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Up Topic Welding Industry / Inspection & Qualification / Welder continuity AWS D1.1
- - By gsi (**) Date 11-24-2008 15:44
4.1.3. Period of effectiveness....
When doing inspection I typically check to make sure welders are current. I recently ran into a issue with a contractor that did not have a continuity log but wanted to offer me a letter certifying that the requirement was meet. I was just wondering if this was acceptable per the code. 
Parent - By 3.2 Inspector (***) Date 11-24-2008 16:13
First of all.....I am not familiar with AWS D1.1 at all. So all you get is my opinion.

I think a letter staing the requirements has been met is a bit to "easy"
I guess the continuity log is to prove that the company QA/QC department is keeping track of thoose things.

I would also imagine this log should be available to the inspector as some kind of proof.

3.2
Parent - - By kipman (***) Date 11-24-2008 17:33
GSI,
Why not wait until the project has been completed, and in lieu of WPSs, welder qualification records, filler metal certifications, etc, accept a letter from the contractor stating that the job has been performed in accordance with D1.1?  No reasonable person would accept this as sufficient evidence that the contractor has adhered to the code, and for the same reason you should not accept a letter stating that they are maintaining their welders' certifications.
Bottom line is, if they don't have the documentation to prove it they really don't know it.
Mankenberg
Parent - - By swnorris (****) Date 11-24-2008 17:53
To my knowledge, D1.1 doesn't require a continuity log.  However an AISC quality certified facility is required to provide objective evidence that the period of effectiveness has not been exceeded.
So the contractor is offering a letter certifying that the requirement was met.  Anyone can offer a letter, just as anyone can make a bogus continuity log, just as anyone can make up a WPS on the fly.  It can and does happen.  Lack of proper documentation is definitely a concern.  It still boils down to what the welder is actually doing in terms of machine set up, technique, and welding within the acceptable parameters of D1.1.  If you find that you have issues, then there are bigger problems to address.    
Parent - - By gsi (**) Date 11-24-2008 19:06
I have some big concerns with this contractor. The more I look the more problems I find. They are back tracking now to produce a log. But thats just one minor issue @ this point
Parent - By Jim12 (**) Date 11-24-2008 19:18
There is a real simple fix to this whole dilema! Instead of AWS requiring welders who have been certified from acreddited testing facilities to keep certifications current by documentation, the following can be changed to require recertification regardless of qualifications or expand the national AWS certification and abolish the acredited test facility system. Like mentioned above if you ask for a log who's to say it would be legit?
Parent - By Joseph P. Kane (****) Date 11-24-2008 19:29
Dave

In most fabrication shops workers have to fill in daily time sheets showing what project they worked on or what phase of a job they worked on.  Many times the fabricators use these records to justify partial payments.   This is especially true in shops where government contracts are worked on.  A supervisors journal can also be used to reliably point out where a given welder was working on a given day.  If there is a QC inspector with a note book or daily report, that is another source of reliable information.

I do not think it is wrong to go back to some sort of daily record like this and create an Ex-Post -Facto welder continuity record.  If they can convince you that enough welding time can be proven through these records, I think you should try to accept them.
Parent - - By pipewelder_1999 (****) Date 11-24-2008 19:44 Edited 11-24-2008 19:46
Hey Kip,

I think the code is silent on how this is done unless I missed something in the code indicating the need for documentation.  It may be in inspector requirements somewhere.

The word "documentation" shows up in the code only a handful of time.

The period of effectiveness is listed as remaining in effect
indefinitely unless (1) the welder is not engaged in a
given process of welding for which the welder or welding
operator is qualified for a period exceeding six months or
unless (2) there is some specific reason to question a
welder's or welding operator's ability

the welder has not welded with the process in that 6 month time frame. It is my opinion that based on the way the code is written, the burden of proof lies with one who doubts the person is qualified and not with the company/welder.

Though a continuity log would be handy for us documentation hungry inspectors to review as we sit in the qc office , it is not required by D1.1. I feel that indicating the continuity log as something required by the code is incorrect. In addition to prohibit the contractor from providing a letter certifying they are current is outside the scope of D1.1.  If the quality/ability of the welders is in question then use #2 from above. That same contractors signature signed the original cert (in most cases).

