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Up Topic Welding Industry / Inspection & Qualification / AWS D1.5: Supervision by a ASNT Level III
- - By clyne Date 03-27-2007 18:18
According to AWS D1.5 Sect. 12.16.1.2, qualified NDT personnel must be "supervsed" by a ASNT level III. The commentary states what "under supervision" means. I am currently providing a QA inspection of a fracture criticle bridge members. The shop insists that the code commentary is not enforceable, and they will interperate what supervision will mean. I need to verify this "supervision." Any ideas?
Parent - - By jwright650 (*****) Date 03-27-2007 18:44
I'm going to step out on a limb here and agree with the fabricator in some respect. The NDT inspectors Level I and or Level II need to work under a Level III or be under his "supervision"(which could mean off premises or a contract Level III), but I would interpet "direct supervision" to be within vocal or line of sight type of supervision. 

Anyone else agree with this interpetation?
Parent - By CWI555 (*****) Date 03-27-2007 19:35
I would agree with those interpretations.
Parent - - By HgTX (***) Date 03-27-2007 21:57
For other provisions requiring "supervision", I do like the "vocal or line of sight" interpretation; just having someone in a vertical line on the org chart shouldn't count.

That said, this provision seems very odd to me.  What your typical 3rd-party Level III does is not what I'd call "supervision".

Hg
Parent - - By clyne Date 03-28-2007 13:40
I was not speaking "typically", but specifically regarding AWS D1.5 section 12.16.1.2 - a clearly defined code requirement. Thanks for your response.
Parent - By HgTX (***) Date 03-28-2007 14:54
That's my point.  If it's so "clearly defined", you wouldn't be asking.  Considering typical Level III activities, the 12.16.1.2 requirement seems odd.  Unless "supervision" means something very, very vague and loose.  The distinction made above between "direct supervision" and "supervision" may be the key.

But look at 6.1.3.3.  That paragraph uses the word "supervision" without "direct", but yet they talk about daily monitoring of the supervisee's work.

Then there's C6.1.3.4:  "An ASNT NDT Level III individual has the skills and knowledge to establish techniques; to interpret codes, standards, and specifications; designate the particular technique to be used; and verify the accuracy of procedures. [...] The NDT Level III is responsible for conducting or directing the training and examining of NDT personnel in the methods for which the NDT Level III shall be qualified."

This doesn't include physical monitoring of Level II's work.

Furthermore:  "Inspection by a Level III shall not be recognized, as the Level III may not perform actual testing regularly enough to maintain the special skills required to set up or to conduct the tests..."

Also not consistent with having the Level III really "personally oversee and independently verify" the Level II's work.

To be honest, I haven't enforced this particular provision.  We haven't required a Level III to be lurking in the background whenever FC work is being done.

Hg
Parent - By hogan (****) Date 03-27-2007 22:10
john
i ran into a unique situation with the asnt requirement for working under a level III. ASNT-TC-1A is a recommended practice, and as such what you write in your qa manual can adhere to all or just the parts you like. this one shop in particular had no level III on staff and had no level III contracted, but this is what they had written in there qa manual. they were an AISC certified shop, but excluded this requirement from there manual
Parent - - By clyne Date 03-28-2007 13:45
Would you (or anyone else) agree that a letter from the Level III stating his agreeement to "supervise" would be sufficient to verify complance to the requirements of D1.5 sect. 12.16.1.2?
Parent - - By NDTIII (***) Date 03-28-2007 14:01
In my opinion it means there must be a Level III onsite.
Parent - By jwright650 (*****) Date 03-28-2007 16:23
I respectfully disagree, and here's why....If I were required to UT a joint at the jobsite and I am a Level II UT, I would have to wait for the Level III to get there and so he could supervise me inspecting the joint and then look over my paperwork.....sounds redundant to even have a Level II at all, he then has reduced me to a Level I that requires direct and complete supervision..........why not all of us just become a Level III UT and be done with it.
Parent - By chall (***) Date 03-28-2007 14:08
I must admit a healthy degree of ignorance about this topic.  Like the other answers, I would tend to go with what is "typical"; however, I was unaware of the commentary.  Now that I am aware, I may be inclined to take a harder line.

