Written practice

Date 09-02-2011 11:59

Mike,
Once work such as that is subcontracted out the program of jurisdiction then becomes the subcontractors. His procedures, his approvals, his Level III. The subcontracting party now shifts to the supplier approval process, wherein the subcontracting party verifies that the subcontractor is complying with his program. A different chapter in the manual. It is certainly beneficial if the subcontracting party has some expertise in evaluation of procedures, etc., in this case NDE, but it is not a requirement unless their program states explicitly that it is.

By Mikeqc1 (****)

Date 09-02-2011 19:25 Edited 09-02-2011 20:36

Snt-tc-1A Definitions
Employer : the corportate , private or public entity which employs personel for wages salary, fees or other consideration.
A company who has no NDE program or inspectors needs a LVL III and qualification program. they do however have a person who will be the inhouse LVL II.
so they employ a LVL III to set up and qualify the NDE program and personel..
They appoint him JOE as the Companies level III .
The Employer has no responsibility to draft a written practice, and that the written practice can be come from anyplace or any company with any name across the top?
And approvals can be by any LVL III ?

I see this as a problem here is why.
The manufacturer builds a vessel the thing fails in service.
Come to find that Poor NDE practices are to blame.
The Manufacturer is dragged into court.
They ask to see qualifications of NDE personel.
They ask who approved this written practice and NDE procedures.
The Manufacturer says Greg approved the written practice and Bob Approved the MT procedure (Both Level III)
So Greg and Bob are in court they ask about the Documents Yes I approved this or that they say.
Then the letter appointment is dragged out, it appoints Danny as the manufacturers LVL III.
Danny is questioned Danny says That’s not my Approval ....end of story for Dan?
Greg and BOB say Wait we were never appointed as LVL III for the Manufacturer.

Next ill be told again that If a written practice has a visual eye exam requirment of J-1 then the j-2 will be still acceptable.

By Mikeqc1 (****)

Date 09-03-2011 13:04

I disagree the responsibility remains with the FAB Shop.

By js55

Date 09-06-2011 12:08

Apparently I didn't give you the answer you were looking for. :lol:

Thats OK. Sooner or later somebody else will.

By Jim Hughes (***)

Date 09-10-2011 11:31

That's correct js55. This is a fishing exersise to justify something. :) SNT-TC-1A is not a mystery. ASNT gives the writer the latitude to write it they way they choose. Right, wrong or inadverent that is the way it works. Using the tools that ASNT gives, such as the Model Written Practice, Recommended Practice and speaking with ASNT tech servise folks you can have a very good program that will meet or exceed industry standards. If the program is set up correctly "Billy" won't find himself in court.

Jim

By jbndt

Date 09-02-2011 22:09

Mike,

Your post asking how level II’s come into this has disappeared!

Because somebody has to do the testing and as I said,
“You DO have to be a “practicing level II” to do testing according to a book that I read once. ”

6.14.6.1 ASNT Requirements. Personnel performing NDT other than visual shall be qualified in conformance with the current edition of the American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1A. Individuals who perform NDT shall be qualified for:
(1) NDT Level II, or
(2) NDT Level I working under the NDT Level II

Cheers,
jb

By Mikeqc1 (****)

Date 09-03-2011 12:55

Yes i understand ......
But my question is can a manufacturing plant who Needs an NDE program Appoint a LVL III yet have a different LVL III approve the written practice that has not been developed for the manufacturer.
and shouldnt the written practice be developed by the employer....not the NDE Company who was subcontracted.
Lets say i own a weld shop.
My customer requires NDE Quals Per SNT.
i have no level III but i have an inhouse inspector (who will do the Inspections)
i call A NDE service to find a LVL III to assist in the development of a written practice and Qualifications ETC.
I send the Letter of appointment and recieve back a letter of acceptance.
My company now has a LVL III to perform these tasks.
Again i think that the written practice should have the Fab shop name address and a signature of someone from the Fab shop(employer), and the Approval of the Same LVL III who was appointed.
i dont think that a fab shop should use the written practice of the NDE contractor and im sure that appointing BoB as the level III but having Greg approve the practice is not proper.
My questions are all about approvals.

By js55

Date 09-06-2011 18:54

Mike,
The NDE company who is subcontracted IS the employer.