I think contract requirements, industry practice, code requirements, and good quality practices are all things that should be looked at PRIOR to someone being awarded a contract. If not "BUYER BEWARE".

The code is not a quality system.
Parent - - By kipman (***) Date 11-26-2008 06:12
Hi Gerald,
You are correct that the code does not specify how to document this, and in fact it does not specify the necessary means to document any of the many code requirements.  Of course, the fact that the code does not require a continuity log (or does not otherwise specify how the contractor must document adherence to this provision) does not mean that the contractor is free to not adhere to this provision.

I agree that the code is not a quality system, however, there are enough detailed requirements in the code such that a company that does not have a functional quality system would likely have a difficult time adhering to the code.  If you can't even trust a contractor to be able to document something as simple as ensuring his welders have used each process they are qualified for in the last 6 months, how can you trust them to follow the more difficult code requirements?

I have performed dozens and dozens of AWS D1.1 audits of fabricators/contractors in my career - from mom & pop shops to one that had 8000 structural welders.  One of the first things I ask to see is how they maintain their welder qualifications, i.e. the six month thing.  It has never failed - if they have problems with that provision there are much larger problems with their quality system also.  I do not think it is too much to ask a contractor to prove that they can adhere to the code.
Regards,
Mankenberg
Parent - - By pipewelder_1999 (****) Date 11-26-2008 14:15
NOTE TO ALL : My response on the subject is based upon the assumption that NO contract stipulations other that D1.1 are required. I fully understand that various other company requirements, codes and standards may more clearly define this subject. Each project should be evaluated on its own and the conditions compared tio the documented" requirements.

I agree that there is no allowance for the contractor to not assure that the welder has welded within a process in a 6 month period. I didn't think that is what I implied.

If you cannot trust a contractor to verify the welders have been striking an arc every 6 mos, then the welder qualification paper that the original qualification is written on is of NO value. The method of verifying that the welder has welded within that 6 month window is left completely open. Continued employment in a shop in which a welder welds on a daily basis is sufficient for a contractor to meet the requiremnts of paragraph 4.1.3.1.

I too have perfromed quite a few audits. In most cases the project specifications were clear on many of the requirements for the contractors quality systems. In most cases, any customer of any size would conduct a pre award evaluation of a fabricator in which various aspects of the contractors system was reviewed. This would eliminate any of the areas that may not be easy to interpret using the code only.

I have answered and reviewed quite a few "surveys" in which this subject is explicitly addressed. In cases in which I was conducting a survey prior to award of a contract, I would have questioned how this was handled. If the fabricator indicated that based on continued employement, all welders have welded with a process within the past 6 mos, I woiuld have ABSOLUTELY no grounds to not accept that unless somewhere in the project requirements some sort of supporting documentation was required.

If you cant trust a "CUSTOMER" to clearly define any requirements outside the scope of the code, how can you trust them to not exceed those requirements and try to indicate that you as the supplier are not compying with the contract or code.

Though a contractor should be able to work within the quality requirements of the code, the lack of a document that is not required by the code does not indicate a problem with their quality. It may very well indicate a need for a "quality system" however that is a different subject.

Here is an example situation.

You are an inspector hired by company A to perform final inspections on product fabricated in accordance with AWS D1.1. Your contract with company A says you are to inspect final welding, verify qualification of welders, and review WPS's for suitability for the work being performed.

I am fabricator B. Company A sent me a contract saying "Fabricate all widgets in accordance with AWS D1.1".

Upon entering my shop you say you would 1st like to review welder qualification records. After reviewing them you indicate you would like to see the "continuity log". A term I have NEVER heard of. I ask what it does. You show me paragraph 4.1.3.1 . I sa "Ohhh !, All of our welders weld every day, as long as they are employed, they meet that requirement."

Where do the widgets stand ?

In the other scenario I respond with , "Oh I didn't know the code said that but All of our welders weld every day, as long as they are employed, they meet that requirement"

Does my lack of knowledge about a code requirement nullify the quality of the products ? If it does, does the lack of knowledge of a code requirement by an inspector instantly nullify all of the inspections that person has performed ?

