API 1104 Audit Preparation for Inspection Companies
A API 1104 audit runs in 6 stages, beginning with establish which edition governs the contract: work under 49 cfr part 192.. 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.
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. What separates firms that clear an audit from firms that collect findings is not the quality of the documentation but whether it describes what actually happens.
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.
| Stage | What happens | What it tests |
|---|---|---|
| Stage 1 | Establish which edition governs the contract: work under 49 CFR Part 192 or Part 195 must meet the 21st edition,. | Where the paperwork is tested against itself |
| Stage 2 | Qualify welding procedures under Section 5, or Section 12 for mechanized welding with filler metal additions; qualify welders under Section. | Where the paperwork is tested against practice |
| Stage 3 | Write and approve nondestructive testing procedures to Section 11, and fix the acceptance criteria to Section 9 or, with the. | Where the paperwork is tested against practice |
| Stage 4 | Certify NDT personnel under 8.4 and qualify inspection personnel under 8. | Where the paperwork is tested against practice |
| Stage 5 | Inspect and test production welds under Section 8; repair or remove defects under Section 10 and re-examine | Where the paperwork is tested against practice |
| Stage 6 | Client or operator audit follows the record trail end to end — procedure, technician certificate, acceptance criterion, indication, disposition | Where the paperwork is tested against practice |
| 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. | Diarised from the certificate date, not the last audit |
How long does API 1104 audit preparation take?
Document work — the written practice, procedures and quality manual — takes weeks. What cannot be compressed is documented experience and records history: on-the-job hours accrue in real time, and calibration and certification history cannot be back-filled. Firms that start when the audit is scheduled rather than announced clear it without findings.
What does 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 look at first?
Records, not manuals. A manual states intent; records show practice. The usual opening move is to take a completed job and trace it back to the technician's certification, the instrument's calibration, the approved procedure and the report — and see whether all four reconcile.
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. Almost all of them are evidence problems rather than capability problems: the work was done correctly and the proof was not kept, or was kept somewhere the firm could not retrieve during the audit.
Can a consultant attend the API 1104 audit?
Yes, and it changes the outcome. Someone who has sat through the same audit at other firms answers in the auditor's own terms, produces the right record without a search, and stops a clarification turning into a finding. The firm still owns every answer — the consultant does not speak for it.
What happens after a API 1104 finding?
A corrective action with a deadline, and evidence of closure at the next audit. Repeat findings are treated far more seriously than first ones, because they show the corrective-action system itself is not working.
Does API 1104 require a pre-audit or gap assessment?
Not as a requirement, but the arithmetic favours it: a gap assessment finds the same evidence problems the auditor would, without the finding attached, and while there is still time to fix them. Firms entering their first API 1104 audit blind typically collect findings that a sampling exercise would have caught.
What the auditor asks to see
- 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 to close before the audit
- 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.