Effective 1/1/2022, Appendix 47 of the ASME Section VIII, Div. 1 Code requires:

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 Responsible Charge must be actively engaged in the engineering process, from conception to completion. Engineering decisions must be personally made by the Responsible Charge or by others over which the Responsible Charge 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. (Reference: NSPE Position Statement No. 10-1778)

Specifically, the Responsible Charge shall either create or direct the creation of:

  • Design calculations including all Division UG 22 loads including:
    • Internal and external pressure
    • Vessel Weight
    • Vessel supports
    • Test pressure
    • Reactions from external connections
    • Reactions form internal attachments
    • Cyclic and dynamic reactions
    • Wind, snow, and seismic reactions
    • Impact loading, for example, water hammers
    • Loads due to thermal expansion
    • Fatigue analysis

Finite Element Analysis (FEA) provides the best solutions for loads in bold.

ASME Code requirements related to FEA are detailed in Appendix 46

  • Fabrication drawings
  • Selection of material including:
    • Material specifications for purchase orders
    • Review and approve receiving inspections
  • Selecting proper welding procedures.
  • Creation of the fabrication traveler and defining hold points
  • Defining PWHT requirements
  • Creating Nonconformance Reports (NCRs) and recommending corrective action
  • Creating pressure test procedures and approving pressure test reports
  • Creating the Manufacturing data report.
  • Interfacing with the Authorized Inspector.

KEE Engineering has a Professional Engineer qualified as a Certifying Engineer ready to partner with our clients with 20 years of experience designing pressure vessels and analyzing equipment with Finite Element Analysis.

Div. 1 Appendix 47 Legacy Design

KEE Designs and Calculates to your QA manual with methods you have been using.

Your classical method could be:

  • Hand Calculations
  • Compress® from Codeware
  • PV Elite® from Hexagon
  • Or your other software tools

KEE Engineering will your classic technique or lead your design team with techniques they already use.

Once the design is certified, KEE’s Professional Engineer (PE) and meets Appendix 47requirements, KEE will sign and apply the PE stamp to calculations and drawings.

Appendix 46 allows the use of Division 2 techniques


  • Part 4 Design by rules
  • Part 5 Design by FEA analysis

These techniques can be used to meet special requirements like:

  • Fatigue analysis, or
  • Simplify nozzle connections, or
  • Non-standard designs

KEE’s Certifying Engineer will ensure the Appendix 46 design meets Appendix 47 requirements, sign and apply the PE stamp to calculations and drawings.

KEE Engineering uses state of the art software programs to document design including Compress and non-linear Finite Element Analysis for Division 2 designs.

If your fabrication facility has a Division 1 “U-Stamp” but not a Division 2 “U-2 stamp” KEE’s professional mechanical engineering and quality department can provide teams to upgrade your facility to Division 2.

Division 2 vessels will expand your market and increase your profits because Division 2 vessels are significantly lighter saving on material costs, welding costs and handling costs that far outweigh the additional non-manual costs.

Services offered by KEE Engineering for pressure vessels and heat exchanges include:

  • Division 1 and Division 2 calculations
  • Fabrication Drawings
  • Procurement specifications
  • Evaluation of proposal submittals for code compliance
  • Weld procedures, Procedure qualification and Welder qualification
  • Evaluation of Fabrication change request
  • Pressure testing procedures and documentation
  • Preparation of ASME forms
  • Preparation of documentation for Authorized Inspector (AI)
  • Pre AI-inspection review
  • Manage AI review


Pressure vessel repair is often scheduled during plant outages and the extent of the repair is often discovered during the outage. Proper planning will minimize the potential of costly extension of outage time. KEE Engineering can provide worst case scenario planning during pre-outage planning to ensure that all material, procedures and contractors are available to minimize the time required for unforeseen repairs.

Engineering Support

KEE Engineering’s teams can provided support in the following areas:

  • Engineering scaffolding design as required by OSHA
  • Design of temporary supports with scaffolding or structural steel
  • Pressure test specifications, procedures and documentation
  • Engineered pressure test caps that can be fabricated in the field
  • Critical lift design and documentation
  • Design of special lifting lugs, trunnions, and spreader bars


KEE Engineering uses state of the art parametric solid modeling software and finite element software to optimize design of new products and review for potential improvements to existing products. For new product design, the process shortens the design cycle, ensures designs meet code requirements optimizes fabrication and minimizes the requirements for prototypes. For existing design, KEE Engineering analysis can identify opportunities for costs savings as well as extension of fatigue life and failure analysis.