Ultrasonic Testing (UT) Requirements Under OSHA PSM

Sensitivity setting is the auditable step: the reference block used must itself be in calibration and traceable, and its identity recorded on the report. OSHA PSM, enforced by Occupational Safety and Health Administration, US Department of Labor; enforced through inspections.: OSHA specifies no certification scheme at all — there is no OSHA NDT certificate and no OSHA-approved certifying body.

An auditor examining UT asks for instrument, probes, cables, couplant, and the calibration and reference blocks used to set sensitivity. PSM licenses nobody, but it is the reason most refinery and chemical inspection work exists and the reason your paperwork gets audited. The mechanical integrity element requires written procedures to maintain equipment integrity, training for maintenance personnel, inspections and tests performed on process equipment, inspection and testing procedures that follow recognized and generally accepted good engineering practices, frequencies consistent with manufacturers' recommendations and good engineering practices, and documentation of each inspection identifying the date, the name of the person who performed it, the equipment serial number or other identifier, a description of the test and the results. Every NDT report you issue into a PSM plant becomes the host employer's record under that documentation paragraph. Separately, the contractor paragraph puts training, documentation and site-rule duties directly on you.

Source: 29 CFR 1910.119 as published in the eCFR, text current to 1 August 2026 — verified verbatim for (a)(1)(i) and (a)(1)(ii) including the Category 1 flammable gas / flammable liquid with a flashpoint below 100 °F (37.8 °C) at 10,000 pounds (4535.9 kg) or more threshold; (d)(3)(ii) documentation that equipment complies with recognized and generally accepted good engineering practices; (e)(6) five-year process hazard analysis update and revalidation; (h)(1) application and the incidental-services exclusion; (h)(2)(i) through (vi) host duties; (h)(3)(i) through (v) contract employer duties including the training record contents; (j)(1) the six equipment categories; (j)(2) written procedures; (j)(3) training for process maintenance activities; (j)(4)(i) through (iv) inspection and testing and the five documentation items; (j)(5) equipment deficiencies; (j)(6) quality assurance; (k) hot work permits; and (o)(1) through (o)(5) compliance audits at least every three years with the two most recent reports retained. OSHA Instruction CPL 03-00-021, PSM Covered Chemical Facilities National Emphasis Program, information date 17 January 2017 — verified for the inspection process (opening conference, document requests before and after unit selection, PSM overview, initial walkaround, unit selection, Dynamic List questions, inspection of both host and contract employers, citations), for the emphasis on implementation over documentation, and for the specific request of contract employer safety programmes and contract worker training documentation. OSHA penalties page, osha.gov, accessed 21 August 2026, for $16,550 and $165,514. Percentage breakdowns of PSM citations by paragraph circulating online trace to a 1995 article and are not reproduced here.

Ultrasonic Testing under OSHA PSM — procedure, personnel and evidence
Item	What applies	Why it matters
Regime	OSHA Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119 — Mechanical Integrity and Contractor Requirements	Enforced by Occupational Safety and Health Administration, US Department of Labor; enforced through inspections under the PSM Covered Chemical Facilities National Emphasis Program and by State Plan agencies
Method	Ultrasonic Testing (UT)	Needs its own procedure and its own qualified personnel
Procedure approval	The employer's Level III, qualified in this method	The signature an auditor traces
Other methods in scope	UT thickness, PAUT, TOFD, RT, MT, PT	Each needs separate qualification
Renewal	No certificate, no expiry, nothing to renew. PSM obligations are continuous. The two recurring intervals that shape inspection demand are the process hazard analysis, which must be updated and revalidated at least every five years after completion of the initial analysis, and the compliance audit, where employers must certify at least every three years that they have evaluated compliance with the standard and must retain the two most recent compliance audit reports. Refresher training for employees operating a process is required at least every three years. Contract employer training records must be current for every person you put on site.	Applies to the personnel certification behind this method

Does OSHA PSM require a separate procedure for UT?

Yes. Every method in scope needs its own written procedure, approved by someone qualified in that method, describing technique, equipment, calibration, scanning or coverage, acceptance criteria and reporting. A single combined "NDT procedure" covering several methods is a finding under every regime that names procedures individually.

Who can approve a UT procedure under OSHA PSM?

A Level III qualified in UT. Because OSHA PSM accepts employer-based certification, that Level III may be contracted rather than employed — but their own qualification must cover UT, and an auditor will check that before accepting the signature.

What UT records does a OSHA PSM audit sample?

The approved procedure, the technician's UT certification on the date of work, and the equipment evidence — instrument, probes, cables, couplant, and the calibration and reference blocks used to set sensitivity. The auditor works backwards from a finished job, so every item has to reconcile with the report and its stated acceptance criteria.

What is the most common UT finding at audit?

An in-calibration instrument used with an unidentified or out-of-calibration reference block. It is a records failure rather than a technique failure — the examination was performed correctly and the evidence supporting it cannot be produced, which under OSHA PSM is recorded the same way as not having done the work.

Can a technician certified elsewhere perform UT under OSHA PSM?

Not automatically. Employer-based certification ends when the holder leaves, so the new employer must certify them under its own written practice. Prior training and documented experience transfer as evidence; the certificate itself does not.

What equipment evidence does UT need under OSHA PSM?

Calibration status traceable to the day of use, covering the instrument and its accessories — probes, cables, blocks and reference standards for ultrasonics; sources and densitometers for radiography. An in-calibration instrument with an out-of-calibration reference block fails the same way as an uncalibrated one.

How do UT requirements differ from the other methods in OSHA PSM?

Scope, qualification and evidence are method-specific, so the differences are real rather than administrative. OSHA PSM also covers UT thickness, PAUT, TOFD, RT, MT, and each carries its own procedure, its own personnel qualification and its own equipment evidence.

Personnel certification for UT

OSHA specifies no certification scheme at all — there is no OSHA NDT certificate and no OSHA-approved certifying body. Qualification enters indirectly, through the requirement that equipment comply with recognized and generally accepted good engineering practices and that inspection and testing procedures follow RAGAGEP. In practice that means API 510, 570 and 653, ASME Section V and ASNT SNT-TC-1A, because those are what the industry recognises. Employer-based certification is therefore fully accepted, and an outsourced Level III who writes the written practice, approves the procedures and certifies the examiners is a defensible RAGAGEP basis. What OSHA does require of you as a contract employer is a record containing the identity of each contract employee, the date of training, and the means used to verify that the employee understood the training.