Written Practice for Part 195
Part 195 names this requirement as "Written set of procedures for nondestructive testing — §195.234(b)(1)". The employer's Level III owns it, and a contracted Level III can author and sign it.
The finding auditors record against this document is: Technician training records written generically to the method rather than to the established procedure and the equipment employed in the testing. 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 |
|---|---|---|
| Regime | Transportation of Hazardous Liquids by Pipeline, 49 CFR Part 195 | Enforced by 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 |
| Document | Written Practice | the document that defines how the employer qualifies and certifies its own NDT personnel |
| Owner | the employer's Level III | The signature an auditor traces back |
| Where it is checked | Impracticability decisions documented weld by weld and kept inside the 10 percent daily cap; Records handed to the. | Usually against a sampled job, not in isolation |
| Common failure | 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 | The gap between the manual and the job file |
What must a written practice contain under Part 195?
It has to satisfy Part 195 as 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 enforces it: the document that defines how the employer qualifies and certifies its own NDT personnel. The test is not completeness on paper but traceability — an auditor picks a finished job and works backwards to this document, so anything it claims must be demonstrable on that job.
Who signs the written practice for Part 195?
The employer's Level III. Because this regime accepts employer-based certification, that role can be filled by a contracted Level III rather than a staff appointment, provided they are qualified in the methods they sign for.
How does a Part 195 auditor test this document?
By sampling. They take a completed job, find the technicians and equipment used, and trace each back through this document to the evidence behind it. A document that reads well but cannot survive that trace is the most common finding across every regime, not just this one.
How long must Part 195 records be kept?
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. Retention is set by the regime and by the client contract above it, and the longer of the two governs. Firms that set one retention period for everything and document it fare better at audit than firms tracking different periods per record type and losing track.
Does a generic template satisfy Part 195?
No. A downloaded template describes a generic firm, and the first question an auditor asks is whether the document describes THIS firm — its methods, its equipment, its people, its actual workflow. Templates are a starting structure; the content has to be the firm's own or the trace fails immediately.
What happens if this document is missing at a Part 195 audit?
It is a finding, and depending on the regime it can suspend the certificate rather than merely generate a corrective action. The related finding auditors record most often is: 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
Where this sits in the Part 195 evidence pack
- 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)
Personnel certification context
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.
Related: the Part 195 overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.