By js55

Date 09-06-2011 19:29

If you look at the definition for Written Practice it states "their employees".
The subcontractors employees are NOT the fabricators employees.
The only time they would be considered as the fabricators employees is if the examiners are operating under the fabricators system, with the fabricators procedures, approved by the fabricators Level III, qualified per the fabricators Written Practice, and supervised by the fabricators supervision.
This is no different than these large EPC's subcontracting out fabrication and not even reviewing weld procedures. It doesn't matter. The fabricator is responsible for the welds and code compliance with their procedures. NOT the EPC.
If your argument holds then everybody up the food chain would be responsible for maintaining a Level III who in turn ALL are responsible for reviewing and approving procedures and qualifications. As much as these contract Level III"s would like that it isn't the way its done.
How is it the fabricator is ultimately responsible as you state but not the general, the EPC, etc.? Is not the fabricator just another subcontractor like the NDE company?
Is it incumbant upon a fabricator to have Level III comparable expertise in all facets they subcontract? Paint, galvanizing, machining, PWHT, NDE, Engineering, cold forming, hot forming, metallurgical services?
Doesn't that sort of run counter to the whole logic of subcontracting?
If I sub out engineering I do not have to have a PE on staff to review all calculations. I simply review the qualifications per code requirement for the PE I am subcontracting, and who is claiming they are the experts. That is why I am subcontacting. If I were capable of reviewing the calcs on par with the engineer I wouldn't need the engineer.
Do all fabricators with R stamps have to have PE's on retainer to review the calcs performed by their subs?
Now certainly a fabricator is going to be held responsible for their subs, just as your General would be held responsible for the fabricator. It doesn't change the expertise requirements. Just how you may go about your due diligence. I garantee you I am reviewing calculations as best I can for code compliance. But in the end I am not an engineer with pressure vessel experience, nor am I required to retain one to review my subs work.

By Mikeqc1 (****)

Date 09-06-2011 23:17

No Sir,
Just one LVL III who is appointed by the fabricator He and he alone has responsibility to the written practice and procedures, not a LVL III who is not in the mix or the acting LVL III of the company, and the employer holds resposibility over all of it written practice and proceedures even if its subcontracted.

By js55

Date 09-07-2011 12:30

Mike,
You can certainly do that if you wish (and actually I do) but it is nowhere a requirement, it is due diligence. The requirement (if your program chooses to make TC-1A a requirement)is that the company under who's program the procedures are written and controlled by the Quality Manual is responsible for Level III oversite. In other words, whoever's name is on the Manual controlling the procedures is the company responsible for Level III oversite.
SNT-TC-1A is an employer based recommendation program. When subcontracting the subcontractee is NOT the employer.
Even in Section III (arguably the most stringent construction standard wherein TC-1A actually becomes mandatory NB-5521(a)) any language pertaining to Level III references the employer. And in NB-5523 it states, "The Certificate Holder (i.e. the fabricator in this context) has the responsibility to verify the qualification and certification of nondestructive examination personnel employed by Material Organizations and qualified by them in accordance with NCA-3820 and subcontractors who provide nondestructive examination services to them." Heck, Section III does not even require the Level III be present when demonstrating your procedure qual to the ANI. You need a Level III signature on the procedure, to be sure, but if you are using a subcontractor his Level III signature is required to be there the fabricators isn't. In other words, you do not need to have two Level III signatures. If you argue that the fabricator must sign the procedure then who's signature is going to be there when the sub works for someone else? So you are essentially arguing that two Level III signatures are required where the sub goes. I do not believe anybody believes that.
In other words, the Certificte Holder is required to verify quals and certs NOT approve or evaluate NDE procedures. There is nothing in Section III about a Certificate Holder having to retain a Level III to evaluate subcontract NDE procedures.
When I send my auditors out to evaluate a subcontractor, and among other things evaluate the NDE qualifications and certifications of a subcontractors employees, they are not necessarily Level III's. And they are not required to be so.
TC-1A does not require it, Section V does not require it, and neither do any of the construction codes I am familiar with.

By Mikeqc1 (****)

Date 09-07-2011 16:41

im not saying 2 LVL III need to sign....just one and it needs to be the one appointed by the fabricator.
I cannot be a random LVL III.

By js55

Date 09-07-2011 18:32

But, if the subcontractor has a Level III that has approved the procedures the fabricator does not need to appoint one to do so again.