Because something is not documented, and that something is not required by the code to be documented, is not in my opinion a sound basis to reject something. I would note it, send it to the company I am inspecting for and hopefully if that is an issue, in all future purchasing documents they would clearly identify any requirement for extra documentation by direct statement in some project related document.

Again I do not in my previous post indicate that the contractor is " is free to not adhere to this provision". I think there are differing opinions on what the provision is.

Again I am by no means an expert on reading the codes and have never attended a code committee meeting so the experts on this subject may have a different understanding of "THE INTENT" of this statement. I can only go by what it says or does not say.

Thanks of the comments Kip,

Gerald Austin
Iuka, Ms
Parent - - By hogan (****) Date 11-26-2008 15:13
pipewelder_1999,
One issue I would have with your scenario is when a shop has several processes that they have welders qualified in. Just showing up to work will not equal using all processes you are qualified in.
Parent - By pipewelder_1999 (****) Date 11-26-2008 15:20
Thats true however depending on what type of work t ghe shop does, it could. All tacks and roots with GTAW or SMAW, all Fillet welds done with FCAW, all tubular products done with FCAW. If all welders weld with each process as a normal part of their day, then they are doing what the code said. Even if they are welding every 5 mos 29 days (28 in Feb) :)

All welders build similar products and tack, root and fill all welds.

Again, it depends upon the situation but regardless it does not change the requirements in the code. A written quality system could address this in any manner and I suggest everyone have one.
Parent - - By Joseph P. Kane (****) Date 11-26-2008 12:57
Pipewelder

The burden of proof always lies with the contractor/ welder.
Parent - By pipewelder_1999 (****) Date 11-26-2008 14:25
Thats a fair opinion.

I just don't see where any written document is even required. If a fabricator were to oblige the inspectors "need" for documentation by creating a letter, then the fabricator has provided more than called for by the code.

I would just hate to see a bunch of new inspectors go out and get hung up requireing a piece of paper thats not required by the code just because we all indicted it was required by the code.

I strongly suggest to any fabricator that they document their practices and follow that documentation. I strongly suggest to companies that are purchasing products that they clearly define what is required OR pre-approve a fabricators quality system.

Thanks for the comment Joseph. Have a good one.

Gerald
Parent - - By pipewelder_1999 (****) Date 11-24-2008 19:31
There is no requirement in D1.1 as to how to document continuity for a welder in D1.1.

If the letter is done after the fact then that would be suspicious however the code is unclear on whether this would be acceptable.

I could provide a letter that said something to the affect of "based upon contnious employment records from original date of certification , I hearby certify that Joeblow the Ragman is currently qualified to weld in accordance with AWS D1.1 using the blah b;lah process as indicated by original record of performance qualification".

There is nothinng in D1.1 that prohibits that. There is no reference to requiring any kind of "continuity log". A fabricator could place a series of dated signatures on the back of a form or any other method that they decide is acceptable.

HOWEVER

D1.1 is not a quality system. If a company is purchasing welded fabrications without doing anything more than requireing it "be done in accordance with D1.1" then they are somewhat limited in any recourse should they not be happy with the quality system (or lack thereof) of the chosen fabricator.

Quality Control is based on much more than a code book. Documentation is only that. Paper. If you go into a shop and everybody is busy welding daily and they only use one or two processes is there any practical reason to suspect that the welders have not used the process within the last 6 mos? Why even burden a shop with the extra paperwork when based upon a guy showing up for work at least once every 6 mos is evidence that he worked using the process. Of course multicraft type setups may be different but still it can go overboard.

Its my unofficial opinion that D1.1 is silent on this. Other contract documents of fabricators quality system may be another place to go.
Parent - - By welderbrent (*****) Date 11-24-2008 23:53
I would have to agree with Pipewelder.  And I have used letters of documentation on myself as shop owner, welder to verify my continual usage of a process.  It has been accepted by Special Inspectors, City Inspectors, and General Contractors on some fair sized jobs.

