Level III Requirements

[holdpt]

The topic of having a Level III on retainer has come up with my company. They are under the impression that you must have a Level III on retainer in order to run your quality program. Our work is 99% AWS D1.1 and I have not heard of such nor read anywhere that this is a necessity. I would rather just pay an hourly rate when needed than to pay thousands for standby. Am I unaware of a requirement?

 

[weldtek]

holdtpt,

D1.1 references SNT-TC-1A and so the short answer is yes, as is true for ASME Sec VIII work also, however, you must do so to conform to the requirements in SNT-TC-1A. This doesn't require that you pay an some huge sum to retain the services of a Lev III sitting around for hours waiting for some form to come across his desk requiring a signature. Typically, firms that don't have a Lev III directly on their payroll will retain a Lev III for specific activities such as testing technicians,developing procedures etc. They charge for the services performed.

 

[Duwe6]

The easy way to avoid having to retain the services of a L/III is to out-source all the NDT [testing] to a 3rd-party firm like MISTRAS or TEAM. Then the onus is on them. If you do nothing but visual, and you have a CWI, you are 'golden' per D1.1 and and the other D1 codes.

Even is you have the L/III, you still have to educate and certify your NDT folks. MT - mag particle - requires 24-hrs of formal classroom, PT - dye penn - requires 16 hours of formal classroom training, certified by a L/III. It is usually cheaper for a structural shop to outsource all testing [other than VT - visual]

 

[gtaw]

The Level III doesn't have to be on a retainer per se. The contractor responsible for fabrication has a responsibility to ensure the required inspections and tests are performed in accordance with the project specifications and applicable codes. If NDT is required, the contractor is responsible for the testing. The tests can be performed by in-house personnel if they have the requisite qualifications and certifications or the work can be subcontracted to a qualified vendor.

The latter is the rub. Even when work is subcontracted to a vendor, the responsibility to ensure the NDT was performed properly remains with the "prime" contractor. The fact that the work was contracted out does not absolve or indemnify the contractor from legal responsibility.

The contractor has an obligation to verify the vendor is qualified to perform the NDT that needs to be done. Due diligence would require the contractor to review the vendor’s written practice, NDT procedures, and qualifications and certification of the NDT technicians that would be doing the actual work.

It has been my experience that many contractors (manufacturers included) have the opinion that once the work is contracted to another company they are free and clear of any liability should something go wrong. That is far from the case as many companies have discovered once something goes horribly wrong and the courts have passed judgment.

Back to due diligence, the contractor has an obligation to ensure the vendor is qualified before awarding the work. Few contractors have the back ground needed to verify the vendor is in fact qualified other than by the simple fact they submitted the lowest quote. That being the case, it is in the contractor’s best interest to have an agreement with an “Outside Agency” that can provide Level III services. The services to be provided should be defined in a “Letter of Agreement” between the contractor and the outside agency. The services provided by the outside agency can be simply reviewing documentation submitted by vendors, or it can be acting as the contractor’s Level III in all matters such as developing a written practice, NDT procedures, training, administering the contractor’s certification program, etc.

Performing due diligence in determining the qualifications of the vendor providing NDT is a responsibility of the contractor. Failure to verify the NDT vendor is properly qualified to do the work simply opens the contractor up to additional liability should something go wrong.




Best regards - Al

 

[holdpt]

Thanks all for the input. I am the CWI and we perform our duties by the book, but have been paying over $2K for a Level III to wait for our call. Our MT and PT guys were trained appropriately and I over-see that as well as their VT work. I have moved writing procedures and testing welders in-house to save money. The only exception would be mechanical testing (ex. tensile pulls) that we are not set up to do. I am trying to streamline not only production but related costs as well in order to stay competitive. I summise that we may draw up a formal letter of agreement for the level III and just pay when needed.

 

[gtaw]

There is a lot that isn't being said in this post, such as exactly who in the company has taken on the tasks of writing procedures and what procedures being written.

