TTBS / OSH Act Compliance for Inspection Service Providers

NDT and inspection contractors serving the Point Lisas ammonia, methanol and iron estate, Atlantic LNG at Point Fortin, the Pointe-à-Pierre refinery complex, Heritage and Touchstone upstream, offshore platforms and the marine and dry-dock trade. Personnel are qualified under employer-based certification, so a contracted Level III can sign the written practice and administer examinations for the firm.

It binds any firm examining steam boilers or air pressure containers, and any firm claiming accredited inspection status locally. Trinidad and Tobago has no NDT-specific regime, and the gap itself is the commercially important fact. TTBS's accreditation arm, TTLABS, accredits laboratories to ISO/IEC 17025 and ISO 15189 only, so there is no domestic route to ISO/IEC 17020 inspection body accreditation; firms go to JANAAC in Jamaica or to a foreign accreditation body, which is how TTBS's own Implementation Division came to hold ISO/IEC 17020:2012 accreditation. What is legally binding sits elsewhere. Under the Occupational Safety and Health Act, Chap. 88:08, and the Boilers Regulations and Air Pressure Containers Regulations continued in force by section 98(2), steam boilers and air pressure containers must be thoroughly examined every twelve months by a person holding a Ministerial licence who is independent of the occupier, owner or hirer.

Source: Occupational Safety and Health Act, 2004 (Act No. 1 of 2004), Chap. 88:08, as amended by Act No. 3 of 2006, Laws of Trinidad and Tobago revised edition, read directly: the Occupational Safety and Health (Prescribed Forms) Order (GN 187-1948) items 18 Hoists or Lifts, 19 Steam Boilers and 20 Air Pressure Containers; the Boilers Regulations (GN 2-1949) including the annual and other examinations provisions, the boiler examiner licence and independence requirement, Gazette publication of licences and the list of boiler examiners on 1 January each year, and the twenty-one day report filing period; the Special Provisions for Safety in the Case of Air Pressure Containers Regulations (GN 3-1949) including the competent person requirement; all continued in force by section 98(2). The Act, except section 98, came into operation by Proclamation LN 48/2006 on 17 February 2006, with section 98 brought into force by 17 August 2007, repealing the Factories Ordinance (Ch. 30 No. 2), the Employment of Women (Night Work) Act and the Gas Cylinders (Use, Conveyance and Storage) Act. TTBS website and TTLABS accreditation page (accessed August 2026) confirming accreditation to ISO/IEC 17025 and ISO 15189, ILAC and IAAC membership, and that the TTBS Implementation Division operates as an ISO/IEC 17020:2012 inspection body accredited by JANAAC; JANAAC website confirming ISO/IEC 17020 among its scopes alongside ISO/IEC 17025, ISO/IEC 17021-1 and ISO 15189, and its IAAC MLA and ILAC MRA signatory status; CROSQ report of TTBS Certification Division accreditation by JANAAC to ISO/IEC 17021-1:2015 on 3 October 2022. The Standards Act number and chapter establishing TTBS could not be verified from a primary source in this session and is therefore not stated.

TTBS / OSH Act at a glance — authority, scope and what it demands
Item	What applies	Why it matters
Authority	Trinidad and Tobago Bureau of Standards (TTBS), including its laboratory accreditation arm TTLABS; the Occupational Safety and Health Authority and Agency; the Minister responsible, who licenses boiler examiners; the Ministry of Energy and Energy Industries for petroleum operations	The body that issues, audits and can withdraw
Applies to	NDT and inspection contractors serving the Point Lisas ammonia, methanol and iron estate, Atlantic LNG at Point Fortin, the Pointe-à-Pierre refinery complex,.	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	The statutory intervals are fixed and verifiable. Steam boilers and all fittings and attachments: thorough examination at least once in every period of twelve months and also after any extensive repairs, with the twelve months running from completion of the examination under normal steam pressure; the competent person may extend that period by not more than one month in an emergency where shutdown would cause serious loss or damage, after which the next examination must fall within the succeeding eleven months. Air pressure containers: thoroughly cleaned, examined and hydraulically tested every twelve months. Hoists and lifts: thoroughly examined every twelve months. Boiler examiners' licences and the examination fee schedule are published in the Gazette on 1 January each year.	Diarise from the certificate date, not from memory
Methods in scope	UT, PAUT, TOFD, RT, MT, PT	Each method needs its own procedure and qualified personnel
Industries	Ammonia, methanol and urea plants, LNG, Refining, Upstream oil and gas, onshore and offshore, Iron and steel	Where this regime shows up in contracts

Who does TTBS / OSH Act apply to?

NDT and inspection contractors serving the Point Lisas ammonia, methanol and iron estate, Atlantic LNG at Point Fortin, the Pointe-à-Pierre refinery complex, Heritage and Touchstone upstream, offshore platforms and the marine and dry-dock trade. It binds any firm examining steam boilers or air pressure containers, and any firm claiming accredited inspection status locally.

Can an outsourced Level III sign for TTBS / OSH Act compliance?

Yes. TTBS / OSH Act 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 TTBS / OSH Act audit ask for?