It is easier to take a test every so often.  Also, if you do enough jobs that do require special inspection, get the inspector to date and sign the back of original cert or a documentation log of what ever style you come up with.  Especially if there are RT, UT, or other such testing besides visual inspections. I try to get a copy of all reports.

Currently, I fill out a self made log on myself and my son every six months and include info on ANY inspection done, the process used and the inspectors name and affiliation.  Puts some weight behind just my word as to usage. 

Add them all together and you have a pretty complete verification system.  But how far does a company really have to go to meet 'code'?  I think pipewelder expressed it pretty well.  The code does not say 'Thou must do it this way'.  So unless I or my welders, or any I am inspecting, show obvious signs of abuse of the code with wholly inadequate welds and craftsmanship I would expect that my word should be good enough.  Because really, my word is all it is even with some kind of log.

Well enough of my two tin pennies worth.

Have a Great Day, Brent
Parent - - By gsi (**) Date 11-25-2008 13:02
I take a lot of pride in my job and I admitted that the paper that is required on some projects to support the obvious is just silly @ times.  I'm currently working with this fabricator to resolve each issue as it comes up..  I also believe that the reward for a job well done is the opportunity to do it again..
Parent - - By tazmannusa (**) Date 11-25-2008 22:59
Question on this. Would it be your call if somthing does not look right, just have them retest for the procedures they are doing?
Tom
Parent - - By Joey (***) Date 11-26-2008 04:23
In addition to Tom's good suggestion.

API RECOMMENDED PRACTICE 577
States " Welder performance qualification expires if the welding
process is not used during a six-month period. The welder's
qualification can be revoked if there is a reason to question
their ability to make welds. A welders log or continuity
report can be used to verify that a welder's qualifications are
current".

So how would you define continuity report?  Would it be acceptable to receive testimonials from previous
or current employer stating that he/she been involved in such project using such welding process.

If API / AWS accept endorsement of employers in the reference forms whenever you want to renew your certification,
to prove that you spent the required minimum work experience, then why can't apply the same method to the welders?
Well, I guess....the inspector thought they are more bless than the welders.

Best Regards
Joey
Parent - - By gsi (**) Date 11-26-2008 14:07
Joey,
I would define a continuity report as a paper trail starting from the date of qualification. I have accepted various forms of this documentation. I know how I handle it in our shop but how other manufactures maintain this documentation is up to them. I have seen lots of manufactures using different forms of maintaining this information. Some of which are very creative and simple.

Your second question.  "If API / AWS accept endorsement of employers in the reference forms whenever you want to renew your certification, to prove that you spent the required minimum work experience, then why can't apply the same method to the welders?"
It's my understanding that AWS D1.1 06  Previous Performance Qualification 4.1.2.1 allows this sort of thing.

Thanks
Dave
Parent - By Joey (***) Date 11-27-2008 10:52
gsi

I do understand the continuity report but I believe this can't be religiously followed. In my place, there are many freelance welders and we can't produce continuity report for them. Some are hired to work for a short period of time or based on project duration.

We even hired imported welders who are expert in welding of those exotic materials. What we get are certificates, resume & testimonials, but no continuity report.

Best Regards
Joey
Parent - - By gsi (**) Date 11-26-2008 14:04
Tom,
Thanks for the Question. I have done this when needed
Parent - - By tazmannusa (**) Date 11-26-2008 17:08
OK thanks
I have allways figured that would be the simple solution. Myself I am on the otherside of the fence here, My certs have no stamp or signatures for years. County requied me to cert. for welding agg barns but no CWI , building inspector is the only one that comes out. It would be nice if they did things the way they are supposed to be done, not half arse.
Tom
Parent - - By pipewelder_1999 (****) Date 11-26-2008 17:57
No signature or reference to when where who tested you ?

There is no need for a CWI or any kind of stamping however if the building code does not require it then maybe thats why the building inspector has accepted it. If D1.1 has been referred to by the building codes then this would be a bit odd.
Parent - - By welderbrent (*****) Date 11-26-2008 19:27
Tom and Pipewelder,

Not necessarily 'odd'.  If your building inspectors are being lenient on "barns" and/or don't know much about welding and codes then they could just be interested in making sure it looks reasonably safe and secure and somewhat close to the prints.  But for what you are doing he/she is possibly not that concerned with a log of usage.

