Written Practice for TTBS / OSH Act
TTBS / OSH Act names this requirement as "Written practice to ASNT SNT-TC-1A, signed and dated by the Level III, covering every method, level and technique the company offers". 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: Written practice imported unchanged from a US parent, listing methods and techniques the local branch has no certified Level III to support. 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.
| Item | What applies | Why it matters |
|---|---|---|
| Regime | Trinidad and Tobago Bureau of Standards (TTBS) and the Occupational Safety and Health Act, Chap. 88:08 | Enforced by 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 |
| 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 | Where the client requires third-party accreditation, apply to JANAAC or another recognised accreditation body for ISO/IEC 17020 accreditation,. | Usually against a sampled job, not in isolation |
| Common failure | Boiler examination performed by an NDT contractor's Level II or Level III holding no Ministerial boiler examiner's licence | The gap between the manual and the job file |
What must a written practice contain under TTBS / OSH Act?
It has to satisfy TTBS / OSH Act as 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 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 TTBS / OSH Act?
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 TTBS / OSH Act 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 TTBS / OSH Act records be kept?
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. 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 TTBS / OSH Act?
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 TTBS / OSH Act 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: Boiler examination performed by an NDT contractor's Level II or Level III holding no Ministerial boiler examiner's licence
Where this sits in the TTBS / OSH Act evidence pack
- 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
Personnel certification context
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.
Related: the TTBS / OSH Act overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.