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Up Topic Welding Industry / Inspection & Qualification / Level III & CWI Duties
- - By cremx (*) Date 06-23-2009 14:52
An employer´s written practice approved by a external Level III establishes the following:

4.1.3 Responsability oe each level.....
4.1.3.3 Level III...The NDT Level III, in the methods in which is certified, shall be capable of training and examining NDT level I and II personnel for certifications in those methods

6.0 Responsabilities
6.4 Level III or CWI (Certified welding inspector by AWS only for VT) personnel is responsible for NDT aplication and qualification of each NDT level, and also is responsible for NDT training and qualification (As described in 4.1.3.3)

The facts:

The same external Level III who approved the written practice has qualified a VT Level II, but this external Level III is not qualified for VT but he is CWI

Questions:

a) It is in compliance of SNT TC-1A?
b) It seems to be a interest conflict?
c) SNT TC-1A-2001 paragraph 1.4 allows to review and modify the recommendations presented herein. Is this is the case?
d) The Level III ethics is in question?
Parent - - By Mikeqc1 (****) Date 06-23-2009 18:42
Looking into this.
MDK
Parent - - By cremx (*) Date 06-23-2009 21:32
Mikeqc1,

LOL¿¿¿??
Parent - By michael kniolek (***) Date 06-23-2009 23:35
That’s the issue with TC-1a its extremely flexible.
I cant readily point out where its forbidden, but even if it was, it could be modified to suite the employer.
So I would think that if its documented in the Written practice and approved by all responsible parties I would accept it.
I have a welder that’s LVL II in VT and when his EYE exam comes up I run out make him read the required chart document it and im done.
I did question this practice .....so.....I checked the written practice and it was documented that our LVL III or any1 designated by the LVL III would perform this exam.
It was signed by all parties.
Done.

mikeqc1
AKA
MDK
Parent - - By Joseph P. Kane (****) Date 06-23-2009 22:09
Look at Paragraph 1.4

Anything the employer wants to do is acceptable, if the written practice takes advantage of this paragraph.

However, the customer does not have to accept your written practice.
Parent - By trapdoor (**) Date 06-24-2009 00:26
I know there are many exeptions on one hand but on the other hand how many customers read the NDT written practice and know what it all means? It's all voodoo to most people. Where is the regulation?
Parent - - By cremx (*) Date 06-24-2009 04:00
In my opinion, paragraph 1.4 works if you follows the SNT-TC-1A rules. I disagree if you use 1.4 to modify the basic rules, i.e. Level III characteristics paragraph 4.3.3, as statement: "The NDT Level III, in the methods in which certified, should be capable of training and examining NDT Level I and II personnel for certification in those methods"
Parent - - By Joseph P. Kane (****) Date 06-24-2009 18:23
The word "should" does not imply a mandate.

The wording "The NDT Level III, in the methods in which certified, should be capable of training and examining NDT Level I and II personnel for certification in those methods" ... does not imply that a Level 3 can ONLY certify a Written Practice that covers a method in which he/she is certified.  It has the "Should" word, which implies "At Least", not "At Most".

I would argue that the Level 3 basic covers the question of certifying a Written Practice all by itself.  The level 3 method certifications are more a qualification to adjudicate and help rectify problems associated with practice in that method, not TRAINING and Testing to SNT-TC-1A in a specific method.
Parent - - By cremx (*) Date 06-24-2009 21:56
I agree with you, however, in my case, the VT qualification should be limited to welding inspection only

Look a this:

Inquiry 89-7
In reference to the SNT-TC-1A (1984 Edition), we want to know if the words “should” and “shall” have a specific definition. If these words have a specific definition, what is the scope of each?

Response
No. The words “should” and “shall” do not have a specific definition applicable to the 1984 Edition of SNT-TC-1A.

The implied intent of these words initially was that “shall” was used to express the importance of a particular function or activity to be considered by an employer in the written practice, whereas “should” was intended to denote a suggested or recommended function or activity which could or should be considered for inclusion in an employer´s written practice.

A conflict in the intended usage of these two verbs was introduced by a regulatory body which interprets the words “shall” and “should” when used in their code as “shall” meaning mandatory and “should” being preferred.

To further clarify ASNT´s position on the use of these words in the context of SNT-TC-1A, the 1988 Edition of SNT-TC-1A now defines “shall” and “should” in Section 2.1 as

(8) Shall: a verb used to express the minimum recommended guidelines for most employer´s qualification and certification programs; this is intended to express what is mandatory by law or regulation.

(9) Should: a verb used to express the desired guidelines for most employer´s qualification and certification programs.
Parent - By Joseph P. Kane (****) Date 06-25-2009 12:35
Cremx

I am always leery of the TC-1A committee's interpretations.  This one is typical.   Many of the committee's interpretation clarify the intent of what the current committee members think it is.  This is the same thing for all consensus committees. 

However,in the case of this committee, they do not have the stones to go back and change paragraph 1.4.  The original document was intended to be a guideline.  It was written so that adaptation could be made for individual and unique situations.  This would be ideal in an ideal world where everyone wanted their inspectors to be the best, be most diligent, and the companies themselves weren't crooks, or didn't have cutthroat competition.

