Part 192 Compliance for Inspection Service Providers
NDT contractors radiographing or ultrasonically testing girth welds on gas transmission, gathering and distribution pipelines and at compressor stations and LNG facilities, and firms supplying individuals to perform covered tasks under an operator's qualification programme. Personnel are qualified under employer-based certification, so a contracted Level III can sign the written practice and administer examinations for the firm.
The regulation binds the operator, not you directly — but the operator can only demonstrate compliance through your procedures, your technicians' training records and your daily test records, so it is enforced against you contractually. Part 192 writes your job description even though it regulates the operator. Section 192.243 requires nondestructive testing of welds to be performed in accordance with written procedures and by persons who have been trained and qualified in the established procedures and with the equipment employed in testing — that is the entire personnel requirement, and it names no certification scheme. Separate interpretation procedures must be established for each test. Weld acceptability is judged under 192.241(c) against section 9 or Appendix A of API Std 1104, and Appendix A may not be used to accept cracks.
Source: 49 CFR Part 192 as published in the eCFR, text current to 1 August 2026, cross-checked against the 2024 annual CFR edition on govinfo.gov. Verified verbatim: §192.7, which incorporates API Standard 1104, Welding of Pipelines and Related Facilities, 21st edition, September 2013, including Errata 1 through 5 (April 2014 through September 2018), Addendum 1 (2014) and Addendum 2 (2016), IBR approved for §§192.225(a), 192.227(a), 192.229(b) and (c), 192.241(c) and Appendix B to Part 192 — and which incorporates ASME BPVC Section IX, 2007 edition, but NOT ASME Section V, so Section V is not a federal requirement for Part 192 pipeline NDT; §192.227(a) welder qualification routes and (c) five-year record retention for steel transmission pipe installed after 1 July 2021; §192.241(b) the 20 percent SMYS trigger and the visual-inspection exceptions, and (c) acceptability under section 9 or Appendix A of API Std 1104 with Appendix A barred from accepting cracks; §192.243(a) through (f) in full, including the Class 1 at least 10 percent, Class 2 at least 15 percent, Class 3 and 4 plus major or navigable river crossings, offshore and railroad or public highway rights-of-way including tunnels, bridges and overhead road crossings at 100 percent unless impracticable in which case at least 90 percent, and tie-ins at 100 percent; §192.245(a) removal of a weld with a crack more than 8 percent of the weld length; §192.801 the four-part covered-task test; §192.805(a) through (i); and §192.807(a) and (b). Accessed 21 August 2026.
| Item | What applies | Why it matters |
|---|---|---|
| Authority | Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, US Department of Transportation; state agencies certified under 49 U.S.C. Chapter 601 inspect intrastate pipelines | The body that issues, audits and can withdraw |
| Applies to | NDT contractors radiographing or ultrasonically testing girth welds on gas transmission, gathering and distribution pipelines and at compressor stations and LNG facilities,. | 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 | No certificate exists to renew; the obligations are continuous. Re-evaluation intervals for operator qualification are set by the operator in its own programme under §192.805(g), not by the rule, so they vary by operator and by task. Records supporting an individual's current qualification must be maintained while that individual performs the covered task; records of prior qualification and of individuals no longer performing covered tasks must be retained for five years under §192.807(b). Welder qualification records for steel transmission pipe installed after 1 July 2021 are retained a minimum of five years following construction. The nondestructive testing record itself is retained for the life of the pipeline. | Diarise from the certificate date, not from memory |
| Methods in scope | RT, AUT, PAUT, UT, MT, PT | Each method needs its own procedure and qualified personnel |
| Industries | Gas transmission pipelines, Gas gathering systems, Gas distribution, LNG facilities, Compressor stations | Where this regime shows up in contracts |
Who does Part 192 apply to?
NDT contractors radiographing or ultrasonically testing girth welds on gas transmission, gathering and distribution pipelines and at compressor stations and LNG facilities, and firms supplying individuals to perform covered tasks under an operator's qualification programme. The regulation binds the operator, not you directly — but the operator can only demonstrate compliance through your procedures, your technicians' training records and your daily test records, so it is enforced against you contractually.
Can an outsourced Level III sign for Part 192 compliance?
Yes. Part 192 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 Part 192 audit ask for?
Written nondestructive testing procedures for each method and technique — §192.243(b)(1), Procedures for the proper interpretation of each nondestructive test of a weld — §192.243(c), Evidence that each technician has been trained and qualified in the established procedures and with the equipment employed in testing — §192.243(b)(2), Record showing, by milepost, engineering station or geographic feature, the number of girth welds made, the number nondestructively tested, the number rejected and the disposition of the rejects — §192.243(f), Welding procedure specifications qualified under §192.225 and welder or welding operator qualification records under §192.227. 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 Part 192 renewed?
