Contradiction on PQR qualification by others?

[XL83NL]

I was reading david339933's excellent post on NB's article about ASME IX article QG-106. This reminded me on a section in B31.3, which has a provision in 328.2.2 on Procedure Qualification by Others.

328.2.2 Procedure Qualification by Others. In order to
avoid duplication of effort and subject to the approval of
the owner, WPSs and BPSs qualified by a technically
competent group or agency may be used provided the
following are met:
(a) The procedures meet the requirements of ASME
BPVC, Section IX and any additional qualification requirements
of this Code.
(b) The employer has qualified at least one welder,
brazer, or operator following each WPS or BPS.
(c) The employer’s business name shall be shown on
each WPS and BPS, and on each qualification record. In
addition, qualification records shall be signed and
dated by the employer, thereby accepting responsibility
for the qualifications performed by others.

Assuming we're not talking subcontracted work here, isn't that contradicting with QG-106.1(b)

(b) Production of qualification test joints under the
supervision and control of another organization is not
permitted. However, it is permitted to subcontract any
or all of the work necessary for preparing the materials
to be joined, the subsequent work for preparing test specimens
from the completed test joint, and the

The Code of construction (here B31.3) would normally prevail over the service code (sec IX), but such contradictions don't seem to fit the larger picture.
Am I missing something?

Huub

 

[SJones]

Huub - could it simply be that one document has "Boiler & Pressure Vessel" on the front, and the other has "Pressure Piping?" Employers, such as oil companies, find it much easier to keep a library of WPSs to dish out to service fabrication contractors for piping, whereas a vessel fabricator would have to be pretty desperate to take on such a WPS.

Steve Jones
Corrosion Management Consultant

http://www.linkedin.com/in/drstevejones

All answers are personal opinions only and are in no way connected with any employer.

 

[XL83NL]

Sorry I might be misunderstanding you or missing your point Steve.
The oil companies or any other company we've dealt with (chemical, biochemical, renewables, pharmaceutical, biopharma, etc.) don't have WPS's they provide us with. They provide details for welding through their specs though, but not a complete WPS. Never. Nonetheless, why would it matter?
What Im looking at or for is the great (apparent) contradiction in these 2 codes. What 328.2.2 is telling me is that our company can start welding pressure piping to B31.3 when they hold no PQR, but use a WPS of another company, provided the requirements of a, b and c are met. Requirement (a) directs me to sec IX, which tells me I can't do that. B31.3 requirements would normally prevail (at least, that how I understand the hierarchy between construction and service codes). Am I interpreting this contradiction correctly?

Huub

 

[SJones]

No, you are OK Huub - it's a fair question. Probably needs an ASME stalwart who has sat on both committees to give us the lowdown. I can only think that the B31.3 people meant the welding procedure specification and qualification requirements of Section IX without the quality management add ons, but they didn't spell it out enough.

I've certainly been involved with oil companies that maintained piping WPSs and PQRs that were made available to piping fabrication contractors who had to do shop and field welding. It was piping only, never for vessels as they'd not get a stamp.

Steve Jones
Corrosion Management Consultant

http://www.linkedin.com/in/drstevejones

All answers are personal opinions only and are in no way connected with any employer.

 

[weldstan]

I can agree with Steve regarding the use of WPS's qualified to ASME IX by the Owner and supplied to our company for welding piping under B31.3.

 

[DekDee]

Looks like this Procedure Qualification by Others subject has been chopped and changed quite a bit over the years.

Interpretation: 11-09
Subject: ASME B31.3-1990 Edition, Para. 328.2, Welding Qualification
Date Issued: November 25, 1992
File: B31-92-013
Question: In accordance with ASME B3l.3-1990 Edition, para. 328.2, may a contractor use a
welding procedure specification written by others provided that he produces a supporting procedure
qualification made by his own organization?
Reply: Yes, see para. 328.2.2

Interpretation: 12-07
Subject: ASME B31.3-1990 Edition, Para. 328.1, Welding Responsibility
Date Issued: June 7, 1993
File: B31-93-Q09
Question: In accordance with ASME B31.3-1990 Edition, para. 328.1, is it permissible for owner,
rather than employer, to assume responsibility for the welding done by employer's personnel; and
for owner to provide WPS, PQR, and to arrange for tests required to qualify or re-qualify welders
and welding operators?
Reply: No.

Interpretation: 19-26
Subject: ASME B31.3-1999 Edition, Para. 328.2.2(i), Welding Qualification
Date Issued: October 10, 2002
File: B31-02-D3819
19-26. 19-27. 19-28, 19-29
Question: In accordance with ASME B31.3-1999 (2001 Addenda), para. 328.2.2(i), when using
welding procedures qualified by others, must all welders qualified to a specific WPS be qualified
by bend testing under BPV Section IX, para. QW-302?
Reply: No. Only one welder must be qualified to the specific WPS by the requirements of BPV
Section IX, para. QW-302. All others may be qualified in accordance with ASME B31.3, para. 328.2.

2012 edition has major changes.
My library only goes back to 2002 so unsure when the changes start happening.

Hubert,
If you want to follow up send an e-mail to Walt Sperko who has sat for many years on both the ASME IX and B31.3 committees.
He would have been in the thick of these changes.
Cheers,
Shane

 

[CWEng]

Section IX is a service code. It supports the construction codes, such as III, VIII, or B31.X. The construction codes can use, modify, add to Section IX as they see fit. In the case of B31.3 it's modifying the requirements of Section IX.

 

[XL83NL]

Yeah, I know, understand that - I wrote that twice in previous posts.
This just seemed to me like a rather huge (perhaps unintended) contradiction though - Ive seen differences before, but usually smaller and never this way around (i.e. construction limits the play room of a service code).
Ill send a message to Walter to see if he knows.

Thanks all so far.

Huub

 

[gtaw]

I believe the provision is included to allow contractors to purchase Standard Welding Procedure Specifications from the American Welding Society to side step the need to qualify the WPS by testing themselves. A welder has to pass a performance test staying within the limits of the SWPS before the SWPS can be used for production welding.

There are a couple of additional provisions; 1) the construction code must recognize the use of SWPSs, for instance the SWPS cannot be used per B31.3 if the system is categorized as high pressure, 2) the SWPS is not valid if PWHT is required, 3) the SWPS is not valid when CVN is required by the construction code, 4) the SWPS must be followed and can not be subdivided to utilize just one welding process if two welding processes are listed by the SWPS, 5) the SWPS cannot be combined with another SWPS or with another qualified WPS.

Best regards - Al