In my county we had no building inspections up until a couple of years ago.  Not even on homes.  They sent someone from planning to check the foundation and sewer.  That's it.  The rest was up to the bank, some of which hired private inspections services to make sure their investment was properly built.  So if you were outside the city limits you could get away with alot if you were so inclined.  But when you go to sell, a new bank would probably request an inspection and if codes are not met you will have to update before they will finance. 

As that is still in a changing process, most of the new county inspectors defer to the standards of our nearest major city (40,000 pop).  That city does have an inspector who is also a CWI, so he sets a fairly high standard for all concerned to adhere to and always falls back on D1.1.  But your inspector possibly does not even know what D1.1 is even if it is called out as the basis for welding procedures by the designers of the barns.

All that aside, to get to your comment based upon the content of this thread, if you were to ask the building inspector to acknowledge your usage on their projects of the process to which you are certified, or get a copy of the inspection report and ask them to name the welder and process used, it would help you maintain a record beyond your word. Especially could be helpful if you are self employed and expect to do larger jobs at times where an inspector might try to push for better documentation.  In todays world it is all about the paper trail and first impressions.  Not, as has been stated, about code adherence, just how you look to the customer and the inspector.  Can save a lot of what this whole thread has been about- hashing out the "intent" of the code and how to comply.

Bottom line from my point of view- You can't have too much paper no matter what the code says.  Only takes a minute to get a signature.

My two tin pennies worth.  Have a Great Day and a Very Good Thanksgiving.   Brent
Parent - - By pipewelder_1999 (****) Date 11-26-2008 19:42
That paper keeps us all working ! Its all mainly about everyone trying to comply as opposed to doing a good job. Or being efficient.

We could all just go crazy writing up papers for barns. Hire document control specialists just to follow us around just to make sure we are all covered in case we "get sued".

If a building inspector is left to his own judgement as to what is acceptable and what is not, I would think that as "ODD" no matter how you slice it.

Should we request the calibration papers for the lug wrench when we have the tires rotated ? It would provide a nice "paper trail" for those interested in protecting themselves from a possible wheel falling off.

Maybe the welders should request from the companies they work for a certificate of compliance for all of the welds they make having been inspected in accordance with the code and that way if something breaks, it wont go on the welders "permanent record".

What is practical, adds value to, and promotes saftey of is sometimes not addressed in the code. Good practices when required should be addressed as just that . Good practices. Not requirements of the code.

The original context of the question was in relationship to the requirements of D1.1 There has been no "intent of the code" stated yet. I just know what it says (or doesn't say) but may very well not know what the writers meant.
Parent - By welderbrent (*****) Date 11-26-2008 21:47 Edited 11-26-2008 22:00
Pipewelder,  Not sure but I think we're largely in agreement and just saying a few things differently. While I did say that you can't have too much paper, I do believe the record keeping can get vastly overdone.  In Tom's case I was just trying to state that if he were to get the building inspector to verify his usage of the process it would make a good record. Depending upon his local work situation, that could be useful.  Only needs to be done every few months, not every job. Maybe I misunderstood him and his comments and question.

I, personally, am a big advocate of paper.  But I also think we get to the point where our file cabinets aren't large enough, no one cares, it gets too expensive to do and keep up, and is way beyond common sense let alone any code.

You made a couple of very worthy statements: Being efficient. Good practices. Promotes safety.

And you are right, we don't need to go crazy. 

In my own experience, I have found most inspectors do go by their own judgment.  I have had to challenge several and ask "Could you show me that in the code, please?  I don't understand."  Usually in regard to International Building Code but occassionally D1.1 as well.  Often they are going by amendments to the code that were used in different jurisdictions (IBC-which cities modify to their own interests).  That is why they TRY to teach us at the D1.1 seminar, "Don't memorize. Look it up and go by the book for the code required."  From the perspective you are coming from, I see the "ODD" factor.

Anyway, I hope I have not muddied the waters.  Hope Tom has gained the info he wanted. 

