Manufacturer Data Reports

When performing Compliance Audits and Mechanical Integrity inspections, I often find facilities do not have Manufacturer Data Report as required for a compliant PSM program.

What is a Data Report?

Often referred to as the “birth certificate” of a pressure vessel or heat exchanger, the data report (U-1 or U-1A, U-3 form) is a document supplied by the manufacturer which describes the specifications, materials used, types of welding employed, etc., for the construction of an ASME certified vessel or heat exchanger. ASME B&PV Code Section VIII UG-120 requires a data report to be prepared and ASME B&PV Code Section VIII Appendix W provides sample forms and guidance for pressure vessel manufacturers responsible for preparing a data report.

Where in the PSM regulation does it require a Data Report?

You will not find a section in PSM which explicitly requires data reports. However, the following two (2) sections of PSM require data reports through the disguise of our favorite acronym, RAGAGEP.

1. Process Safety Information

Title 29 CFR §1910.119(d)(3)(ii) requires the following:

“The employer shall document that equipment complies with recognized and generally accepted good engineering practices.”

In regards to a pressure vessel or heat exchanger, a data report is the only documentation available to demonstrate compliance with the above-stated requirement.

2. Mechanical Integrity

Title 29 CFR §1910.119(j)(4)(ii) requires the following:

“Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.”

For the ammonia refrigeration industry, IIAR Bulletin No. 109 has long been considered the RAGAGEP for performing an annual inspection of a refrigeration system. Both the Pressure Vessel and Heat Exchanger checklists ask the following question:

“Manufacturer data report on file?”

How do I Obtain a Data Report?

There are three (3) main avenues for obtaining data reports:

1. Installing Contractor – Typically, the data report is supplied to the purchasing contractor when the vessel is shipped for installation. Contact the contractor who installed the vessel or heat exchanger and request the data report.
2. Manufacturer – If the installing contractor is no longer in business, or not cooperative, contact the vessel or heat exchanger manufacturer directly and request the data report.
3. National Board – If the manufacturer cannot produce the data report, then your final option is to contact the National Board directly. This option will only be available to vessels and heat exchangers which were registered with the National Board and are equipped with a National Board number. You can submit the request online and purchase the data report for a $26 fee per page of the report.