is a major breakthrough. We have also established an International Interest Review Group available to those regulators who see ASME as a means to meet their local pressure vessel requirements. We have established a group so they can have input into our process. They are equivalent to an international form of a Conference Committee. We have also expanded globalization by increased participation of international volunteers. Every time we come to a code week, we see a large number of our Japanese friends here, and increasingly we see people from Europe. There is an increased trend toward the participation of international volunteers.
We have established a delegate program that provides a method for becoming a member of our committee but not requiring attendance at all meetings. The delegate process gets international volunteers into the ASME C&S Connect [codes and standards] process so we can go in and look at proposals, vote, and provide input from an international perspective.
As globalization has increased, ASME has made changes to its code. Two or three years ago we published a total rewrite of Section 8, Division 2. We tried to bring a more modern and international flavor to our code. We brought technologies that aren't necessarily used in the U.S. and incorporated them into our new code. Section 1 has established a Task Group on Section 1: Modernization. We have ongoing research projects trying to provide some seed to the Modernization Task Group so we can bring Section 1 into the 21st century. Also Section 3 is now undergoing reorganization. Dick Barnes, chairman, is reorganizing groups, and I think with this reorganization, we will eventually see some major revisions to Section 3 of the code.
One thing you will notice in the upcoming July 1st addenda is we are moving to a single ASME mark. You will no longer have the cloverleaf with one of the 28 particular symbols within it. We will still retain the cloverleaf, but in it will be A-S-M-E in a diagonal and on the nameplate will be what we are referring to as a certificate designator. So instead of having the cloverleaf with the S in it, you will have the cloverleaf with ASME in it and also S on the nameplate to indicate a boiler meets the requirements of Section 1. We have also expanded through major revision of our QAI-1 document and we’ve redefined the way we look at authorized inspection agencies. Again, we are trying to think globally.
In conclusion, I would like to note one thing: Change is inevitable, and we have to get ready for it. In some cases we’ve almost been dragged into change, such as with the consent decree. Other times we try to look inward, as we are with Section 3, to see how it could be revised. We see a faster pace of change. Even though the global pie may be growing, the U.S. share is becoming less and less. We have to keep an eye on it. But we must also get back to those three basic principles that were established in 1921 at the 1st General Meeting: uniform stamping requirements (the ASME code symbol stamp, although in a different form right now), the registration of equipment (an ongoing process), and the qualification of the inspectors (also an ongoing process). The first executive director of the National Board, Carl Myers, presented his vision of one code, one inspector, and one stamp many years ago. It is as viable today, 90 years later, as it was back then.