No certificate exists to renew; the obligations are continuous. Re-evaluation intervals for operator qualification are set by the operator in its own programme under §192.805(g), not by the rule, so they vary by operator and by task. Records supporting an individual's current qualification must be maintained while that individual performs the covered task; records of prior qualification and of individuals no longer performing covered tasks must be retained for five years under §192.807(b). Welder qualification records for steel transmission pipe installed after 1 July 2021 are retained a minimum of five years following construction. The nondestructive testing record itself is retained for the life of the pipeline. 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 Part 192 findings?
Nondestructive testing procedure written to the API 1104 22nd edition when the federally enforceable edition remains the 21st, Technician holds an SNT-TC-1A certificate but has no record of training on the specific written procedure and the specific equipment, which is what §192.243(b)(2) actually requires, No separate procedure established for the interpretation of each test, in addition to the examination procedure — §192.243(c) is a distinct requirement, Daily record kept by weld number only, without the milepost, engineering station or geographic feature §192.243(f) requires. 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 Part 192 cover?
RT, AUT, PAUT, UT, MT, PT, 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 Part 192
Neither employer-based nor central certification is mandated by the rule. Section 192.243(b)(2) requires only persons who have been trained and qualified in the established procedures and with the equipment employed in testing. In practice operators specify ASNT SNT-TC-1A Level II as their contractual acceptance criterion, and an outsourced Level III writing the written practice and certifying technicians satisfies that specification — but what is federally enforceable is procedure-specific and equipment-specific training, evidenced per technician per procedure. Separately, Subpart N operator qualification applies to covered tasks, defined as activities performed on a pipeline facility that are operations or maintenance tasks, performed as a requirement of Part 192, and that affect the operation or integrity of the pipeline. The operator identifies them, so ask which of your scope items are on the operator's covered-task list rather than assuming.
The audit sequence
- Operator identifies covered tasks in its written qualification programme and ensures through evaluation that individuals performing them are qualified — §192.805(a) and (b)
- Contractor's nondestructive testing procedures and interpretation procedures accepted by the operator before construction
- Technicians trained and qualified on those specific written procedures and that specific equipment, with records held per person per procedure
- Daily production testing at the class-location percentage required by §192.243(d), plus a sample of each welder's or welding operator's work for each day under §192.243(e)
- Records compiled by milepost, engineering station or geographic feature and handed to the operator, who must retain them for the life of the pipeline
- PHMSA or the certified state agency inspects the operator; the operator's audit of your records is where the requirement is actually tested
Documents an auditor asks for
- Written nondestructive testing procedures for each method and technique — §192.243(b)(1)
- Procedures for the proper interpretation of each nondestructive test of a weld — §192.243(c)
- Evidence that each technician has been trained and qualified in the established procedures and with the equipment employed in testing — §192.243(b)(2)
- Record showing, by milepost, engineering station or geographic feature, the number of girth welds made, the number nondestructively tested, the number rejected and the disposition of the rejects — §192.243(f)
- Welding procedure specifications qualified under §192.225 and welder or welding operator qualification records under §192.227
- Welder qualification records retained a minimum of five years following construction for steel transmission pipe installed after 1 July 2021 — §192.227(c)
- Weld repair procedures qualified under §192.225 — §192.245(c)
- Operator qualification records identifying the qualified individual, the covered tasks he is qualified to perform, the dates of current qualification and the qualification methods — §192.807(a)
- A controlled copy of API Std 1104, 21st edition, September 2013, including Errata 1 through 5 and Addenda 1 and 2 — the edition incorporated by reference
Findings firms get against Part 192
- Nondestructive testing procedure written to the API 1104 22nd edition when the federally enforceable edition remains the 21st
- Technician holds an SNT-TC-1A certificate but has no record of training on the specific written procedure and the specific equipment, which is what §192.243(b)(2) actually requires
- No separate procedure established for the interpretation of each test, in addition to the examination procedure — §192.243(c) is a distinct requirement
- Daily record kept by weld number only, without the milepost, engineering station or geographic feature §192.243(f) requires
- Class 3 or Class 4 locations, major river crossings, offshore, or railroad and public highway rights-of-way tested at less than 100 percent without the impracticability determination the rule requires for each untested girth weld
- No sample taken of an individual welder's or welding operator's work on a day that individual produced welds
- Appendix A of API 1104 used to accept a crack, which §192.241(c) expressly forbids
- Disposition of rejected welds not carried through into the record, so repairs cannot be tied back to the original rejection
Related: the Part 192 overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.