API 1104 Compliance for Inspection Service Providers
NDT contractors and welding inspection firms working girth welds, tie-ins, branch and fillet welds, mechanized welds and in-service welds on pipelines and related facilities for the compression, pumping and transmission of crude oil, petroleum products, fuel gases, carbon dioxide and nitrogen. Personnel are qualified under employer-based certification, so a contracted Level III can sign the written practice and administer examinations for the firm.
It also reaches fabrication shops producing pipeline components and any firm writing radiographic, magnetic particle, penetrant or ultrasonic procedures for pipeline weld examination. API 1104 is the technical spine underneath the federal pipeline rules. Section 8, Inspection and Testing of Production Welds, contains the two clauses a service provider is audited against: 8.3, Qualification of Inspection Personnel, and 8.4, Certification of NDT Personnel. Section 9 gives the acceptance standards for radiographic, magnetic particle, liquid penetrant, ultrasonic and visual results, including undercutting and internal concavity. Section 11 gives the procedures for each nondestructive testing method. Annex A provides alternative acceptance standards for girth welds supported by stress analysis; Annex B covers in-service welding and carries its own inspection clause and its own standards of acceptability. The commercially critical fact: the 22nd edition is current, but the federally enforceable edition for US pipeline work is the 21st.
Source: API Standard 1104 announcement page, api.org — confirms the 22nd edition and its scope covering gas and arc welding used in the construction and in-service repair of pipes and components for the compression, pumping and pipeline transmission of crude oil, petroleum products, fuel gases, carbon dioxide and nitrogen; the July 2021 publication date appears in reseller listings, not on API's own page. American Welding Society study guide for API Standard 1104, 22nd edition (pubs.aws.org) — verified for the clause structure: Section 4 Specifications; Section 5 Qualification of Welding Procedures with Filler Metal Additions; Section 6 Qualification of Welders including 6.6 Nondestructive Testing, Butt Welds Only; Section 7 Design and Preparation of a Joint for Production Welding; Section 8 Inspection and Testing of Production Welds with 8.1 Rights of Inspection, 8.2 Methods of Inspection, 8.3 Qualification of Inspection Personnel and 8.4 Certification of NDT Personnel; Section 9 Acceptance Standards for NDT with 9.3 Radiographic, 9.4 Magnetic Particle, 9.5 Liquid Penetrant, 9.6 Ultrasonic, 9.7 Visual Acceptance Standards for Undercutting and 9.8 Visual Acceptance Standards for Internal Concavity; Section 10 Repair and Removal of Weld Defects with 10.4 Repair Welder Qualification; Section 11 Procedures for Nondestructive Testing with 11.1 Radiographic, 11.2 Magnetic Particle, 11.3 Liquid Penetrant and 11.4 Ultrasonic; Section 12 Mechanized Welding with Filler Metal Additions; Annex A Alternative Acceptance Standards for Girth Welds with A.2 Stress Analysis; and Annex B In-service Welding with B.5 Inspection and Testing of In-service Welds and B.6 Standards of Acceptability: NDT (Including Visual). 49 CFR 192.7 and 195.3 in the eCFR, text current to 1 August 2026, for the incorporated 21st edition and the sections for which it is IBR approved. The full text of clauses 8.3 and 8.4 could not be obtained from a primary source; their titles and location in the standard are verified, their wording is deliberately not quoted here. Accessed 21 August 2026.
| Item | What applies | Why it matters |
|---|---|---|
| Authority | American Petroleum Institute develops and maintains the standard; PHMSA makes specified parts of it federally enforceable by incorporating it by reference in 49 CFR 192.7 and 195.3 | The body that issues, audits and can withdraw |
| Applies to | NDT contractors and welding inspection firms working girth welds, tie-ins, branch and fillet welds, mechanized welds and in-service welds on pipelines and. | Whether this binds your firm at all |
| Personnel certification | Employer-based — the firm certifies its own, under a qualified Level III | Decides whether an outsourced Level III can sign for you |
| Renewal | API 1104 is a standard, not a certificate, so there is nothing to renew. What changes is the edition. API issues new editions and addenda on its own ballot cycle and the 22nd edition is current. The enforceable edition for US pipeline work changes only when PHMSA amends the incorporations by reference in 49 CFR 192.7 and 195.3, which as of the eCFR text current to 1 August 2026 still name the 21st edition, September 2013, with Errata 1 through 5 and Addenda 1 and 2. Track both, and keep the 21st edition on the shelf for as long as you take federally regulated pipeline work. | Diarise from the certificate date, not from memory |
| Methods in scope | RT, MT, PT, UT, AUT, PAUT | Each method needs its own procedure and qualified personnel |
| Industries | Pipeline construction, Pipeline integrity and maintenance, Gas transmission, Hazardous liquid transmission, Gathering systems | Where this regime shows up in contracts |
Who does API 1104 apply to?
NDT contractors and welding inspection firms working girth welds, tie-ins, branch and fillet welds, mechanized welds and in-service welds on pipelines and related facilities for the compression, pumping and transmission of crude oil, petroleum products, fuel gases, carbon dioxide and nitrogen. It also reaches fabrication shops producing pipeline components and any firm writing radiographic, magnetic particle, penetrant or ultrasonic procedures for pipeline weld examination.
Can an outsourced Level III sign for API 1104 compliance?
Yes. API 1104 accepts employer-based certification, which places the obligation on the employer and allows a contracted Level III to write and sign the written practice, approve procedures and administer examinations. The Level III must be qualified in each method they sign for, and the employer still owns the records.
