Part 195 Compliance for Inspection Service Providers
NDT contractors testing girth welds on crude oil, refined product, natural gas liquid, anhydrous ammonia and carbon dioxide pipelines, at pump stations and at breakout tankage, and firms supplying individuals for covered tasks under an operator's Subpart G 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.
If you run one procedure set across both gas and liquid pipeline work, this is the part that will catch you out, because its testing triggers are structured differently. Part 195 governs hazardous liquid and carbon dioxide pipelines, and its welding and testing rules are built on a different frame from Part 192. There is no class-location table. Instead, during construction at least 10 percent of the girth welds made by each welder and welding operator during each welding day must be nondestructively tested over the entire circumference of the weld. A defined list of locations requires all girth welds installed that day to be tested — near water bodies and offshore, in railroad or public road rights-of-way, at overhead road crossings and in tunnels, within incorporated subdivisions of a State government, and in populated areas — with impracticability permitted only if the untested welds stay within 10 percent of that day's total. Used pipe and tie-ins are 100 percent.
Source: 49 CFR Part 195 as published in the eCFR, text current to 1 August 2026, cross-checked against the 2024 annual CFR edition on govinfo.gov. Verified verbatim: §195.234(a) through (g) in full, including (b)(2) 'with personnel that have been trained in the established procedures and in the use of the equipment employed in the testing', (d) at least 10 percent of the girth welds made by each welder and welding operator during each welding day tested over the entire circumference, (e) the five 100-percent location categories and the 10-percent-of-the-day impracticability cap, (f) used pipe at 100 percent of old girth welds, and (g) tie-ins at 100 percent; §195.222(a) welder qualification under section 6, section 12, Appendix A or Appendix B of API Std 1104 or ASME BPVC Section IX; §195.228(a) and (b) visual inspection supplemented by nondestructive testing and acceptability under section 9 or Appendix A of API Std 1104, with Appendix A barred from accepting cracks; §195.230(a) removal of a weld with a crack more than 8 percent of the weld length; §195.3, which incorporates API Standard 1104, 21st edition, September 2013, including Errata 1 through 5, Addendum 1 (July 2014) and Addendum 2 (May 2016), IBR approved for §§195.214(a), 195.222(a) and (b) and 195.228(b), and ASME BPVC Section IX, 2007 edition, IBR approved for §195.222(a); §195.501 the four-part covered-task test; §195.505(a) through (i); and §195.507(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 hazardous liquid pipelines | The body that issues, audits and can withdraw |
| Applies to | NDT contractors testing girth welds on crude oil, refined product, natural gas liquid, anhydrous ammonia and carbon dioxide pipelines, at pump stations. | 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; the obligations run continuously. Operator qualification re-evaluation intervals are set by the operator in its own programme under §195.505(g). Records supporting an individual's current qualification must be maintained while that individual performs the covered task, and records of prior qualification and of individuals no longer performing covered tasks must be retained for five years under §195.507(b). Part 195 has no equivalent to Part 192's five-year welder-record rule for steel transmission pipe, so retention of welder qualification records is governed by the operator's own programme and by contract. | 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 | Crude oil pipelines, Refined product pipelines, NGL and LPG pipelines, Carbon dioxide pipelines, Anhydrous ammonia pipelines | Where this regime shows up in contracts |
Who does Part 195 apply to?
NDT contractors testing girth welds on crude oil, refined product, natural gas liquid, anhydrous ammonia and carbon dioxide pipelines, at pump stations and at breakout tankage, and firms supplying individuals for covered tasks under an operator's Subpart G qualification programme. If you run one procedure set across both gas and liquid pipeline work, this is the part that will catch you out, because its testing triggers are structured differently.
Can an outsourced Level III sign for Part 195 compliance?
Yes. Part 195 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 195 audit ask for?
Written set of procedures for nondestructive testing — §195.234(b)(1), Procedures for the proper interpretation of each weld inspection — §195.234(c), Training records showing each technician has been trained in the established procedures and in the use of the equipment employed in the testing — §195.234(b)(2), Daily record of girth welds tested per welder and per welding operator, evidencing the at-least-10-percent-per-welder-per-day requirement — §195.234(d), Impracticability determinations where a girth weld in a 100 percent location was not tested, with proof the day's untested welds stayed within 10 percent of the girth welds installed that day — §195.234(e). 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 195 renewed?