By js55

Date 09-07-2011 13:32

If I might frame this several other ways.
If a subcontractee must have a Level III responsible for the Written Practice and Procedures, then who is responsible when the subcontractor works for someone else?
If the subcontractor has 30 clients, are all 30 clients Level III's responsible for the Written Practice and the subcontractor isn't required to have a responsible Level III?
In all this, is the subcontractor never an employer and never required to have a responsible Level III?
Is the fabricator not a subcontractor in many instances himself?
And if so, is he now NOT responsible for a Written Practice in the same manner that you are arguing his subcontractor is not responsible?
If the fabricator and subcontractor are both responsible then wherein lies the requirment that says the fabricator is the last subcontractor in the food chain responsible and his clients are not?
It seems to me the way you are arguing this is turning TC-1A, Section V, and the construction Codes into indeciferable nonsense.

By Mikeqc1 (****)

Date 09-07-2011 16:38

we are way to far removed from the original issue the Written practice and approvals.
a fab shop with NDE potential personel for LVL I LVL II has been contracted to weld and perfom NDE.
they Seek out a LVL III to certify them.
Q.....under whose written practice should this be done under?
Remember the LVL I and LVL II are employed by the fabricator.
SNT seems clear on this......it is the responsibility of the employer.
Q.....Do you think its ok for the fabricator to just use the LVL III company written practice or should the fabricator draft his own.
Q.....and if he drafts his own shouldnt the appointed lvl III approve it?

By js55

Date 09-07-2011 18:30

Mike,
Your original post said the employer has no NDE program or personnel and he needs to subcontract it.
This is significantly different than a fab shop that has been contracted to perform NDE with 'potential' personnel, or Level I/II employed by the fabricator. Technically you can't have an SNT-TC-1A Level I/II without a program of some kind since TC-1A is employer based.

If you subcontact NDE then the subcontractors program, Written Practice, and Level III apply. If the fab shops personnel are going to perform NDE then the fabricators program, written practice, and Level III will apply. There are some allowable gray areas in here but I won't muddy the waters.

To use a Level III company's Written Practice you essentially have to make it your own. This is not a bad idea. Your Level III writes it and signs it and you incorporate it into your system with a company rep signature as well. No different than having a consulting company help you develop your NDE program. In fact, thats what you would be doing.
Many people like to see someone different review a procedure but it isn't required unless you say so in your Manual. For example, if you had an in house Level III you could develop a review independent of them, but that review is not required to be another Level III. You are not required to have two Level III's or go outside if you have on 'in house'.

By Mikeqc1 (****)

Date 09-03-2011 13:02

the issue isnt about LVL II its about the LVL III and who can approve the written practice.
i think the companies appointed LVL III needs to approve the practice not any other LVL III

By Mikeqc1 (****)

Date 09-16-2011 22:59

Let me Beat a dead horse….
If a contract states that a product will be manufactured by ACME and states that personnel will be qualified under Acmes written practice.
You audit them and find they do not have a written practice, they produce a subcontractors written practice, signed by the sub contractors president and their level III they could not produce Qualification records or a letter of assignment for said level III.
Thoughts?

By js55

Date 09-19-2011 11:52

Are you talking about the sub not being able to produce qual records or a Level III letter?
Does the Level III work for the sub?
If so, they don't need a letter.
If the sub does not have qual records there's a problem. If the fabricator doesn't have qual records its a who cares.

By js55

Date 09-19-2011 12:01

One other comment. If ACME doesn't do NDE why would they have a written practice?
Even if they did have one, if they are subbing the NDE the Written Practice would mean doodly.
A written practice is generated by the employer. The sub.
If a contract was signed by ACME and their customer stating that ACME should have one when they don't do NDE then shame on both ACME and the customer for not recognizing that the contract as stated is essentially irrelevent.
Didn't anybody for the customer review procedures? Or at the very least note whether or not they exist?
There may be a contract issue here. Certainly sounds like there is. But there is no code issue that I can see. As long as the sub has the written practice, the quals, and the Level III. ACME may have violated the code but the customer was negligent in evaluating ACME.

By bozaktwo1 (***)

Date 09-20-2011 16:55

My line of thought on that would be a contractual issue. I often must report my outsourcing of critical processes. NDI is one of them. So by the language in the contract, a requirement is being stated that cannot be met.