The best answer may be in the job specifications.  One of our field engineers posed this very question to me a year ago; except he was quoting the requirement to include direct, on the job, supervision by a Level III from the job specifications.  I was pretty shocked at the time.  Now I am becoming worn out by the number of things I have taken for granted that have been wrong over the years.

Charles
Parent - - By HgTX (***) Date 03-28-2007 14:58
A letter "agreeing to supervise" is as meaningless as the provision requiring "supervision".  Either you define supervision in terms acceptable to all parties that need to accept it, or you don't; the letter adds nothing.

Hg
Parent - - By ssbn727 (*****) Date 03-29-2007 09:20
Okay, now would be a good time to get an opinion from the folks @ ASNT about this because, it might help in clarifying the issue better.

Even though I doubt that doing so always ends up clarifying interpretations of words used in definitions or best practices... Unfortunately semantics can wreak havoc with the use of one word or another rather innocently!!!

I say: "When in Doubt, go to the source... If the source can't help then  start annoying them until they make a ruling so always maintain your persistance in seeking a definitive answer!!!"
I too am curious as to what is the absolutely correct answer here.

Respectfully,
Henry
Parent - - By dmilesdot (**) Date 03-30-2007 14:29
I dont think that ASNT would make a determination on what is written in an AWS code book.  It seems to me that AWS should comment on what they were thinking when they wrote their requirement.  The written practice of a company should spell out when a Level III must be physically present.  It should also state weather a Level III can perform level II inspections.  Most of the Level III's that I know perform inspections every day, its not a desk job for every person who holds an ASNT Level III.  Its actually the written practice that governs the activities of its employees.  Just my 2 cents.
Parent - - By jwright650 (*****) Date 03-30-2007 15:19
ASNT SNT-TC-1A:1996 does not say anything on this subject. Only reference I saw was under the Level III's description he should be able to test and evaluate Level I and Level II personnel. <--- said nothing about supervising
Parent - - By ssbn727 (*****) Date 03-30-2007 17:34
Well, then ask the D1.5 committee and find out what they meant by that...
That's what I meant to say in the first place... Thanks for the correction fellas!
I do'nt work on D1.5 stuff anymore so maybe JW or Joe Kane could find out what the D1.5 committee meant in the commentary and/or being that they work with this code quite often then, they would know.

Respectfully,
Henry
Parent - - By hogan (****) Date 03-30-2007 18:45
I've found that it's the dot's interpretation that will need to be adhered to. if it's to out of line I'll go to the engineer.
Parent - By 803056 (*****) Date 03-31-2007 18:50
He who holds the check has the power.

Al
Parent - - By Joseph P. Kane (****) Date 03-31-2007 23:20
Henry;

One thing for sure.  It is NEVER a good idea to ask ASNT for their opinion whether an ASNT Level III is needed!!!!!

I was hoping to stay out of this string for a few more days, but it has taken some strange turns and perhaps it is time for my two cents.  Remember, I am not a member of the D1.5 Committee and cannot give you an "Official" interpretation.  If you send in a series of questions to the D 1.5 Committee, for an "Official Interpretation", it may take two years to get a reply.

Everyone must remember that D1.5, while it a National Code, is just a guidline to most State DOTs.  Most States take several exceptions to it.  New York State DOT has the New York State Steel Construction Manual, and currently does not use the D 1.5.  The NYSSCM was the first "Bridge Code" and had the first "Fracture Critical" section. However, it is more than a Code, it is a "Construction Manual" that covers many aspects of bridge construction. (In my opinion, it is the best bridge fabrication document on the planet.)  Under the NYSSCM, the MT, PT UT & RT personnel have to be qualified to SNT-TC-1A.  The UT practitioner also has to pass a "hands on test" given by the NYSDOT in Albany.  This is the "GOLD STANDARD" of UT tests for structural inspection. 

Under D1.5, the NDT practitioners must be Qualified in accordance with ASNT SNT-TC-1A and the Level III "Supervisor" can be Qualified and Centrally Certified  (by ASNT), or Qualified in accordance with SNT-TC-1A.  The practitioner must be qualified differently, depending on whether the product is Non-FCM bridge fabrication (Section 6), or "Fracture Critical" (FCM) fabrication (Section 12).  The rules are stricter if you are doing Fracture Critical inspection.  T(here is an explanation in the Commentary section (C12.16.2.1).  The last sentence defines what is meant by Level III "Supervision".  In my opinion it was intentionally left this vague, to address the operational requirements of the various State DOTs.)