Written practice to ASNT SNT-TC-1A, signed and dated by the Level III, covering every method, level and technique the company offers, Personnel certification files with training records, documented experience, examination papers and grading, and current near-vision and colour differentiation records, Written NDT procedures approved by the Level III against the code the client cites: ASME BPVC Section V, API 510, API 570, API 653 or AWS D1.1, Boiler examiner's licence issued by the Minister, unsuspended and uncancelled, for anyone examining steam boilers, economisers, superheaters or air pressure containers, Prescribed Form No. 7, report of examination of the boiler when cold, signed by the person making the examination. 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 TTBS / OSH Act renewed?

The statutory intervals are fixed and verifiable. Steam boilers and all fittings and attachments: thorough examination at least once in every period of twelve months and also after any extensive repairs, with the twelve months running from completion of the examination under normal steam pressure; the competent person may extend that period by not more than one month in an emergency where shutdown would cause serious loss or damage, after which the next examination must fall within the succeeding eleven months. Air pressure containers: thoroughly cleaned, examined and hydraulically tested every twelve months. Hoists and lifts: thoroughly examined every twelve months. Boiler examiners' licences and the examination fee schedule are published in the Gazette on 1 January each year. 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 TTBS / OSH Act findings?

Boiler examination performed by an NDT contractor's Level II or Level III holding no Ministerial boiler examiner's licence, The examiner is on the occupier's payroll, or the owner's or hirer's, breaching the independence requirement the Boilers Regulations impose, Only the cold examination performed and the examination under normal steam pressure omitted, so the twelve-month clock never legitimately restarts, Forms 7 and 8 completed but not entered in or attached to the General Register within twenty-one days of the examination. 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 TTBS / OSH Act cover?

UT, PAUT, TOFD, RT, MT, PT, VT, ET. 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 TTBS / OSH Act

Employer-based certification is accepted for NDT, and is dominant. There is no local ISO 9712 certification body, and TTLABS does not accredit personnel certification bodies, so technicians hold employer certification written against ASNT SNT-TC-1A, the norm across the US-influenced petrochemical estate, or PCN and other ISO 9712 certificates issued in the UK. An outsourced Level III can write and sign the written practice, approve procedures and certify Level I and II staff. The statutory boiler and pressure-vessel examination is a separate and stricter matter: it requires a licence from the Minister plus personal independence from the equipment's owner, and no NDT certification substitutes for it.

The audit sequence

Establish the statutory route first: identify which items on the client's site are steam boilers, economisers, superheaters or air pressure containers under the Act, because those require a Ministerially licensed examiner, not merely a certified NDT technician
Confirm the examiner's licence is current and that he is not in the employ of the occupier of the premises, nor of the owner or hirer of the equipment
Carry out the examination in the prescribed order: the boiler cold, with interior and exterior prepared to the examiner's satisfaction, then under normal steam pressure
Report on Forms 7 and 8, signed by the person making the examination, and enter or attach them to the General Register within twenty-one days
Where the client requires third-party accreditation, apply to JANAAC or another recognised accreditation body for ISO/IEC 17020 accreditation, since TTLABS does not offer that scheme
Maintain the twelve-month cycle, dated from completion of the examination under normal steam pressure

Documents an auditor asks for

Written practice to ASNT SNT-TC-1A, signed and dated by the Level III, covering every method, level and technique the company offers
Personnel certification files with training records, documented experience, examination papers and grading, and current near-vision and colour differentiation records
Written NDT procedures approved by the Level III against the code the client cites: ASME BPVC Section V, API 510, API 570, API 653 or AWS D1.1
Boiler examiner's licence issued by the Minister, unsuspended and uncancelled, for anyone examining steam boilers, economisers, superheaters or air pressure containers
Prescribed Form No. 7, report of examination of the boiler when cold, signed by the person making the examination
Prescribed Form No. 8, report of examination of the boiler under normal steam pressure, signed by the person making the examination
General Register entries or attachments, filed within twenty-one days of each statutory examination
Hydraulic test certificate specifying the maximum permissible working pressure and the tests applied, for any new or previously used boiler before it is taken into use
Equipment calibration certificates and reference block traceability records
Radiation-protection authorisation for gamma radiography sources, operators and source transport

Findings firms get against TTBS / OSH Act

Boiler examination performed by an NDT contractor's Level II or Level III holding no Ministerial boiler examiner's licence
The examiner is on the occupier's payroll, or the owner's or hirer's, breaching the independence requirement the Boilers Regulations impose
Only the cold examination performed and the examination under normal steam pressure omitted, so the twelve-month clock never legitimately restarts
Forms 7 and 8 completed but not entered in or attached to the General Register within twenty-one days of the examination
A second-hand or relocated boiler taken back into use with no prior examination, hydraulic test and report
Air pressure containers treated as out of scope and inspected ad hoc, rather than on the twelve-month clean, examine and hydraulically test cycle
"Accredited" claimed on tender documents when the firm holds only ISO 9001 certification; TTLABS accredits laboratories, not inspection bodies, and the distinction is routinely blurred in local bids
Written practice imported unchanged from a US parent, listing methods and techniques the local branch has no certified Level III to support