So, since 1966 this committee has been able to infer (If their collective IQ was greater than 66) or have been directly told, of the problems and ambiguities the wording in their document can cause.  Did they change the basic wording?  No.

So, until they change paragraph 1.4 and a few other sentences, I will continue to pick and choose whatever I want,   If I win the big lottery I'll sue the pants off everyone of them for mopery with intent to gawk and compound duplicity.

I used to read the official interpretations, but unless they support some position I want to hold, I refer back to paragraph 1,4 and go my merry way.

Joe Kane
Parent - - By michael kniolek (***) Date 06-27-2009 00:07
It All reverts back to the written practice, but should the written practice implement a certain part of SNT-TC-1a that might bind him to other obligations.
If the Written practice you mentioned had not put in “Level III or CWI (Certified welding inspector by AWS only for VT) personnel is responsible “  I would call them on it.
It all comes down to what the customer , LVL III and employer agree to and sign.
So even if it was all a bunch of BS rest assured when the Company folds and said LVL II  or LVLIII looks for a new job all the rules get changed.
MDK
Parent - By cremx (*) Date 06-30-2009 00:04
It is mean that the employer´s written practice take precedence over the SNT-TC-1A requirements?
Parent - - By CWI555 (*****) Date 06-24-2009 02:29
In regards to SNT-TC-1A.

It is going to eventually die if this kind of loose interpretation persist. ASNT is slowly but surely killing themselves by letting it persist.

However, even in SNT-TC-1A there was a statement regarding contract docs. If those contract docs specifically invoke the language of TC1A as a rule rather than a guide, then that is how it is to be interpreted. The same applies if a governmental authority invokes it as a rule rather than a guide.

Left alone it has no power whatsoever. Only 'contract docs when so written, or governmental regulations when so written', that give TC1A any standing on it's own.

I would be concerned with the situation as well. Especially given they went to an external Level III and didn't bother to require either a SCWI, or a LIII VT to sign off on the visual certs. I could buy into it if it were an SCWI as B5.1 table 1 gives some credence to that idea.
While there are many capable CWI's out there, There is some risk involved here. If something goes south, (blows up) all parties involved are going to have one hell of a time in court explaining why they felt a CWI was qualified to perfrom that funtion when every industry document either explicitly says no, or recommends to the contrary.

I don't think the level III themselves have done anything wrong from an ASNT ethics standpoint. If the client bought off on this then the it's on them. Where there would be an ethics violation is if that LIII misrepresented themselves as something they are not.

From an AWS Standpoint it's a bit more grey. Table 1 B5.1 gives some room for there to be a problem with a CWI certifying LII VT hands.

I claim to to work on rockets, but I won't claim to be a rocket scientist, or have any particular expertise other than to say I've worked on some rockets. If NASA contracted me on that basis with all facts given up front, it's then their problem.

Regards,
Gerald
Parent - - By michael kniolek (***) Date 06-26-2009 23:42
Im currently studying TC-1a to take my lvl III basic test,and it was a kanundrum to me.
Why do anything if its all a "recomendation"
And i have NEVER seen such a short document have so many interpretations!
MDK
Parent - - By Joseph P. Kane (****) Date 06-28-2009 20:33
MIKE

The document was deliberately made to be less restrictive than it could have been.  Reportedly, it was generated back when a group of sincere and idealistic experts realized that some codification and standardization of training, training procedures and classification of personnel would help the industry.  Others suggest that it was an industrial attempt to circumvent having Mil. Std. 410 become the civilian standard by default.   (Both documents were born in the late 60s.)

Soon after, the industry revealed it's true colors,(although I believe that the industry was just as crooked before SNT-TC-1A as it appeared to become later on.) and the dollar ruled, instead of training and minimal standardization. 

Now, it is incontrovertible that the document was designed to be liberal, as well as to fit a broad expanse of application.  It was also an attempt to give testing companies a legitimate claim  to qualification and national standardization. 

Through the years the committee members have tried to reign in some of the liberal interpretations that have surfaced over the years, by issuing restrictive "Interpretations".   WELL, I DO NOT THINK THEY HAVE A RIGHT TO DO THAT!

If they want to issue restrictive "Interpretations", they should be Issuing TC-1B, or TC-2A.  They should not be issuing FATWAS that are essentially revisionist ideas of what they think is the best way to do things in 2009, or 1999, or 1988, or 1984.   Change the document sufficiently to remove the liberal "one size fits all" wording, or recognize that the original idea was really quite valid then and still is quite valid today.

Joe Kane
Parent - By 803056 (*****) Date 06-28-2009 22:26
While it isn't a cure all, many organizations that purchase NDT services would do well to specify CP-189 instead of SNT-TC-1A. It is still an employer based program, but CP-189 is a standard that delineates the minimum requirements for qualification and certification. It eliminates many of the liberties taken by NDT providers when SNT-TC-1A is specified in the purchasing documents or project specifications.

Best regards - Al
Up Topic Welding Industry / Inspection & Qualification / Level III & CWI Duties

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