By js55

Date 09-20-2011 19:23

bozak,
I would agree that it seems in this case a contract violation has been made. But somebody ain't paying attention. Why would you insist upon a Written Practice for a company that is going to sub their NDE. Thats like insisting someone have a furnace when they are subbing PWHT. You may write a specification dictating what you expect of a Written Practice (or PWHT) but a specification is not a written practice. And a Written Practice for anyone other than the employer of the NDE personnel is meaningless in a TC-1A context.

By Mikeqc1 (****)

Date 09-22-2011 19:25 Edited 09-22-2011 20:06

ok so when NDE is Subcontracted the Written practice is The resposibility of the NDE employer.
If Acme were to hire or wish to train lvl IIs without a LVL III they appoint one and develop the written practice, and have the LVL III train and certify.

By js55

Date 09-23-2011 11:53

Yes.
I do it both ways. We utilize in house VT, MT, and PT. I have a Written Practice for those, I have Level II's performing the NDE, and a contract Level III (I actually have several Level III's because the company I use provides more than one and I utilize the one with the most expertise in the Particular method (its the same cost)) to administer the program as required.
However, I also subcontract RT and UT and expect and review the subcontract Written Practice. I actually have my Level III review them as well though it is not required.

By Joseph P. Kane (****)

Date 09-02-2011 22:47

jbndt, JS55, Mikeqc

Everyone should read, memorize and make liberal use of SNT-TC-1A, Paragraph 1.4!!!!!!!

I have always made liberal use of Paragraph 1.4 of SNT-TC-1A, and made my "Written Practice" fit the way "I" want to work. I do not care about official interpretations from ASNT!!!!!! F--K T--M!!!!!!!!!!!!! They have not changed paragraph 1.4 since the first edition in 1966!!! So, if I want to do something differently, I just write it into my "Written Practice", and do it. If ASNT and the TC-1A Committee doesn't like it, let them change paragraph 1.4.

Now, I have to tell you that not every customer will accept my written practice! However, under the law of the states that I have practiced in, my written practice is completely legal.

Usually, most customers do not know enough about SNT-TC-1A to argue with me about it!!! I run into die hard level 3s who "know" I am wrong, but whom also agree that I have a right to change things the way I wanted to, using paragraph 1.4! In those cases, I just do not get accepted.

Joe Kane

By jbndt

Date 09-02-2011 23:38 Edited 09-02-2011 23:42

Ah Joe,

Your always so subtle! :lol:

That is the primary reason that I mentioned CP-189.
At least it's a step in the right direction.

Cheers,
jb

Edit: Spellin'

By Joseph P. Kane (****)

Date 09-03-2011 04:16

jbndt

I do not think CP189 is the "Step in the right direction". The whole ASNT qualification scheme set is fraught with protectionism, and short on real-value. They almost went there there with ACCP, but only to a small extent.

In MY (not so humble) opinion, the whole "Level 3 requirement" is the real reason that few companies are legitimately in compliance. Plus when you do get a Level 3, he proceeds to feather his nest and make himself more important than he really is. Then he becomes too expensive and costs the company their whole NDT program.

The "mandatory requirements" in CP-189 do weed out the guys like me, who actually have a copy of SNT-TC-1A, have read it, understand it, know the problems associated with it, know it's real intent and limitations (I.E., It is not an operations manual, it is just a training circular). However, neither CP-189, nor ACCP can regulate and insure honesty, integrity and competency in actual NDT operations.

Joe Kane

By 803056

Date 09-03-2011 18:05 Edited 09-03-2011 23:05

When a human element is involved honesty, ethics, and the desire to do what is right is always in question. The integrity of the individual inspector is the only thing that can make the system work or the lack of integrity can allow the system to break down and fail the employer, customer, and society.

You cannot mandate morality. Any individual bent on distorting the recommendations or requirements of the system will do so to benefit themselves. They do so with the full knowledge that what they are doing is not right, immoral, unethical, and unreasonable. Most moral people know what is right and what is wrong. Just because an action is not illegal doesn’t make it right or moral. The inspector, whether they are certified by AWS, ASNT, API, or an employer has a responsibility to the people that depend on them to be moral and honest in all their actions and activities. Once trust is breached because of unethical actions or activities by an inspector, whether they are work related or related to their personal life, their professional activities will always be called into question. It has been my experience that most inspectors that leave the profession do so because of breaches in ethics or honesty.

