The 2025 Edition of ASME Section VIII, Division 1 makes a notable change to how design responsibility is defined. The revision of Mandatory Appendix 47 removes all previous references to “responsible charge” and replaces them with a manufacturer-controlled qualification system.
This shift places the accountability for designer competence directly on the manufacturer’s quality-control (QC) program rather than on individual credentials listed in the Code.
Rewritten Structure and Paragraph Changes
Appendix 47 has been reorganized and simplified.
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Paragraphs 47-1, 47-2, and 47-3 have been completely rewritten.
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The previous 47-3, 47-5, and 47-6 paragraphs have been deleted.
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What was 47-4 in the 2023 edition is now designated 47-3.
All language referring to responsible charge—along with the education and experience requirements that supported it—has been removed. The new text instead defines the responsibilities of designers and establishes that their qualifications must comply with criteria defined by the manufacturer’s QC system.
Appendix 47 no longer discusses the need for software training by the vendor; instead the code user/software user must continue to fall on the long established language in the forward of the code.
According to the Forward of the 2025 Edition of ASME Section VIII, Division 1 (p. xxxii):
“The Committee recognizes that tools and techniques used for design and analysis change as technology progresses and expects engineers to use good judgment in the application of these tools. The designer is responsible for complying with Code rules and demonstrating compliance with Code equations when such equations are mandatory. The Code neither requires nor prohibits the use of computers for the design or analysis of components constructed to the requirements of the Code.
However, designers and engineers using computer programs for design or analysis are cautioned that they are responsible for all technical assumptions inherent in the programs they use and the application of these programs to their design.”¹
From Code-Defined Credentials to Manufacturer-Defined Competence
Earlier versions of Appendix 47 detailed explicit qualification standards for the engineer or designer “in responsible charge.”
The 2025 edition eliminates those fixed Code requirements. Under the new approach, the manufacturer determines what qualifications are necessary for the personnel performing pressure-vessel design work.
The revised Paragraph 47-3 states that designers must meet the minimum standards defined within the manufacturer’s quality program. At a minimum, they must:
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Understand the manufacturer’s quality-control program as it relates to design activities.
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Apply the ASME Certification Mark correctly and recognize its significance.
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Demonstrate competency in the design work they perform, as defined by the manufacturer’s or assembler’s internal requirements.
These expectations are intentionally broad, allowing each manufacturer to define qualification levels appropriate to its processes and engineering structure.
Integration with the Quality-Control System
Because Appendix 47 now ties designer qualification to the quality program described in Mandatory Appendix 10, compliance depends on how that system is written and maintained.
Manufacturers must ensure that:
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The QC manual clearly defines the minimum qualification criteria for personnel who perform design work.
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Training and competency records are maintained and traceable to those requirements.
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Internal reviews confirm that only qualified individuals prepare or certify design documentation.
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Procedures describing the application of the Certification Mark align with Appendix 10 controls.
This approach eliminates the prescriptive qualification lists used in prior editions and replaces them with an auditable, manufacturer-specific process.
Appendix 10 does not include any explicit requirement for software training. Rather, it requires that the software/calcs are verified to show it correctly solves the calculations.
What This Means for Manufacturers and Designers
For manufacturers, the change expands flexibility but increases responsibility. Each organization must now define and document what “qualified” means within its own system and be prepared to demonstrate it during audits.
For designers and engineers, the emphasis shifts from meeting Code-defined credentials to meeting the manufacturer’s defined standards. The evidence of qualification will come from internal training, experience records, and competence evaluations rather than from Code citations.
This revision also ensures alignment between the design process and the quality system that controls it. The manufacturer is fully accountable for ensuring that its personnel have the necessary knowledge and skills to produce compliant designs.
Even though there is no longer an explicit requirement for vendor training in Appendix 47, it is critical to understand how to use the software properly for economy as well as safety. This also helps satisfy the forward of the code.
Steps to Maintain Compliance
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Review and update the QC manual.
Confirm that any changes to your manual line up with your stamp renewals (as applicable), are compliant with the new Appendix 47. -
Define qualification standards.
Establish education, training, and experience requirements that reflect the organization’s design activities. -
Maintain documentation.
Keep auditable records of qualification, training, and authorization for all design personnel. -
Verify alignment with Appendix 10.
Ensure that quality-program references, approval procedures, and Certification Mark controls are consistent.
Key Takeaways
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The concept of responsible charge has been fully removed from Appendix 47.
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Appendix 47 now identifies designer responsibilities and ties qualification to the manufacturer’s quality-control program.
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All requirements for education or certification are manufacturer-defined, not Code-defined.
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Compliance is proven through documentation—training records, QC manuals, and internal audits—not through fixed credentials.
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Appendix 47 removed the explicit requirement for vendor software training, but understanding how to use the software properly remains critical for economy, safety, and meeting the intent of the forward of the code.
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Appendix 10 does not require software training, but designers must still understand their tools to verify calculations and meet the intent of the forward.
In our training courses, we also demonstrate the verification of the software solving for the calculations so users can clearly understand how the tools work in practice. The ThinkTank Academy, our software learning platform, offers expert-led training across CEI, Finglow, and Paulin Research Group tools. Users can enroll in the courses they need, work through lessons at their own pace, and earn certificates upon completion.
References
¹ ASME Boiler and Pressure Vessel Code, Section VIII, Division 1, 2025 ed., xxxii.


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