No certificate; the obligations run continuously. Operator qualification re-evaluation intervals are set by the operator in its own programme under §195.505(g). Records supporting an individual's current qualification must be maintained while that individual performs the covered task, and records of prior qualification and of individuals no longer performing covered tasks must be retained for five years under §195.507(b). Part 195 has no equivalent to Part 192's five-year welder-record rule for steel transmission pipe, so retention of welder qualification records is governed by the operator's own programme and by contract. 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 195 findings?
A single procedure set run across Part 192 and Part 195 work, so the Part 195 per-welder-per-day 10 percent requirement is tracked as if it were a class-location percentage, Impracticability invoked for a weld in a 100 percent location without documenting that the day's untested girth welds stayed within the 10 percent cap, Welds within a populated area or within the limits of an incorporated subdivision of a State government treated as ordinary line pipe because the §195.234(e) location list was never mapped to the route, Used pipe installed without nondestructively testing 100 percent of the old girth welds. 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 195 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 195
No certification scheme is named, and the wording is weaker than Part 192's. Section 195.234(b)(2) requires nondestructive testing to be performed with personnel that have been trained in the established procedures and in the use of the equipment employed in the testing — trained, where Part 192 says trained and qualified. Operators almost universally close that gap by contract, specifying ASNT SNT-TC-1A Level II. Employer-based certification is fully accepted and an outsourced Level III can own the written practice, write and approve the procedures and certify the technicians. Subpart G operator qualification applies to covered tasks — activities on a pipeline facility that are operations or maintenance tasks, performed as a requirement of Part 195, and that affect the operation or integrity of the pipeline — with the operator, not the rule, defining the list.
The audit sequence
- Operator's written qualification programme identifies covered tasks and ensures through evaluation that individuals performing them are qualified — §195.505(a) and (b)
- Nondestructive testing procedures and interpretation procedures submitted to and accepted by the operator before construction begins
- Technicians trained on those established procedures and on the equipment employed, with records held per person
- Production testing tracked two ways at once — per welder per welding day for the 10 percent minimum, and per location for the 100 percent categories
- Impracticability decisions documented weld by weld and kept inside the 10 percent daily cap
- Records handed to the operator; PHMSA or the certified state agency audits the operator, and the operator audits you
Documents an auditor asks for
- Written set of procedures for nondestructive testing — §195.234(b)(1)
- Procedures for the proper interpretation of each weld inspection — §195.234(c)
- Training records showing each technician has been trained in the established procedures and in the use of the equipment employed in the testing — §195.234(b)(2)
- Daily record of girth welds tested per welder and per welding operator, evidencing the at-least-10-percent-per-welder-per-day requirement — §195.234(d)
- Impracticability determinations where a girth weld in a 100 percent location was not tested, with proof the day's untested welds stayed within 10 percent of the girth welds installed that day — §195.234(e)
- Welding procedures qualified under §195.214 and welder or welding operator qualification records under §195.222
- Weld repair procedures qualified under §195.214 — §195.230(c)
- Operator qualification records identifying the qualified individuals, the covered tasks, the dates of current qualification and the qualification methods — §195.507(a)
- A controlled copy of API Std 1104, 21st edition, September 2013, including Errata 1 through 5, Addendum 1 (July 2014) and Addendum 2 (May 2016)
Findings firms get against Part 195
- A single procedure set run across Part 192 and Part 195 work, so the Part 195 per-welder-per-day 10 percent requirement is tracked as if it were a class-location percentage
- Impracticability invoked for a weld in a 100 percent location without documenting that the day's untested girth welds stayed within the 10 percent cap
- Welds within a populated area or within the limits of an incorporated subdivision of a State government treated as ordinary line pipe because the §195.234(e) location list was never mapped to the route
- Used pipe installed without nondestructively testing 100 percent of the old girth welds
- Technician training records written generically to the method rather than to the established procedure and the equipment employed in the testing
- Interpretation procedure not established separately from the examination procedure, as §195.234(c) requires
- Appendix A of API 1104 applied to accept a crack, which §195.228(b) does not permit
- Tie-in welds not identified as tie-ins in the record, so the 100 percent requirement under §195.234(g) cannot be demonstrated
Related: the Part 195 overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.