Part 195 Audit Preparation for Inspection Companies
A Part 195 audit runs in 6 stages, beginning with operator's written qualification programme identifies covered tasks and ensures through evaluation that.. Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, US Department of Transportation; state agencies certified under 49 U.S.C.
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. 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 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.
| Stage | What happens | What it tests |
|---|---|---|
| Stage 1 | Operator's written qualification programme identifies covered tasks and ensures through evaluation that individuals performing them are qualified — §195. | Where the paperwork is tested against itself |
| Stage 2 | Nondestructive testing procedures and interpretation procedures submitted to and accepted by the operator before construction begins | Where the paperwork is tested against practice |
| Stage 3 | Technicians trained on those established procedures and on the equipment employed, with records held per person | Where the paperwork is tested against practice |
| Stage 4 | Production testing tracked two ways at once — per welder per welding day for the 10 percent minimum, and per. | Where the paperwork is tested against practice |
| Stage 5 | Impracticability decisions documented weld by weld and kept inside the 10 percent daily cap | Where the paperwork is tested against practice |
| Stage 6 | Records handed to the operator; PHMSA or the certified state agency audits the operator, and the operator audits you | Where the paperwork is tested against practice |
| 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. | Diarised from the certificate date, not the last audit |
How long does Part 195 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 hazardous liquid 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 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. 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 195 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 195 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 195 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 195 audit blind typically collect findings that a sampling exercise would have caught.
What the auditor asks to see
- 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 to close before the audit
- 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.