NDT Ethics: Rewriting Your Written Practice According to Your Needs 

Editor’s note: This NDT Ethics case study, written by Greg Weaver, is published in conjunction with the June 2022 issue of Materials Evaluation. Published quarterly, each NDT Ethics column will present a case study and invite readers to respond here on ASNT Pulse with their comments. Readers are also invited to email column editor Toni Bailey with their own ethical scenarios, which may be featured in future columns.  

_______

This month we discuss an ethics situation regarding the development of a company’s written practice that did not meet the intent of Recommended Practice No. SNT-TC-1A or customer requirements. We are using an example of unethical behavior by a company regarding the qualification and certification of nondestructive testing (NDT) personnel. SNT-TC-1A, and other standards, are designed with a simple framework for ease of implementation for the NDT method and all certification levels. Customary practice is that an employer’s written practice should, at a minimum, mimic or even exceed the intent of SNT-TC-1A or other standards required by the customer.  

No matter which qualification for certification document is selected for use by the employer (SNT-TC-1A, ANSI/ASNT CP-189, NAS 410, ISO 9712, or EN4179), the intent is well defined for formal training and experience for all certification levels. The different standards do have minor differences, but in general, the levels go in sequence beginning with limited levels through Level I, Level II, and finally Level III. Per SNT-TC-1A, there is also a path to obtain Level III certification by working in a position comparable to Level II, but in those cases, the full formal training and experience requirements of Level II are required. The approach to reaching Level III is clear in all the previously mentioned documents. Knowing this, let’s discuss a scenario where a company modified its written practice to allow for a Level I to obtain certification directly to Level III without meeting initial Level II qualification requirements.  

Modifying a Written Practice 

In this scenario, a company rewrote their written practice to accommodate their internal needs, knowing it was outside of the governing qualification for certification requirements. The company manufactures parts for the aerospace and power generation industries. They have an NDT written practice that is based on a hybrid of SNT-TC-1A and NAS 410. They have been in business for many years and have approximately 20 certified NDT employees. Their program encompasses several NDT methods and all levels of certification, and they have several Level IIIs on staff. The method we are discussing in this scenario is ultrasonic testing (UT), and it is a method that they have been performing for many years. The highest level of certification within the UT method allowed by their written practice is Level I. This is mainly because the only UT inspection performed is simple wall thickness measurement and their previous customers did not require any level of certification in UT, only qualification.  

As the written practice is limited to only allowing up to Level I, it was surprising to find that the UT inspection oversight and supervision was being performed by two Level II UT inspectors. Both inspectors stated that they were evaluated and certified to Level II by the company.

Remember, this is not possible, as there is no allowance for UT Level II within the company. 

After investigation, it was discovered that the company was using previous outside formal training and qualification testing to “certify” the two inspectors to Level II, even though it was not allowed within the written practice. One of the operators may have held a Level II at a previous company, but the other only had work experience from within the current company. No experience hours were ever documented for the Level IIs. We could stop here, but it gets worse. 

Level III Certification 

The company won a new contract, but this customer had a requirement for a UT Level III to perform inspection oversight. So, the company decided they would modify their procedure to allow for all levels of UT certification. This is fine, but they also decided to allow for the previous “Level IIs” to test directly to Level III. This decision came from “the top down,” so the written practice was modified and away they went. 

Questions 

So, are these Level IIIs qualified? Should they have been certified? Will their NDT records pass an audit? Is the work they are approving valid? These are all questions that might raise more questions for the company than they intended.  

We now ask you, the reader, to think about the scenario presented and determine if the company’s approach to qualification and certification violates the general code of ethics.

We would like to hear from the NDT community. Please comment below! 

_______

Greg Weaver: ASNT NDT Level III (RT and PT) and NAS 410 (RT, PT, and UT) Responsible Level III, Weaver NDT Non-Destructive Testing & Consulting, Las Vegas, NV 

Column Editor

Antionette (Toni) Bailey: ASNT NDT Level III/NAS 410 Level III (MT, PT, RT, UT, and ET), IRRSP; TB3 NDT Consulting LLC, Manorville, NY; 516-885-5007; toni@tb3ndt.com