PQR Testing and Ownership

[Jimmy123406]

A contractor that is fabricating (2) storage tanks per API-650 for our project has produced numerous WPS's signed by "their company QC" with PQR's that were 3rd party tested using the 3rd party testing companies welder and 3rd party testing companies inspector with both individuals names listed on the PQR, the form was then signed by the contractors QC that is claiming ownership of the PQR.

The contractors QC told me their company had a phone conversation contract with the 3rd party testing company to qualify the PQR'S and to my knowledge the contractors QC did not even witness the PQR testing nor use their own companies welder to qualify the procedure.

My experience of 38 years in the industry and teaching by my peers and predecessors has taught me that this is not allowed per code. My follow up research of ASME Section IX QG-100 thru QH-109.2 and QW-200.2 by my interpretation confirms that this is not allowed.

The contractor is very persistent that they are allowed to do this and to save argument I would like to reach out to the community for advice on how to handle this situation.

Thank you in advance.
Jimmy

 

[SJones]

https://www.eng-tips.com/search.cfm?q=ownership+of+welding+procedures&action=search

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.

 

[DekDee]

Your Contractor is wrong and it is not acceptable

QG-106.1 Procedure Qualifications. Each organization
is responsible for conducting the tests required by
this Section to qualify the procedures that are used in
the construction of components under the rules of the
Codes, standards, and specifications that reference this
Section.
(a) The personnel who produce test joints for procedure
qualification shall be under the full supervision
and control of the qualifying organization during the production
of these test joints. The persons producing test
joints for the qualification of procedures shall be either
direct employees or shall be personally engaged by contract
for material-joining services, except as permitted
in QG-106.4.

organization: as used in this Section, an organization is a
manufacturer, contractor, assembler, installer, or some
other single or combined entity having responsibility
for operational control of the material-joining methods
used in the construction of components in accordance
with the codes, standards, and specifications which reference
this Section.

(b) Production of qualification test joints under the
supervision and control of another organization is not
permitted, except as permitted in QG-106.4.

QG-106.4 Simultaneous Procedure Qualifications.
When expressly permitted by the referencing code, welding
procedures may be simultaneously qualified by more
than one organization, provided that each organization
accepts full responsibility for any such qualifications
and the following requirements are met:
(a) Each participating organization shall be represented
by an individual with responsibility for qualification
of joining procedures, as detailed in QG-106.

 

[SJones]

“The Code”. - which “code” has been contractually specified?

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.

 

[Krishna_Manyam]

If PQR's been established by Third party inspection under their control and premises, Contractor QC cannot claim the WPS,has to Qualify WPS as per ASME Section IX.

 

[SJones]

That is correct when the complete extent of ASME IX is interpreted as applying to an API Std 650 tank.

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.

 

[Dhurjati Sen]

Check Section 9 (Welding Procedure & Qualifications) of API 650 under which 9.2.1.1. mentions a provision where you as the Purchaser can accept what the contractor wants you to accept.

DHURJATI SEN
Kolkata, India

 

[ethan18]

The contractor is wrong.

Although latest edition of Section IX has removed the requirement of the welder making the procedure qualification test coupon to be an employee of the qualifying organization, he must still be under full supervision and control of the qualifying organization (meaning that a welder on a contract can be used too, for making the coupon). I don't see how employee of the third party in the above question can be understood to be under supervision & control of the contractor.

Secondly, the third party's inspector has signed off on the PQR. This is not allowed too. The qualifying organization cannot subcontract the work of certifying the PQR (reiterated in several interpretations, eg. IX-07-13(qs 1)).

Basically, everything else [including preparation of base plates by machining etc, NDE, preparation of wps (IX-18-47), NDE, preparation of specimens for mechanical testing, actual mechanical testing] can be subcontracted, except the following four things:

1. Welding must have been done under supervision & control of qualifying organization.
2. Welder making the test coupon must have been done under supervision & control of qualifying organization.
3. Certification of PQR must have been done by qualifying organization themselves.
4. Qualifying organization must assume responsibility for all the work done by sub contractors.

In your example OP, the contractor has not met serial number 1, 2, & 3 above. The contractor is not compliant with Sec IX.

 

[Jimmy123406]

After several back and forth emails and conversations the client that I am representing at this time and the contractor that was in question here both reached out to others for advice and admitted that they were mistaken.

The WPS's and PQR's were reperformed by the contractor a couple of days after my post was initiated and are now compliant.

I appreciate the responses by all and hope this thread helps others in the future when confronted by a difficult contractor.


Thank you,
Jimmy Harmon