I think it would be wise to review Table 1 contained in AWS B5.1 and QC1 to make sure no one is taking on job responsibilities for which they may not be certified to perform.

As a CWI, the individual is qualified and certified to perform visual inspections of welds. It doesn't qualify that individual to inspect high strength bolts, paint, develop or write WPSs, or NDT procedures, etc.

An attempt to save the employer money could end up costing the company money and put an individual in a position where they could be placing their CWI certification at risk. There are several conditions attached to being certified by the AWS. The candidate has to pass the CWI examinations, they have to pass the visual acuity test, they have to agree to abide by the Code of Ethic listed in QC1, and don't forget the most important part, pay the appropriate fees to AWS. No one should put their certification at risk by using their certification status as a CWI to say they are qualified/certified to develop WPSs or NDT procedures. To do so can be considered a viloation of the Code of Ethics.

Best regards - Al

 

[gtaw]

Sorry for the tangent.

A letter of agreement with a company that provides Level III services should be sufficient.

The letter of agreement should define what services are being provided. For instance, the Level III should:

a) review and approve the client's written practice.
b) review and approve all NDT procedures.
c) review and comment on all NDT procedures and certifications submitted by vendors providing NDT services.
d) review and approve the work histories, examinations, and certifications of the client's in-house NDT technicians.
e) develop and administer training and examinations of the client's in-house NDT technicians.
f) review and maintain client's certification program.

There are many tasks that can be undertaken by the client company provided they have the personnel with the necessary qualifications. The Level III can then review and approve the documents on a "as needed" basis.

The company providing outside services should establish an on-going relatioship with your employer. They should play an active role when your company is audited or when there is a question regarding your employer's NDT program.

Best regards - Al

 

[Duwe6]

"Our MT and PT guys were trained appropriately and I over-see that . . . ."

Sorry, but the instant there is no L/III available to oversee your L/I's and L/II's, they [and your program] fail to meet SNT-TC1a. Thus their cert's have evaporated.

You can obtain the education and training to certify as a L/III in PT and MT, or perform the examinations as "info only" w/o certification of the results. Or you can continue to retain a L/III to oversee your NDT program, per SNT-TC1a.

$2K/year looks a lot better now, doesn't it?

 

[holdpt]

I should clarify that I make sure the NDT gets done per the drawing or customer's specs. I couldn't correct these MT and PT guys if needed because they know more about it than I do.
I agree that the Lev III should oversee the NDT. However, I am still inclined to think that we are better served monetarily by a formal agreement on a requested or as-needed basis based on the previous $2600 agreement.
All have been extremely helpful and have enlightened me tremendously. IMHO, items such as this should be given more weight in the CWI studies and exam. I have been in this business for over 18yrs and a CWI for almost 9 and I have learned more in this thread than I have in the last 9 years.
Thanks.

 

[qcrobert]

holdpt,

Our company fabricates pressure vessels and holds ASME U & PP certificates incl. NBIC R certificate.

We have a copy of the NDE company (Acuren in this case) QC Manual and have reviewed their procedures and practices. We have a Letter of Agreement for them to provide NDE testing. We only pay them for services as they are rendered, just like our Authorized Inspection Agency. Pardon me but it appears you are getting screwed with a $2K retainer fee.

Whether you are an AWS CWI or not, you can write WPS's Welding Procedure Specifications, witness testing, perform your own bends and send off your tensile pulls and RT if required.

I am certified as SNT-TC-1A Level II in PT & MT to my company's written procedures that were generated & approved by a Level III. Thus I perform all in house PT & MT as a Level II that satisfies contractual specifications.

gtaw,

A Level III is not required to oversee my SNT-TC-1A Level II PT & MT activities.

 

[holdpt]

qcrobert,
I agree that we were screwed by this retainer (I inherited). That is what brought this subject up. I have reviewed AWS B5.1 2003 and Table 1 states that as a CWI, I am not qualified to develop welding procedures, only a SCWI. I am a little insulted but that seems to be the rule. Maybe instead of a 9yr recert this year, I should just try to get the SCWI, I don't know.

