Part 192 Audit Preparation for Inspection Companies
A Part 192 audit runs in 6 stages, beginning with operator identifies covered tasks in its written qualification programme and ensures through.. Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, US Department of Transportation; state agencies certified under 49 U.S.C.
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. The percentage of each day's field butt welds you test is fixed by class location, a sample of each welder's work must be tested each day, and the operator must keep the resulting record for the life of the pipeline. 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: 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.
| Stage | What happens | What it tests |
|---|---|---|
| Stage 1 | Operator identifies covered tasks in its written qualification programme and ensures through evaluation that individuals performing them are qualified —. | Where the paperwork is tested against itself |
| Stage 2 | Contractor's nondestructive testing procedures and interpretation procedures accepted by the operator before construction | Where the paperwork is tested against practice |
| Stage 3 | Technicians trained and qualified on those specific written procedures and that specific equipment, with records held per person per procedure | Where the paperwork is tested against practice |
| Stage 4 | Daily production testing at the class-location percentage required by §192. | Where the paperwork is tested against practice |
| Stage 5 | Records compiled by milepost, engineering station or geographic feature and handed to the operator, who must retain them for the. | Where the paperwork is tested against practice |
| Stage 6 | PHMSA or the certified state agency inspects the operator; the operator's audit of your records is where the requirement is. | Where the paperwork is tested against practice |
| 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. | Diarised from the certificate date, not the last audit |
How long does Part 192 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 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 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 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. 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 Part 192 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 Part 192 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 Part 192 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 Part 192 audit blind typically collect findings that a sampling exercise would have caught.
What the auditor asks to see
- 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 to close before the audit
- 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.