Have a Great Day, Brent
Parent - By tazmannusa (**) Date 11-27-2008 00:29
pipewelder
Yes I have the original from about 6 or 7 years ago from a local CWI.
The way are county does things is a bit odd to say the least. Originaly the buildings and such were considerd agg exempt no engineering, permits or inspections then around year 2000 they got in trouble with EPA and others over the dairies so then they decided to go by the rules just like everyone else. I get the certs I need then they decide we dont need a welding inspection by a CWI. Made no sense to me but what do I know.
I think my best bet is to go retest and get updated certs rather than wait till the red flag then have to do it.
Tom
Parent - - By pipewelder_1999 (****) Date 11-26-2008 14:31
D1.1 does make provisions for questioning the welders ability and retesting that welder. In my opinion addressing the qualty of weldes and welders abilities is more productive than reviewing a piece of paper that is not required by D1.1.
Parent - - By Jim12 (**) Date 11-26-2008 21:54
I see alot of information here some I agree with and some I don't! I currently work at a mine and was just told by management that they were going to start testing welders for upgrades! This in My opinion is the wrong reason to test. Testing should be done when ever a employee is hired to see if that employee is capable of doing the process or processes the company is utilizing! Further the company is lame in theyre utilization of inspectors for QC of completed or work that is being currently carried out as they donot always perform work to manufacturers requirements since no codes are used to govern the work. I also spoke with a friend of mine who works in Florida assembling asphalt bulk plants, I asked him are the welders tested? He said no that even when he hired on they never challenged His abilities! The point I'm driving is from My experiences most companies donot want to pay the price to show that theyre welders are qualified, And as I have mentioned in a post a few months back the a certification is simply a piece of papper showing the welder has met the minimum requirements to complete a sound weld for the process utilize! Further is the welder even though He has passed required qualifications still capable of doing them? or has He had some changes like the need for training or perhaps even simple eye correction. So depending on the job or who the job is for usually it is government contracts that require testing, Examples Space Launch complex (slc)6 Vandenburg AFB welders had to test, SLC 4 VAFB MST tower modifications required welders to test, also some large civilian jobs such as Mobile natural gas refinery Refugio beach California, Diablo Nuclear power plant San Luis Obispo Ca, so why is it the case that we are not imposing this to all projects! I'm here to tell you my friends with the baby boomers retiring and the increase of skilled jobs being taken by individuals not trained correctly or who's standards are not desirable! be prepared to see the welding industry fall short of it s capabilities because of what I just mentioned. Testing in My opinion is the way We should be headed and it should be in every part of the industry not just big jobs!
Parent - By Joseph P. Kane (****) Date 11-27-2008 16:31
Jim 12
In my not so humble opinion.....
It goes without repeating that pretesting immediately prior to start of work is desirable.  Retesting in the middle of a project as a QA tool is even more desirable.  For field welders, temporary welders, Union Hall hire-outs, "rig welders", and outside contractor welders, it is essential that welders should be tested just before employment on the project.  There is no reliable way of verifying competency from the paperwork that they carry in with them. However, in a shop, a person designated as a "Welder" would probably be welding on a continuous basis of some given interval.  It would be unreasonable to expect them to re-test at the whim of an inspector, unless there was cause to question competency. Any type of paper trail should be accepted, as long as the welder can be disqualified on the basis of unacceptable welding.

On New York State Bridges, a field welder takes a special examination in front of a State Civil Engineer.  After his coupons are tested, and he receives his certificate, there is a work card that the welder is obligated to have signed off by a PE. or a CWI attesting to six days of welding in each six month period, to retain currency.  Welders who retain their currency but who fail to perform in the field can, and sometimes do get their certificated revoked.  Mostly though, bad welders just keep being sent from job to job and never get busted out.  The exception is for Fracture Critical welding, where the welder has to certify within six months of starting the FCM work, and retest each year.

If the contract specifications allow it, the best thing is for the Inspector to require re-qualification of any welder who makes a non-conforming weld, or who says he cannot make a weld I/A/W the WPS.

Joe Kane
Up Topic Welding Industry / Inspection & Qualification / Welder continuity AWS D1.1

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