Maritime NDT consulting that survives a class service-supplier audit

Two IACS requirements govern maritime NDT, and yards apply the wrong one

UR W35 covers firms providing NDT and advanced NDT on the new construction of ships and offshore structures subject to classification. Its scope reaches independent NDT companies and the internal NDT departments of shipyards and hull block fabricators equally, across welding of integrated components, independent fuel or cargo tanks including type A, B and C tanks, hull structure as defined in UR Z23, and rudders of welded construction. W35 §1.1(iii) then states plainly that these suppliers are not included in the scope of UR Z17.

UR Z17 Annex 1 Section 1 covers something else entirely: thickness measurement of structural material on ships and mobile offshore units in service. A yard that builds and repairs sits under both, on two approval clocks and two personnel standards. The failure we see most often is a repair yard holding a Z17 thickness measurement approval and assuming it covers weld NDT on a newbuild block. It covers none of it, and the remedy — building a written practice and a Level 3 record from nothing — takes months, not weeks.

The written practice is the first document a surveyor asks for

W35 §2.1 lists what must be available to the Society on request. For companies running an in-house certification scheme, that list names a written practice developed in accordance with a recognised standard such as ASNT SNT-TC-1A 2020 or ANSI/ASNT CP-189 2020. W35 §2.3 then sets the bar the practice has to clear: employer-based qualification may be accepted if the Society reviews the written practice and finds it acceptable, and the practice shall, excepting the impartiality requirements of a certification body, generally comply with ISO 9712:2021.

That one sentence is where most US shipyard NDT departments fail. A written practice cloned from a template has never been mapped clause by clause against ISO 9712:2021, has never been submitted for Society review, and names no responsible Level III — the same defect that dominates aerospace findings under NAS 410 and Nadcap AC7114. We rewrite the practice against both standards, produce the gap analysis the surveyor asks for, and name the accountable Level III inside the document rather than in an org chart.

How UR W35 treats an outsourced Level 3

W35 §2.4 states that the supplier shall normally employ, on a full-time basis, a Level 3 supervisor certified in the applicable methods. It then opens two doors. Where the supplier does not hold a Level 3 in every method practised, it may employ an external Level 3 certified by an accredited certification body in the methods not covered. Alternatively, by agreement with the Society, it may appoint a full-time internal supervisor certified to a minimum of Level 2 and contract Level 3 services from outside for procedure development, procedure approval, consultancy and review.

Both doors carry the same condition: the external Level 3 shall be certified by an accredited certification body in all applicable methods. An employer-based Level 3 certificate does not satisfy the external route. W35 §2.3 closes the other shortcut — an employer-based Level 3 must come through the examination method detailed in the written practice, and direct appointment without examination is not permissible. How examinations are authored, graded and retained is set out at /consulting/ndt-level-3-exam-oversight.

Where class NDT audit findings actually land

Findings concentrate on records, not on technique. W35 §2.4(e) requires the supervisor to re-evaluate the qualification of operators annually on behalf of the supplier; almost no yard evidences it, because it gets folded into the annual eye test and the two are treated as one. W35 §2.2 requires a documented procedure for testing operators' visual acuity, and yards hold optometrist slips with no procedure behind them. W35 §2.1 requires a written statement issued by the employer, based on the scope of certification, authorising each operator and supervisor to carry out specified tasks; the certificates are on file and the authorisation statements are not.

The remainder cluster on traceability. W35 §2.2 requires an order reference system making every engagement traceable to when, who and where the test was carried out, plus a declared retention time for records. W35 §2.9 requires reports signed by personnel of the appropriate certification level with signatory status defined in the quality management system, which almost no quality manual defines. Under UR Z17 §5.2.2 operators need a minimum of one year of tutored on-the-job training and §5.2.3 puts the responsible supervisor at two years of experience — both asserted in CVs and logged nowhere.

Thickness measurement runs on a three-year clock and a signature per job

UR Z17 §6.2 renews a service supplier certificate at intervals not exceeding five years, then carves out firms engaged in thickness measurements at intervals not exceeding three years. Diarising the short clock against the long one is how an approval lapses mid-survey. Annex 1 §1.2 puts the responsible supervisor at ISO 9712 Level II and §1.3 puts operators at Level I with documented knowledge of ship structures sufficient to select a representative position for each measurement. That is a knowledge record, not a UT certificate, and it is the item most often missing.