SNT-TC-1A is just what it says it is. It is a recommended practice for the qualification and certification of NDT personnel. It is a certification process controlled by the employer. It allows the employer to modify the qualification and certification process to suit their needs as well as those of the customer. It is an opportunity for the unscrupulous to take unreasonable advantage of the generally accepted good practices expected by industry.

A close look at AWS B5.2 will show that the basic concepts of SNT-TC-1A served as the model of how an employer based qualification and certification program for in-house visual welding inspectors can be organized. Likewise, AWS QC1 follows the basic concepts of SNT-TC-1A with regards to the idea that the inspector needs to possess a body of knowledge, i.e., knowledge of the technology of visual welding inspection, welding processes, welding symbols, NDT, etc. QC1 also requires the candidate to attest to having relevant work experience, they have to demonstrate their familiarity with applicable procedures and standards, i.e., welding code, and they have to demonstrate the ability to apply the technology to properly evaluate samples containing “defects”, all of which are basic elements defined by SNT-TC-1A.

The primary difference between QC1 and SNT-TC-1A is that QC1 is a central certification scheme offered by AWS rather than employer based certification. An alternative to employer based certification is offered by ASNT. ASNT’s CP-189 permits central certification and ACCP defines the requirements of ASNT's central certifications scheme which is modeled after the basic concepts delineated by SNT-TC-1A.

As for the three tiers of certification contained in SNT-TC-1A or CP-189, they are not so different than those found in AWS QC1, i.e., CAWI, CWI, SCWI. In many respects the three levels of responsibilities for QC1’s CAWI, CWI, and SCWI closely parallel the responsibilities assigned to ASNT’s Level I, Level II, and Level III.

Whether working with ASNT, API, or AWS, the customer has the right to obligate the contractor to employ visual welding inspectors that are certified by the employer by in-house certification program or through a central certification program offered by a recognized organization such as AWS, ASNT, API, etc. The customer needs to understand the implications of each; in-house certification or central certification. The idea that employer based certification can be tainted by undue employer influences is not new or recent. It is the driving force behind the increased reliance on central certification schemes.

The idea that the Level III should be responsible for developing procedures and approving procedures is closely paralleled by AWS B5.1 Table 1 which delineates the job responsibilities each level of welding inspector level is expected to fulfill. Table 1 of B5.1 clearly indicates that the Senior Welding Inspector should be able to develop procedures, including welding inspection procedures and welding procedures, whereas the WI or AWI (remember, these individuals are not yet certified by AWS) are not expected to develop procedures. One main difference is that many standards that reference ASNT require the Level III to approve NDT procedures. I cannot help but wonder if customers, as they become more knowledgeable of AWS B5.1 and QC1, will at some point in time require welding procedure specifications to be reviewed and approved by a SCWI.

ASNT required involvement of a Level III in the administration of NDT operations is intended to ensure there is an individual available with the proper training and experience to provide the expertise needed to provide training, develop procedures, and to administer in-house certification of Level I, Level II, and where permitted; Level III NDT personnel. Quite frankly, that is something I often find lacking in large organizations that utilize a QA manager, with little to no NDT back ground or expertise, to wrangle their staff of inspectors.

I am currently working to rectify a worst case scenario where a client did away with their entire QC department. I was summoned because a customer involved in military work audited their facility and was dismayed at the situation. The situation went from good to bad when management decided to implement a number of changes in the name of “Lean Manufacturing”. They made several blunders. They didn’t bother to call in a Level III to council them on changes that affected their qualification and certification program. They ignored their existing approved written practice. They didn’t revise the written practice to reflect the changes made. Finally, they didn’t inform the customer of the changes made. That is a serious breach in their contract with one of their main military customers. It is a situation that could have been avoided had they consulted with someone that is versed in handling NDT qualification/certification programs. Sorry fellas, few CWIs or even SCWIs are qualified for the task.

Other than the fact that ASNT’s qualification program isn’t governed by AWS, I fail to understand the rancor or venom directed toward ASNT primary qualification and certification documents. ASNT’s SNT-TC-1A provides guidance for in-house certification and qualification schemes in a manner that is paralleled by AWS’s B5.2. The other is a scheme for central certification of Level II and Level III NDT personnel, i.e., ASNT’s ACCP that is paralleled by QC1. ASNT’s CP-189 requires central certification of the Level III who then administers the in-house NDT qualification/certification program. The customer has the opportunity to specify the certification scheme that best suits their needs.