For normal fabrication (Non-FCM), the qualification requirement (Paragraph 6.1.3.4), has wording that says the Certification of Level I and Level II personnel shall be performed by a person Certified by ASNT or by "testing" under the provisions of  SNT-TC-1A.  The individual who performs the NDT must be qualified for NDT Level II or NDT Level I, working under the direct supervision of an individual qualified for NDT Level II.  There is no routine supervision requirement for the "performance" of NDT operations for Non-FCM fabrication.  NOTE! The Qualification and Certification operation is different from the "performance" operation requirements.

For "Fracture Critical" fabrication, NDT may only be performed by a person qualified to Level II or Level III in accordance with SNT-TC-1A, and MUST be "supervised" by a person who has a current ASNT Level III Certificate. (The Engineer may approve an equivalent alternate qualification, and most State DOTs use this exception for their third party inspectors.) 

Note; Not all Level III personnel are qualified to actually perform (practice) the NDT operations.  Thus, the wording that the Level II and Level III practitioners must be qualified to SNT-TC-1A, means that the Level III "practitioner" must also take the Level II examination.  The Level III "Supervisor" must be centrally certified by ASNT, unless the exception is made by the Engineer.

I know that "supervision" under the FCM provisions of D1.5 are not the same as the "supervision" requirements under the QC-1 for the CAWI.   The  Level III does not have to be in "visible and audible range" of the Level II at all times.  (This is explained in the commentary)

Besides all this, the company that performs FCM has to have an approved QA Manual, and if they fabricate FCM, an "Approved" FCM Manual.  Thus, the requirements vary from company to company, and depends on what their DOT clients will approve.  Most fabricators modify their QA Manuals and FCM Manuals to satisfy their DOT clients.

Joe Kane
Parent - - By HgTX (***) Date 04-02-2007 19:20
"Everyone must remember that D1.5, while it a National Code, is just a guidline to most State DOTs."

I have to disagree with this.  Taking a couple of exceptions to the code does not mean the whole thing is just a guideline--taking an exception to D1.5 in the state standard spec is a LEGAL modification to a LEGAL document.  As far as I know, New York State (ironically, the state whose bridge manual D1.5 is based on) is the ONLY state that does not specify D1.5 as part of their standard specifications for bridge construction.

I've heard this notion expressed before, that D1.5 is just a guideline, and this is simply not true.  It is an explicit part of just about every highway bridge contract in this country (except NYS of course).

That's not to say that, as for any other specification, it doesn't have its fuzzy parts, and parts that are open to interpretation, and areas in which enforcement is not as strong as in other areas.  Again, that doesn't make D1.5 any more "just a guideline" than any other piece of a contract or specification.

Hg
Parent - - By Joseph P. Kane (****) Date 04-04-2007 19:20
HgTX

You are right of course.  It is an AASHTO Standard.  What I really mean to imply is that any State can, and will, take exception to any part of it that it doesn't like.  I understand that many states take more than a "few" exceptions.  If you look at the AASHTO Manual, each state is entitled to print Blue Pages that modify the basic document.  So, I call the D1.5 and the AASHTO Manual a "Guideline".

I don't mean any offence by it.  I happen to like the D1.5, (Especially when copmpared to the "LOOSEY-GOOSEY" D1.1).  However, The NYSSCM is a better document.  It isn't as broad based in the welding Code area as D 1.5, because NYSDOT limits the material you can use.  I believe that there are fewer ambiguities in the NYSSCM, than in the D 1.5.  In general, NYSSCM is more restrictive than D 1.5.  I also have seen a few common fabrication details that are not covered by either the D 1.5 or the NYSSCM.

I understand from Mr. Paul Rimmer at NYSDOT, that the new NYSSCM will be more in line with the D 1.5.  It may be like a D1.5 with a book of exceptions, like the state Blue Pages is to the AASHTO Manual.
Parent - By HgTX (***) Date 04-05-2007 23:05
On a bit of a tangent now but...

