Jurisdictional authority and owner-user authority are not the same purchase

The two commissions the National Board issues

There are exactly two. The National Board Inservice Inspector Commission, designated IS, is issued to individuals qualified to perform installation and in-service inspections, meaning the jurisdictionally required periodic inspections of boilers and pressure vessels that are in operation. The National Board Authorized Inspector Commission, designated AI, is issued to individuals qualified to perform the inspections required by the ASME Boiler and Pressure Vessel Code during construction. For an operating midstream asset, IS is the one that matters and AI is the one people accidentally ask for.

Everything else in the system is an endorsement layered on top of a commission. N, I and C cover nuclear construction, nuclear in-service and nuclear concrete. R is the Repair Inspector endorsement, which is what unlocks acceptance inspections of repairs and alterations under the National Board Inspection Code. B and O are supervisor endorsements, B for an Authorized Inspector Supervisor and O for an Owner-User Inspector Supervisor. None of them stands alone.

The governing document is NB-263, RCI-1, Rules for Commissioned Inspectors. The 2025 Edition became effective 1 January 2025 and mandatory from 1 July 2025, and the National Board publishes a new edition every two years, with the next planned to take effect 1 January 2027. If your RFP template cites an older edition by year, it is already stale, and the auditor reading your file will notice.

The employment rule that decides your RFP

RCI-1 paragraph 1-1.1 is the clause that quietly rewrites your bidder list. A candidate for a National Board Commission shall be in the exclusive employment of a Jurisdictional Authority, an Authorized Inspection Agency, an Owner-User Inspection Organization, a Non-Member Enforcement Agency, or the National Board. The National Board's own guidance adds a Federal Inspection Agency to that list. There is no individual application route; the candidate and the employer apply jointly, and the commission card carries the employer's name.

The consequences run further than most RFP authors expect. Commissions expire annually on 31 December, and the employer renews them, documenting that the inspector completed the required continuing education for each commission and endorsement held. Change employer and the commission has to be transferred on an Application for Change of Employment, with continuing education completed in the twelve months before submittal. Let it lapse more than two years and reinstatement requires retaking the examination.

There is also an ethics rule with teeth. RCI-1 Part 7 requires Commissioned Inspectors to be independent from designing, manufacturing, supplying, installing, purchasing, owning or maintaining the items they inspect, and bars inspecting work performed by entities under the same corporate structure or contractual arrangement. Inspectors employed by an accredited Owner-User Inspection Organization may be exempt from those requirements. That single carve-out is the whole reason the owner-user route exists.

How a person gets a commission, and where API 510 counts

The default path is five credit points drawn from education and experience, with a minimum of one and a maximum of four from each side. Education credit includes three points for a bachelor's degree or higher in engineering, technology, science or mathematics, two for a two-year degree or an accredited apprenticeship, and two for an AWS Certified Welding Inspector certification. Certification as an API 510 or API 570 inspector is also worth two points. Eighty hours of classroom technical training in boiler, pressure vessel or piping inspection earns one.

Experience credit is one point per year in engineering or design review, manufacturing, high-pressure steam plant operation above 50,000 lb/hr, repairs and alterations, quality control systems, inspection of boilers or pressure vessels, or work as an NDE examiner meeting ASNT Level II or III by examination. Concurrent experience does not stack; two years as a QC manager who was simultaneously a Level II examiner is two years, not four.

There is a second route. RCI-1 paragraph 1-1.3 allows the National Board Inservice Inspector Training Program, described in NB-380, in place of the five credit points. It combines mentored on-the-job training with the classroom Inservice Inspector Commission Course, three online courses covering NBIC Part 1, NBIC Part 2 and RCI-1, and a minimum of 300 inspections carried out under the instruction of a National Board Commissioned Inspector. Partial credit is not granted. Either route ends at the same examination, which requires 70 percent to pass.

What the R endorsement adds, and when you need it

The R endorsement is the Repair Inspector qualification, and it is the one midstream RFPs most often omit and then need. It requires the National Board Repair Inspector Course plus an active IS or AI commission. A holder of an IS commission also needs eighty hours of diversified experience as a Repair Inspector trainee under direct supervision, of which up to forty hours may be credited from Authorized Inspector on-the-job training and up to eight hours from observing a joint review for a National Board Certificate of Authorization.

What the endorsement buys is the authority to make authorization, in-process and acceptance inspections for repairs and alterations to NBIC Part 3, and to sign the National Board report forms that follow. If a vessel at your gas plant needs a weld repair to a pressure boundary, that signature is a separate deliverable from your API 510 inspector's engineering evaluation, and it is the one that keeps the jurisdiction and the insurer satisfied.

So the practical RFP question is not which credential, it is which deliverables. In-service inspection and interval setting is API 510 work. Repair and alteration acceptance under the NBIC is R endorsement work. The two overlap on the same vessel in the same outage, and the bidder who cannot name who signs which form is telling you something. That reconciliation is exactly what an API 510 programme audit is for.

The Owner-User Inspection Organization route

NB-371, Revision 11, approved by the Board of Trustees on 10 May 2025, sets the rules for accrediting your own company. An OUIO Certificate of Accreditation allows National Board Commissioned Inspectors on your payroll to perform in-service inspection of items you own and operate, and the scope may be extended to repair and alteration inspections for NBIC compliance. It requires a written quality management system meeting NB-381, a National Board review and verification of implementation at your facility, and authorization from the jurisdictional authority.