Any qualification/certification program is only as strong that those individuals that participate. AWS B5.2 can be modified by the contractor to suit their needs in a fashion similar to ASNT’s SNT-TC-1A. The unethical employer can warp the recommendations of AWS 5.2 or ASNT's SNT-TC-1A to suit their needs.

The question of ethical behavior and conduct has been considered by both AWS and ASNT. AWS QC1 has a code of ethics to which all CAWIs, CWIs, and SCWIs have agreed to abide by as a condition of certification. ASNT's ACCP has a similar code of ethics that is a condition of certification by ASNT. In my opinion those codes of ethics are not exclusive to those projects that require AWS or ASNT certification. I believe the code of ethics apply to all inspections performed by AWS/ASNT certified individuals. It is a perception, my perception of what is ethical, moral, and right. It is in line with my perception that a religious person practices their religion all the time not just when they are in their house of worship. Past posts in this forum indicates that not everyone agrees with my point of view on the former subject.

I hope this doesn’t appear to be a sermon, it just my opinion on how inspectors have a responsibility and a duty to their employer, their customer, and to the general public to do what is right and in the best interest of all parties. When we, as certified inspectors, take liberties, it reflects poorly on our judgment and our abilities to act in an unbiased manner in our professional capacities.

The bottom line is that we have to live with our actions whether they are legal, moral, or not. The decisions we make today determine the life we lead tomorrow.
Best regards – Al

By 99205

Date 09-03-2011 22:03

Very good post, thanks.

By CWI555

Date 09-04-2011 12:46

Excellent post Al. Agreed in full.

By waccobird (****)

Date 09-04-2011 13:01

Al

Thank You

Excellent read and words to keep in mind.

And why I am here Congratulations to you and your series on WPS's in the Inspection Trends that received the Silver Azbee award from the American Society of Business Publications Editors.

They should of given the gold.

Marshall

By 803056

Date 09-04-2011 16:51 Edited 09-06-2011 18:03

Thanks Marshall.

I was hoping the prize would include a token for a free hot tea at FabTech or a piece of paper to hang on the wall, but no such luck. Even with the award, it will cost me a $1.50 for a cup of tea. :wink:

I cut the notice out of the Welding Journal, enlarged it and hung it in my office with a thumb tack. :smile:

Best regards - Al

By welderbrent (*****)

Date 09-06-2011 02:58

I agree with Marshall. Those were excellent and well written articles and you deserve the notice you got from others who evaluate those things.

Too bad it didn't come with more formal awards.

I'd buy you a tea myself but not sure at this point if I am going to make it back to Chicago. Next year it will be right here at my back door, Las Vegas. But I would really like to go to the WPS presentation. I need to add more knowledge to that area.

Congrats on the 'verbal' award.

Have a Great Day, Brent

By 803056

Date 09-06-2011 18:02

Hey Brent, I can wait until Las Vegas! That's no problem!

This was the first time I was awarded anything other than a grade of "D" for something I've written. I'm not sure if my English teacher would die again from laughing or simply turn over in his grave. The poor fellow, one of my favorite high school teachers, fell backwards off a three foot step ladder while changing a light bulb. He hit his head on the concrete floor and that was the end of it for him. He had only retired a few months before the fatal accident.

Best regards - Al :wink:

By Shane Feder (****)

Date 09-13-2011 11:49 Edited 09-13-2011 12:00

Hello Al,
Greetings from Australia.
As you know I have a huge respect for your knowledge and I would like your personal opinion on my situation.
I will quantify my query by stating that I have been in the game a long time and I am always suspicious of any supposed qualifications by the employer and not an independant third party.
SNT-TC-1A is recognised worldwide but it is so open to abuse I find it hard to take seriously (I have been exposed to so many unscrupulous contractors/ employers, especially in Australia)
My situation is thus, I am reviewing NDT qualifications from a major American EPCM which has workshops all over the world.
The original qualifications and the re-certifications (based on satisfactory performance) were signed off by the Welding / QA Manager based in a particular Asian country when the companies Level III is based in the USA.
Obviously the Practical Examination must have been in accordance with a "Written Practice" but who checked the technician while he was performing the practical examination - doesn't the Level III have to do that ?
Any thoughts greatly appreciated,
Regards,
Shane

Edit: I do not have access to SNT-TC-1A so I am flying blind on requirements.