Annex 1 §1.5 requires documented work procedures covering inspection preparation, selection and identification of test locations, surface preparation, protective coating preservation, calibration checks, and report preparation and content. Annex 1 §1.4 requires pulsed-echo multiple-echo instruments on coated surfaces. Annex 1 §1.6 ties reporting to the UR Z7 and UR Z10 series, §1.7 requires the attending surveyor's signature verifying each separate job, and Z17 §5.2.11 requires the report to include a copy of the Certificate of Approval. Reports missing either signature or certificate are rejected on receipt.

Drydock and in-water survey windows compress the documentation problem

SOLAS Chapter I Regulation 10 requires a minimum of two inspections of the outside of the ship's bottom during any five-year period, with the interval between any two such inspections not exceeding 36 months. That fixes the survey window, and the window fixes the day your qualification records are examined. Bulk carriers and oil tankers add the 2011 ESP Code regime adopted by IMO Resolution A.1049(27), which drives close-up survey and thickness measurement scope and therefore the volume of records that must be defensible on the same day.

Where an in-water survey replaces a docking survey, UR Z17 Annex 1 Section 3 applies and adds its own thresholds. A diver carrying out inspection needs at least one year as an assistant diver including participation in a minimum of ten different assignments. An ROV operator needs at least one year of ROV inspection work on vessels, and supervisors two years in their respective roles. Annex 1 §3.8 again requires the attending surveyor's signature on each separate job, and underwater thickness measurement requires the separate Annex 1 Section 1 approval on top.

Naval and government work certifies by examination only

US naval shipbuilding and repair runs on NAVSEA T9074-AS-GIB-010/271, which covers requirements for conducting NDT to detect discontinuities in metals and sets the minimum requirements to qualify NDT personnel, procedures and equipment. Its model, like SNT-TC-1A's, requires Level II and Level III personnel to be certified and recertified by examination rather than by point systems, accumulated experience or previously held certificates. Commercial recertification-by-points habits carried into naval work are the finding an auditor writes first.

ASNT's Naval Shipbuilders NDT Level III Specific examination aligns to that publication and is not open to the general public: eligibility runs through prime or sub-tier NDT Level III test examiner contracts with Huntington Ingalls Newport News or General Dynamics Electric Boat, applied for through the naval shipyard administrator. Yards intending to bid naval work need that route mapped before award rather than after. What an outside Level III can and cannot sign for you is set out at /consulting/outside-ndt-level-3-can-and-cannot-do.

The documentation set we build and keep current

The package is specific: a written practice mapped against ISO 9712:2021 and SNT-TC-1A 2020; method procedures written, verified and approved by a Level 3 with acceptance criteria drawn from the Society Rules per W35 §2.7; employer authorisation statements per §2.1; the annual operator re-evaluation record per §2.4(e); the visual acuity procedure and its results per §2.2; an equipment register carrying maintenance, calibration and verification detail per §2.6 and Z17 §5.2.5, including hired equipment; personnel files carrying the education, training and experience Z17 §5.2.4 names; and subcontractor flow-down per §2.8, since subcontractors meet the same requirements.

Approval is what the documents buy; retention is what keeps it. Z17 §8.2 lists the grounds for cancelling an approval: service improperly carried out or improperly reported, deficiencies found by a surveyor without corrective action, alteration of the quality system without written notification, a missed intermediate audit, wilful acts or omissions, and deliberate misrepresentation. Four of those six are documentation failures rather than technical ones. The shape of an ongoing retainer is described at /consulting/ndt-consulting-level-iii.

Engaging an outsourced Level III without breaking the approval

W35 §2.4 gives the external Level 3 a defined job: procedure development, procedure approval, consultancy and review. W35 §2.7 requires procedures to be written, verified and approved by that Level 3, with all procedures acceptable to the Society and documented so the testing performed can be retraced or repeated later. The supervisor role stays inside your company — validating instructions and procedures established and reviewed by Level 3 personnel, reviewing reports, supervising all tasks at all levels, inspecting equipment and calibration, and running the annual operator re-evaluation.

That split defines the engagement cleanly. We hold the Level III scope: written practice, method procedures and technique sheets, examination authorship and grading with masters and marked papers retained, technique qualification, and the audit-response file. Your supervisor holds daily verification and the annual re-evaluation, working to record formats we design. The boundary between qualifying personnel and certifying them is set out at /consulting/outside-ndt-level-3-can-and-cannot-do, the aerospace analogue of a named accountable Level 3 at /consulting/nas-410-responsible-level-3, and Nadcap's equivalent audit at /consulting/nadcap-ac7114-audit-readiness.

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