Minnesota Department of Labor and Industry

Construction Codes and Licensing Division

Jurisdictional and departmental boundaries for HPP/boilers

The 1998 ASME Code section I, Figure PG 58.3.1 and PG 58.3.2, pages 43 and 44, show where
ASME Code section I and ASME Code B31.1 apply. It also illustrates piping that is beyond
section I and B31.1 requirements. Any item that requires construction to ASME B31.1 and/or
section I will require ASME Code stamping, data report, inspection and sign-off by a National
Board commissioned inspector.

Also in Minnesota, any item that may be considered high-pressure piping (HPP), which also
includes the B31.1 piping shown in ASME Code section I, Figures PG 58.3.1 and PG 58.3.2 and
beyond, require high-pressure-piping inspection and application of HPP statutes and rules.

How to read Figure PG 58.3.1 and PG 58.3.2

Piping shown as a thin black line is “boiler proper” and shall be manufactured by the appropriate
ASME certificate holder and inspected by a National Board commissioned boiler inspector.

Piping shown as a heavy black line is “boiler external piping” or BEP. This piping shall be
manufactured by the original boiler manufacturer or other appropriate ASME certificate holders.
It must meet ASME Code B31.1 technical requirements; it must be stamped and certified by an
appropriate ASME certificate holder; and it must be inspected by a commissioned boiler
inspector who, when satisfied, will sign the appropriate ASME data report. BEP shall also meet
the current requirements of the high-pressure-piping Minnesota Statutes, chapter 326, and
Minnesota Rules, chapter 5230.

The Boilers, High-pressure Piping and Boats-for-hire unit has also adopted in its rules, the
technical requirements of ASME B31.1.

The piping identified by a broken line falls completely under the jurisdiction of the Boilers,
High-pressure Piping and Boats-for-hire unit; there is no requirement for inspection by a
commissioned boiler inspector and ASME certification is not required. This piping is subject to
the HPP requirements, such as contractor license and permit. Any welding must be performed by
qualified individuals, in accordance with the HPP requirements.

The two primary methods of joining BEP are welding technology and mechanical, such as bolted
or threaded assemblies. Both methods are subject to inspection and documentation criteria as
prescribed by ASME Code section I for new construction and by the National Board Inspection
Code for repairs and alterations.

ASME Code section I has eight types of data report forms that may be used by the manufacturer
to record all the items of a complete boiler unit. When the certification of a complete boiler unit
is accomplished by more than one ASME certificate holder, using more than one data report, a
principal data report, consisting of form P-2, P-2A, P-3, P-3A or P-5, shall be designated as the
master data report.
The boiler manufacturer must have a master data report to fully describe and document all parts
of a complete boiler unit as having satisfied ASME Code certification. This master data report
may also document construction of boiler external piping and piping components also
manufactured by the boiler manufacturer. If the boiler manufacturer has not manufactured the
boiler external piping, the BEP is excluded from this documentation.

The organization responsible for the fabrication and installation of BEP, if other than the
manufacturer, is responsible for documentation and distribution of copies of form P-4A or form
P-4B to the inspection agency and jurisdiction.

Form P-4A shall be used to record all shop or field welded piping that falls within the scope of
ASME section I, but that is not furnished by the boiler manufacturer.

Form P-4B shall be used to record all field mechanically assembled boiler external piping. (This
form may not be used if the piping contains a welded joint.)

Example 1: A boiler manufacturer constructs a high-pressure boiler, including boiler external

piping, in its shop. The appropriate master data report is certified by the manufacturer and, when
signed by the commissioned boiler inspector, the ASME Code requirements are met. Note: All
welded BEP more than two inches nominal pipe size (NPS) must bear the appropriate ASME
Code symbol stamp. It may or may not be registered with the National Board and bear a National
Board registration number.

In Example 1, the BEP could be disassembled and shipped with the boiler for mechanical
assembly and re-attachment in Minnesota. In this case, the BEP installer must complete data
report form P-4B. The P-4B form must be signed by a commissioned boiler inspector after the
required final pressure test is completed. Note: The commissioned boiler inspector would not
indicate his National Board commission number on the form if the piping is not registered with
the National Board.

Mechanically assembled BEP that contains no pressure boundary welds does not require
stamping and may be assembled by a non-ASME certificate holder (PG 109.4 of ASME section
I). This organization must have a high-pressure-piping permit to assemble and install. The
responsibility for documentation and hydro testing of this mechanically assembled BEP must be
assumed by a holder of a valid “S,” “A” or “PP” stamp. Note: There has not been an instance yet
where an ASME certificate holder has taken responsibility for another firm’s fabrication; this,
essentially, means if the contractor does not have the appropriate ASME Code symbol stamp,
they likely will not be able to legally install the boiler.

If any welding is performed on the BEP described on the master data reports and shipped with
this boiler, or if any BEP is weld fabricated in the field, this welding must be done by an ASME
“S,” “A” or “PP” certificate holder and high-pressure-piping permit holder. It must also be
inspected by both the HPP inspector and commissioned boiler inspector.

Example 2: A boiler manufacturer constructs a boiler, and no welded BEP or not all of the
welded BEP was provided with the boiler. In this case, the contractor who manufactures and
installs the BEP for this boiler is required to have a valid ASME “S,” “A” or “PP” stamp and a
state of Minnesota high-pressure-piping permit. All piping must meet the requirements of ASME
B31.1, ASME section I and Minnesota high-pressure-piping rules for construction. The
fabricated BEP is subject to inspection by a National Board commissioned, authorized inspector
with an “A” endorsement, at the manufacturer’s shop or field site. The certification of the
appropriate data report and a final inspection and witness of the hydro test by the commissioned
boiler inspector and high-pressure-piping inspector are the final steps in this process.

All boilers are subject to a hydrostatic test prior to start-up to ensure the integrity of the boiler
and piping. This test must be witnessed by a commissioned boiler inspector (Minnesota Rules
5225.2100) and the state high-pressure-piping inspector. If the location has a boiler and
machinery insurance policy in effect, the contractor must contact the insurance company to
perform the hydro test inspection services. If the location has no boiler insurance, the state boiler
inspectors must be contacted to perform the hydro test inspection.

Attached with Figure PG-58.3.1 is Appendix A-357, the guide for data reports required for
certification of boilers to ASME section I and PG 109 from ASME section I.

Specific requirements relating to the subject outlined above should be referenced in the
appropriate code sections. The ASME Code sections may be purchased directly from ASME by
calling 1-800-THE-ASME (1-800-843-2763).

Boiler and HPP rules and regulations may be purchased from Minnesota’s Bookstore by calling
1-800-657-3757 or (651) 297-3000. Boiler and HPP statutes and rules are available online at
www.doli.state.mn.us/code.html.

Joel Amato, chief boiler inspector, (651) 284-5137

Todd Green, chief HPP inspector, (651) 284-5124