By 803056

Date 09-14-2011 03:52

Hello Shane;

You hit the nail squarely on the head. It is just as Joe pointed out; SNT-TC-1A provides the employer the opportunity to do anything they want with a stroke of the pen. The SNT-TC-1A is a recommended practice, nothing more, noting less. The employer can follow the recommendations to the letter or write anything they want into their written practice.

Anyone that accepts at face value that a contractor abides by the recommendations provided by SNT-TC-1A is probably a part owner of the Brooklyn Bridge and most likely received title to the bridge upon handing a crisp $20.00 bill to a street bum.

The only nail the buyer has to hang his hat on is the contractor's written practice. The written practice is a required document the contractor develops that describes and defines how their NDT technicians are qualified and certified. The written practice is supposed to defines how certification is maintained, how often requalification/recertification is required, and how the certification is revoked, suspended, or reinstated. The written practice should also define who in the organization is responsible for administering the program and a description of the responsibilities of the Level I, Level II, and Level III. It should define who develops the examinations, who can administer the examinations, who scores the examinations, and who represents the contractor and signs NDT technician's certifications. That how is supposed to be done, but even when the written practice is available, who is to say the contractor actually does what is described in the written practice?

The suggestion was made that CP-189 is a better document to reference when purchasing NDT services. Whether the contractor is performing NDT in-house or a contractor is retained to provide NDT services, CP-189 is a standard that defines the minimum requirements that must be met by the contractor providing NDT services. That is a major difference, i.e., a recommended practice (SNT-TC-1A) versus a standard (CP-189). CP-189 requires the Level III responsible for the administration of the NDT program to be tested and certified through ASNT. The ensures the purchaser that the Level III has passed the requisite examinations developed by and administered by a third party that has international standing.

One of the most blatant abuses of SNT-TC-1A I have encountered happened a few years ago. A state department of transportation subcontracted all their NDT to a third party. One of the contract requirements stated that the third party had to have a Level II witness all NDT performed by the fabricator. The DOT involved contacted me and complained that the quality of the NDT performed by the fabricators was clearly substandard and the third party that witnessed the NDT clearly was not qualified to witness the NDT because the errors being made were so obvious. They asked me, “What should we do to address the problem?"

The first question I asked was, "Have you reviewed the third party's written practice?"

"What is a written practice?" was the response.

To make a long story short, it took the DOT over a year to get a copy of the third party's written practice. I interpreted the long delay and stalling tactics as a strong indication the third party never had a written practice. Moving the story line along, once the written practice was received it included a subcategory of Level II as the Level II NDT witness. A synopsis of the Level II NDT witness’ qualifications was:

Education: High school graduate or the equivalent
Training: None required
Experience: None required
Examinations: None required
Test scores required: Not applicable

That told the story of why the DOT was getting substandard results. Had they insisted on obtaining a copy of the written practice, a listing of the qualifications of the personnel used, and copies of any NDT procedures to be used as part of the bid submittals, they would have known what the third party was planning on providing. They would have easily discovered the test witnesses did not have the qualifications they expected and they would have had an opportunity to toss the third party's bid aside in favor of a better qualified vendor.

In response to your question, I cannot respond until I review the contractor's written practice. The answers you are looking for should be in that document, i.e., who can the Level III delegate the responsibility for testing and certifying to. If the written practice contains no provisions that allow the corporate Level III to delegate those responsibilities to "on-site" personnel, then what you say is being done would not be permissible. However, if the written practice states that the responsibility for developing the examinations, administering and grading the examinations, and certification of the NDT personnel can be delegated to the janitor, then that is what is acceptable to the company providing NDT.

The customer usually has the right to review and accept or reject the written practice provided by the contractor providing NDT services. Whether the customer chooses to exercise that right or that responsibility is a different matter.

Best regards – Al

By js55

Date 09-14-2011 12:12

If I may again take upon myself the roll of contrarian to a slight degree. Emphasis on slight.
While I am in complete sympathy with the jist of the arguments, and I think Al indicated this earlier, you cannot impose scruples by code or standard. If TC-1A was the Encyclopedia Britannica and mandatory under penalty of death by scrotum suspension we would still be having these same threads. Well, maybe a few less.
Those of us charged with the responsibility of enforcing rules have a tendency to think more rules will make it better, much like congress thinks more government will make it better.
The problem is not always in the rules, or lack thereof.