What documents does a API 1104 audit ask for?
Nondestructive testing procedures written to Section 11 for each method used — 11.1 radiographic, 11.2 magnetic particle, 11.3 liquid penetrant, 11.4 ultrasonic, Records of certification of NDT personnel under Section 8.4, Records of qualification of inspection personnel under Section 8.3, Welding procedure specifications and procedure qualification records under Section 5, or Section 12 for mechanized welding with filler metal additions, Welder qualification records under Section 6, including the Section 6.6 nondestructive testing of butt welds. Auditors open records before they open manuals, because a manual describes intent while records show practice. The most common failure is a documented system that does not match what the technicians actually do.
How often is API 1104 renewed?
API 1104 is a standard, not a certificate, so there is nothing to renew. What changes is the edition. API issues new editions and addenda on its own ballot cycle and the 22nd edition is current. The enforceable edition for US pipeline work changes only when PHMSA amends the incorporations by reference in 49 CFR 192.7 and 195.3, which as of the eCFR text current to 1 August 2026 still name the 21st edition, September 2013, with Errata 1 through 5 and Addenda 1 and 2. Track both, and keep the 21st edition on the shelf for as long as you take federally regulated pipeline work. Firms that diarise renewal from the certificate date rather than from the last audit avoid the lapse that forces a full reapplication.
What are the most common API 1104 findings?
Procedures and acceptance criteria written to the 22nd edition on a job that is federally regulated to the 21st, Section 9 acceptance criteria applied to a weld where the contract invoked Annex A, or Annex A applied without the stress analysis Annex A requires, Annex A used to accept a crack on federally regulated pipe, which 49 CFR 192.241(c) and 195.228(b) prohibit, In-service welds assessed against Section 9 rather than Annex B.6, which carries its own standards of acceptability including visual. These recur because they are records problems rather than capability problems — the work is being done correctly and the evidence is not being kept.
Which NDT methods does API 1104 cover?
RT, MT, PT, UT, AUT, PAUT, VT. Each method in scope needs its own approved procedure and personnel qualified in that specific method; a Level III qualified in ultrasonics cannot sign for radiography.
Personnel certification under API 1104
Employer-based in effect. API 1104 is a consensus standard, not a certification scheme — API certifies no NDT personnel under it and issues no company approval against it. Clause 8.4, Certification of NDT Personnel, and clause 8.3, Qualification of Inspection Personnel, place the obligation on the company performing the work, which is discharged through a written practice and, in the market, through ASNT SNT-TC-1A Level II certification. An outsourced Level III can write and approve the Section 11 procedures, administer and grade examinations and recommend certification, with the employer signing the certificate. Note that the federal rules which make API 1104 mandatory impose their own separate personnel requirement in 49 CFR 192.243(b)(2) and 195.234(b)(2); satisfy both, because they are not the same test.
The audit sequence
- Establish which edition governs the contract: work under 49 CFR Part 192 or Part 195 must meet the 21st edition, September 2013, with Errata 1 through 5 and Addenda 1 and 2, even where the purchase order names the 22nd
- Qualify welding procedures under Section 5, or Section 12 for mechanized welding with filler metal additions; qualify welders under Section 6
- Write and approve nondestructive testing procedures to Section 11, and fix the acceptance criteria to Section 9 or, with the required stress analysis, to Annex A
- Certify NDT personnel under 8.4 and qualify inspection personnel under 8.3, with records available on site for the operator's or client's inspection
- Inspect and test production welds under Section 8; repair or remove defects under Section 10 and re-examine
- Client or operator audit follows the record trail end to end — procedure, technician certificate, acceptance criterion, indication, disposition
Documents an auditor asks for
- Nondestructive testing procedures written to Section 11 for each method used — 11.1 radiographic, 11.2 magnetic particle, 11.3 liquid penetrant, 11.4 ultrasonic
- Records of certification of NDT personnel under Section 8.4
- Records of qualification of inspection personnel under Section 8.3
- Welding procedure specifications and procedure qualification records under Section 5, or Section 12 for mechanized welding with filler metal additions
- Welder qualification records under Section 6, including the Section 6.6 nondestructive testing of butt welds
- Acceptance criteria sheets keyed to Section 9, or to Annex A where alternative acceptance standards for girth welds are used
- Stress analysis and supporting assessment where Annex A is applied — Annex A.2
- In-service welding procedures, welder qualifications and inspection records under Annex B, including B.5 inspection and testing and B.6 standards of acceptability
- Repair procedures and repair welder qualification records under Section 10
Findings firms get against API 1104
- Procedures and acceptance criteria written to the 22nd edition on a job that is federally regulated to the 21st
- Section 9 acceptance criteria applied to a weld where the contract invoked Annex A, or Annex A applied without the stress analysis Annex A requires
- Annex A used to accept a crack on federally regulated pipe, which 49 CFR 192.241(c) and 195.228(b) prohibit
- In-service welds assessed against Section 9 rather than Annex B.6, which carries its own standards of acceptability including visual
- Mechanized welds made under Section 12 examined with a procedure written for manual welding
- NDT personnel certification records held by the individual technician rather than by the employer, so clause 8.4 cannot be demonstrated at audit
- Repairs made under Section 10 without a qualified repair procedure or a qualified repair welder under 10.3 and 10.4
- Radiographic technique sheets and interpretation records not retained with the weld record, breaking the chain from indication to disposition
Related: the API 1104 overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.