Industry appreciates and…

Industry appreciates and supports the proposed changes, which move OPSS 905 toward requirements that better reflect industry steel reinforcement manufacturing practices and can be practically implemented. The intent of this feedback is to further align the requirements with how reinforcement is actually fabricated, while maintaining the required level of engineering review, welding qualification, testing, traceability, and quality control. Key recommendations are to provide clear definitions for Structural or Project-Specific Welds, Fabrication Support Weld (Fabrication Note 2Welds )(spacers), and Resistance Welding (already defined); use sealed Working Drawings for project-specific welding information; manage recurring welding procedures, machine operating procedures, and qualification records through the applicable MTO DSM/fabricator qualification process; and include the applicable references to support clear traceability.

The other main concern is the fixed requirement to submit certain information 7 Days prior to the commencement of steel reinforcement fabrication. Some project-specific information, particularly the actual heat and material certificates for the reinforcement used, will only be available during fabrication. Submission timing should therefore reflect when the information is actually available: project-specific welding requirements through sealed Working Drawings, recurring process qualifications through the DSM process, and material certificates for the reinforcement actually incorporated into the finished product prior to shipment. The detailed comments and requested revisions are summarized in the following table.