Two details decide whether the route is worth it for a midstream operator. First, where the applicant has facilities in more than one jurisdiction, a separate Certificate of Accreditation is required for the facilities in each jurisdiction. A company with vessels in four states carries four accreditations, four QMS implementations, four reviews. Second, the certificate expires every three years, and each renewal repeats the review.

You also have to staff it. The OUIO must employ one or more owner-user inspector supervisors, each holding an active Inservice Inspector Commission and, where the scope includes repair and alteration inspections, the R endorsement. A provisional Certificate of Accreditation lets you employ inspectors and lets employees apply for commissions while accreditation is in progress, but no inspections may be performed until the commissions and the certificate are actually issued. Plan on quarters, not weeks.

What API 510 authorises that no commission does

API 510 is the code, not just the credential, and that is the point people miss. The 11th edition, carrying Errata 1 from 2023 and Errata 2 from 2025, governs in-service inspection, rating, repair and alteration for pressure vessels under an owner-user inspection programme. It gives the authorised inspector the machinery to set inspection intervals from corrosion rates and remaining life, to calculate remaining corrosion allowance, to accept a re-rate, and to accept the vessel back into service.

A National Board commission confers none of that. It confers authority to carry out a jurisdictionally required inspection and to report the result in the manner the jurisdiction prescribes. The two credentials answer different questions: the commission answers who is permitted to inspect on the jurisdiction's behalf, and API 510 answers how the owner decides what to inspect, when, and what to do about the answer. Interval logic and risk targeting sit on the API side, which is where risk-based inspection programme design attaches.

For a US midstream operator there is a third pressure entirely. OSHA's process safety management standard requires mechanical integrity for covered process equipment, and API 510 is the recognised and generally accepted good engineering practice that most operators name to satisfy it. That obligation exists whether or not your state jurisdiction inspects unfired pressure vessels, and it is unpacked in the NDT half of PSM mechanical integrity.

How deep API 510 goes on NDE, and where it stops

Read the body of knowledge and the boundary is unmistakable. The API 510 exam BOK dated September 2025, covering the September 2025, January 2026 and May 2026 windows, lists API 510, RP 571, RP 572 including Annex B, RP 576, RP 577 and RP 578, plus ASME Section V, Section VIII Division 1, Section IX and ASME PCC-2. On ultrasonics it covers ASME Section V Article 23, SE-797 only, the standard practice for measuring thickness by manual pulse-echo contact method.

That means the API 510 certificate tests thickness measurement, radiography, liquid penetrant and magnetic particle general requirements, and nothing about shear wave flaw detection, crack sizing or phased array. An API 510 inspector reviewing a phased array corrosion mapping report is working outside the knowledge the certificate attests. It does not make them wrong; it makes the certificate silent, which is a different thing to say in a bid evaluation.

The gap is filled from the ASNT side, by a Level III who owns the technique and reviews the reads. Naming that role explicitly in the RFP costs nothing and closes the loop, and it is what outsourced ASNT Level III consulting exists to supply for operators who do not carry a Level III in house.

Writing the midstream RFP clause

Write four separate personnel lines rather than one compound one. Line one, the in-service inspection is performed and signed by an API 510 certified inspector, certificate current at the date of inspection. Line two, NDE is performed by examiners certified under a written practice that the bidder submits with the tender, and interpreted by a certified Level III in the applicable method. Line three, where NBIC repair or alteration acceptance falls in scope, that acceptance is made by a Repair Inspector holding an active National Board commission with the R endorsement.

Line four is the one that saves the tender. State that where a National Board commission is required, the bidder shall identify the employing Authorized Inspection Agency or Owner-User Inspection Organization and provide its Certificate of Accreditation number and the jurisdiction it covers. This makes the employment constraint visible at bid stage instead of at mobilisation, and it lets an honest contractor say plainly that they will subcontract the commissioned scope.

Then add the boring line everyone forgets: a personnel matrix listing each named individual, each certificate, the issuing body and the expiry date, refreshed monthly for the duration. Commissions expire on 31 December regardless of when they were issued, so a January outage inherits a cliff edge every year. Tracking that across a roster is precisely the problem NDT personnel certification tracking solves.

Verification: what to ask a bidder to produce

Ask for images, not assertions. On the API side, the certificate shows the programme, the number and the expiry, and API's exam windows for 2026 ran 2 to 23 January, 8 to 29 May and 4 to 25 September for API 510, which tells you how long a lapsed inspector will take to get current. On the National Board side, the commission card names the employer, and the endorsements are printed on it, so an R endorsement that is claimed but not printed is not held.

Then ask one question that separates real capability from paperwork: which specific reports will each named person sign, and against which code. A bidder who answers cleanly has run this before. A bidder who answers with a capability statement has not. Where the answer looks thin, an independent read of a sample of their existing reports settles it faster than any interview, which is what NDT report validation is for.

Where Atlantis fits

Atlantis does not sell API 510, 570 or 653 certification training, and no private company can issue a National Board commission. What we do is the work that sits either side of those credentials for owner-operators: independent validation of the inspection reports your programme depends on, outsourced ASNT Level III coverage for procedure ownership and method scope, and programme audits that reconcile what your RFP asked for against what your files actually contain.

If you are rewriting a midstream inspection RFP this quarter, send us the personnel clause and the deliverables list. We will mark up the places where the commission requirement will exclude your preferred bidder and the places where the API 510 requirement leaves an NDE gap. Get in touch for a demo or a quote on request. Affordable. Accessible. Fully customizable.

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