By Shane Feder (****)

Date 09-14-2011 22:47

Hi guys,
Looks like my concerns may be justified.
Review still underway but have found two technicians who achieved 78% and 79% composite grade on initial certification and yet were signed off as a pass by the Welding / QA manager.
As far as I can see an 80% minimum composite grade is required.
As the work was completed two years ago I hope it is not the opening of a can of worms.
Regards,
Shane

By 803056

Date 09-15-2011 02:19

It is not the purpose of a code or standard to turn an unscrupulous contractor into one that has a sense of morality. The purpose of the code or standard is to provide clearly defined requirements that must be met by the contractor hired to perform the work. The purchaser has a sound basis of seeking recourse for the breach when it is discovered that the contractor does not comply with the requirements of the code or standard.

The purchaser has little recourse if the contractor elects to ignore the recommendations of a recommended practice. After all, the recommended practice is simply a guideline that contains recommendations, but no requirements. There is no breach of contract if the contractor elects to take exception to the recommendations provided by the recommended practice.

With appropriate wordsmithing, the recommendations of a recommended practice can be transformed into minimum requirements, but that still leaves a lot of wiggle room for the unscrupulous contractor and can leave the purchaser wanting.

Ah, yes Shane, it sounds like you are opening a can of worms, but isn’t that why they hire us?

Best regards – Al

By js55

Date 09-15-2011 12:17

Al,
Once again I think our approaches are very close. Not even sure we are disagreeing. Just approaching it from two standpoints. That the purchaser has little recourse if the contractor elects to ignore the recommendations is true after the fact under certain very avoidable conditions. In nukes TC-1A is mandatory and therefore violation is a code violation, a program violation, AND a contractual violation. May even be a Part 21 issue. So there is definate recourse. In boiler code a written practice is evaluated by the teams and therefore a scrutinized written practice will become at the very least a program and contractual violation, and so once again, there is recourse. Outside of these code mandates, pressure piping for example (or the D Codes), you still have a written practice that becomes a contractual obligation. If the written practice is not up to snuff (or if there isn't one AT ALL) for any given customer then shame on the customer for lack of due diligence. If the procurement documents are written properly and due diligence by the customer is practiced in review of the written practice then the voluntary nature of TC-1A is irrelevent. When you sign on the dotted line it is no longer voluntary.

It is popular to bash TC-1A, and in certain points I suppose its warranted (I have my own beefs), but on the other hand if the customer is doing their job it doesn't matter, they WILL have recourse.

When I evaluate subcontract NDE I may not know my azz from my earlobe when it comes to achieving an acceptable radiograph or developing a DAC curve, but I can certainly evaluate a programs compliance with TC-1A. Its not that esoteric. And it is due diligence in that if there is a problem with my sub it is not my sub that my customer is going after. Its me. Then, if I have performed my due diligence I will have down stream recourse.

In the end if the customer does not have recourse it is the customers fault. He has the ability to dictate recourse if he has the inclination.

By 803056

Date 09-16-2011 02:34

No argument from my corner.

It is a case of writing the project specifications using the proper terminology, i.e., make the recommendations of SNT-TC-1A mandatory requirements. However, it is cleaner and easier to invoke ASNT CP-189. Poof, all the BS is gone and there is no argument regarding options available to the contractor.

You can write a contract stating that the contractor must use a 16 oz. framing hammer modified by adding a 11-pounds weight to the hammer head and a 24-inch extension added to the handle. However, a better option would be to simply state that the contractor must use a 12-pound sledge hammer. I prefer the latter. It is clear, unambiguous, and leaves little doubt what tool is required to do the job.

Why invoke a recommended practice that is known to be weak when a better standard is available? The only people I can imagine would advocate staying with SNT-TC-1A are those that want to exploit known weaknesses of SNT-TC-1A to their advantage. Wait a minute, itsn't that called good business management? Silly me! :twisted:

Best regards – Al

By Mikeqc1 (****)

Date 09-03-2011 12:58

Right the customer need not accept YOUR written practice.
Key word for me is YOUR written practice.
what if you showed a written practice with some other companies name all over it, approved by some lvl III that you have no documention for (not the one Appointed by you).