"PP" or "S" stamp required alert...AFTER fabrication??

[JAYDEE23]

We make specialized flow measurement piping for plants. We also hold an ASME "S" stamp certificate and do a lot of piping that is "S" stamped by our ASME Authorized Inspector. The issue is, we have 2 pipe sections now complete that did not technically go through our ASME program review process and now the customer is requiring an "S" stamp. All materials and fabrication have been executed in the very same way as if the stamp was required. It just did not go through the same review process with AI it would have if we had known from the beginning that it needed to be stamped.

My question, It would seem there should be some provision to stamp this if i can produce all ASME conforming documents including MTRs, weld procedures etc.. What i can not produce is design review by AI prior to fabrication..

My AI says he does not think he can approve because it did not follow the laid out sequence of review outlined in our ASME QA manual. Your opinions/thoughts?

 

[metengr]

The simple answer is whatever your AI says, you follow. They are the ones placing their name and NB commission on the line.

 

[JAYDEE23]

Fair enough. Im wondering from an AI point of view if this is a BIG NO NO or what. They certainly have discretion. We have an excellent relationship and never witnesses anything in the fabrication process because he knows our work is top notch. All that being said i am feeling he should at the very least explore any opportunity to help us resolve this issue. He does after all work for us right?

 

[metengr]

The Authorized Inspector provides a service and should be unbiased. That is what you contract the service for, nothing else. Over the years, I have developed good relationships with AI's under contract and respect their opinion. If you can persuade your AI on the facts, this is the approach to take. Again, thye are putting their name and NB commission on the line for you.

 

[JAYDEE23]

The issue has been more internal. We have a review with the AI tomorrow. I will post my results.

 

[GenB]

Bring the complete package in front of the AI and tell him or her the truth... Good luck. My AI will tell "good try" You see I always get credit for trying...

 

[minibenny]

I agree with the suggestion from GenB and metengr above. Provide all required documents to your A.I. for review. If you QC Manual states that A.I. shall review these documents prior to commencement of fabrication, then you may have to write an NCR for not following your program, regardless of whether the fault was yours or not. Hopefully the A.I. will accept that, and hopefully, there will be no re-work required due to any missed mandatory inspections.

I may be wrong, but I'm not certain the A.I's name and commission are on the line, because at the area on the ASME Data Reports where the A.I. signs, it says
"By signing this certificate, neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the boiler described in this Manufacturer’s Data Report. Furthermore, neither the Inspector nor his employer shall be liable in any manner for any personal injury or property damage or a loss of any kind arising from or connected with this inspection."

It also says "....to the best of my knowledge and belief, the Manufacturer has constructed this boiler in accordance with Section I of the ASME BOILER AND PRESSURE VESSEL CODE."

If you can provide the A.I. with all the necessary documents to support the work you've done, and the A.I. can perform the required inspections, then I don't see why the A.I. shouldn't sign it off after documents, inspections, and NCR are accepted.

 

[metengr]

"By signing this certificate, neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the boiler described in this Manufacturer’s Data Report. Furthermore, neither the Inspector nor his employer shall be liable in any manner for any personal injury or property damage or a loss of any kind arising from or connected with this inspection

Tell that to the National Board Peer Review committee. A National Board commission can still be revoked regardless of the above indemnification statement.

 

[minibenny]

Ah, good point. Thanks metengr. It makes sense that NB commissions can be revoked, otherwise neglegence could be an issue. I hadn't really though about that before.

 

[JAYDEE23]

I am surprised by the uncertainty. Certainly this must happen plenty every year. Our customer mis-interpreted BEP vs NBEP so ultimately we did not need to stamp these. By my research and inquiries, seems like an overwhelming YES to allowing, as an exception, a stamp in this case (as long as the proper documentation is supplied). Seems like everyone has an opinion but there are no definitive answers. Thanks for the input. If i cant find a definitive answer i will write ASME..

 

[GenB]

... The ,,opinion,,was to advise you when you tried to cover by your words a mistak. By the ASME Code you definitely committed a Code violation. And by involving the AI who was the only hope for you to stamp the part. By accepting and NCR was a cover by the AI to help you without the getting himself in trouble. Just remember once the part is fabricated it is not the ASME part but the NB's. Good luck. Yeah go ahead and ask the ASME and please post thir interpretation.