I have spoken with a different Level III and was informed that all that is needed is an appointment letter stating he is our Level III, he will submit his certs/QC manual, and he will perform an annual audit of our procedures and NDT work. Of course on an hourly rate which doesn't nearly add up to $2600! I can still develop procedures with his approval. His company does my tensiles so I will be in contact for procedures anyway.

 

[qcrobert]

Interesting that as an AWS CWI you are restricted from from developing welding procedures.

My previous AWS CWI (from 1992) has long been expired yet as a non AWS CWI I can develop WPS's, witness, perform bend tests, send off the tensiles, etc..

 

[gtaw]

It isn't that a CWI cannot write a WPS, it simply that it isn't an expectation that he is able to write a WPS. Some CWIs have the experience and training needed to write a WPS, but it isn't a given that just because an individual has the CWI certification in his back pocket he has the necessary expertise to do so.

I didn't say the Level III has to oversee day to day in-house NDT. I said it is best if there is an on-going relationship between the vendor providing outside services, i.e., Level III service, to ensure the NDT is being performed properly, procedures haven't been modified without proper review and approval, etc.

Considering the various functions that should be handled by the Level III, if the system is functioning properly, the relationship should be on-going rather than a mail-order or a once-in-a-lifetime purchase. The Level III needs to be familiar with the client's product line, methods of manufacturing, and applicable standards if the procedures and services delivered are to be more than "boiler plate" window dressings.

As for an expired CWI, there are many jobs that can be performed by individuals that are not CWI. Even AWS welding standards do not require the visual inspections to be performed by a CWI. That requirement is typically a customer imposed stipulation.

Best regards - Al

 

[gtaw]

AWS B5.1 and QC1 are sister documents. AWS B5.1 lists the job responsibilities and functions a welding inspector should be capable of performing. It lists three categories of inspectors. There is the Associate Welding Inspector, the Welding Inspector, and the Senior Welding Inspector. The functions each category of inspector should be capable of performing is listed in Table 1. Note that B5.1 does not use the terms CAWI, CWI, or SCWI.

QC1 refers back to B5.1 and defines the certification program whereby an individual can become certified by the AWS as a welding inspector. QC1 defines the certification requirements for the three levels of certification, i.e., CAWI, CWI, and SCWI. The QC1 committee has developed examinations intended to permit the candidate to demonstrate a working knowledge of those subjects required to fulfill the functions listed in Table 1 contained in B5.1.

The CWI examinations do not require the candidate to demonstrate the ability to develop a WPS. The examinations requires the candidate to demonstrate the ability to use a WPS and understand the information provided by the PQR.

The SCWI examination is intended to test the candidates ability to develop a WPS based on AWS B2.1. Thus the SCWI is expected to be able to develop a WPS.

An individual can be qualified to perform a function without being certified. An individual becomes certified when someone is willing to sign a piece of paper attesting to the fact that certain qualification requirements have been met.

Best regards - Al

 

[qcrobert]

Thanks for clearing up the matter, Al.

When you stated that, "As a CWI, the individual is qualified and certified to perform visual inspections of welds. It doesn't qualify that individual to inspect high strength bolts, paint, develop or write WPSs, or NDT procedures, etc."

I thought you were implying that the CWI was not permitted to write a WPS.

There is a big difference between just writing a WPS and being qualified to inspect high strength bolts, paint, or NDT procedures.

Only a Level III may develop & write NDT procedures.

Anyway, I believe we are both in concurence with our statements and have enlightened the OP.

QCRobert

 

[qcrobert]

holdpt,

I must inquire about your statement that "Our MT and PT guys were trained appropriately."

Are your MT & PT guys educated AND certified under the guidelines of SNT-TC-1A?

If so, then you have an in-house written practice and applicable NDE procedures that were written and qualified by a Level III.

 

[holdpt]

Yes, all NDT personnel were certified under a Level III by SNT-TC-1A.

 

[qcrobert]

And you have an in-house (your company) written practice and applicable NDE procedures that were written and qualified by a Level III?