How is NYS Bridge Manual more limited in the material allowed?  D1.5 allows only ASTM A 709.

Also, what states take lots and lots of exceptions to D1.5?  I haven't seen "blue pages" anywhere but NYS, not that I've seen a majority of state specs, but I've seen a fair number of them.

I still maintain that "guideline" is an utterly wrong word to use with regard to D1.5 except for NYS.  D1.5 may be a guideline for the new NYS manual.  But for most if not all the other states, it's not just that it's an AASHTO standard, it is an AASHTO standard SPECIFIED by those states in their standard specs.  Every single sentence not covered by a formal exception has the full force of the contract.  Otherwise it's like saying that because there are amendments to the U.S. Constitution, that document is only a guideline.  Being amendable does not make something any less legally binding; the fact that the formal amendments need to be made actually reinforces just how binding the document is.

Illustration by contrast:  the AASHTO Construction Specs ARE a guideline in most cases.  Last time I asked, I was told that about three states specify them outright (I don't know which).  The rest use them as a source of boilerplate to write their own state specs.  THAT is a guideline.   Guidelines are optional.  In something approaching 49 states, D1.5 is not. 

I take this seriously because it is a dangerous attitude for anyone to take that D1.5 is just a guideline.  If someone signs a contract (or subcontracts for a contractor that has signed a contract) that includes a statement like "all welding shall be done in accordance with D1.5", regardless of whether that statement is followed by "with the following exceptions", they better fill those requirements (as modified, if applicable), and not say they read on some website that D1.5 is just a guideline.

Hg
Parent - By CWI555 (*****) Date 04-05-2007 01:51
Joseph,

I think you've come closest to nailing it down. In my opinion, a level III does not have to be in line of site, however; They do have to either be contracted or otherwise available. I cannot think of an NDE program that doesn't require a level III at some point. I.E. A shop performing D1.5 NDE, the level II's have to have someone to go to when they need a determination for code interpretation. Most level II's can interpret specific procedures, and perform the work without a problem, but there is inevitably the odd argument between a supervisor or welder or someone else who thinks the Level II is not interpreting properly. At that point, the level III becomes necessary. I can understand why D1.5 requires Level III supervision on many levels, but I do not think it means standing there watching them, but rather supervision of a group of techs, or contracted as a level III to maintain a smaller organizations program and the occasional audit of the tech to meet QA requirements and interpretations when necessary.
One thing that is clear, a level III has to be in the loop at some point. What that point is, is open to interpretation.
Parent - - By jwright650 (*****) Date 04-02-2007 11:06
SSBN727,
Just for the record.....I'm not all that familiar with the inter-workings of D1.5 ;-), I have dabbled in it but not proficient as I would like to be. Here at work we deal primarily with D1.1. This type work is very humbling. Anytime I feel like I'm starting to figure it all out, I learn something new and blow that theory.

From all that I've read and encountered in the past, the words "supervise" or "supervision" need to be ironed out when that wording is in question. As you can see many interpetations can be made. Like Joe Kane stated, it may or maynot be required for the Level III to be hovering over the Level II personnel...sorta depends on the situation and what the job specs have penned down in them for requirements.
Parent - - By ssbn727 (*****) Date 04-02-2007 22:23
Gentlemen!

First of all, let me say that I've learned a whole bunch here in this thread with respect to AWS D1.5, and really appreciate eveyone's input!!! Let's keep this thread going!!!

Respectfully,
Henry
Parent - By dmilesdot (**) Date 04-04-2007 16:01
Joe, just to let you know, we are working on a rewrite to the SCM.  We are calling it Rev. III.
Parent - By QCCWI (***) Date 04-04-2007 19:11
http://www.aisc.org/Content/NavigationMenu/AISC_Certification/Become_an_AISC_Certified_Company/Application_Submittal/Fabricator_Certification/prog-AISC-AISCQC005-20060321.pdf

Not sure if this will help but the link above is to the AISC Major Bridge Checklist Audit Checklist. If you look under the Quality Control Part of the checklist it gives you AISC's interpretation.
Up Topic Welding Industry / Inspection & Qualification / AWS D1.5: Supervision by a ASNT Level III

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