Running One NDT Program Across Several Branches
Run one written practice with site annexes, not one practice per branch. A single Level III covers every location when the practice names them and defines how examinations, records and audits reach each one. Auditors sample across sites, the square root of the site count on an initial accredited audit, so a divergent branch surfaces fast.
Divergence in a multi-branch inspection company is silent and cumulative. A second office opens, a local Level II starts examining candidates because head office is three states away, someone adapts a procedure for a local client, a branch manager sets a three-year recertification interval because that is what their previous employer used. Two years later the company has one legal entity, one set of certificates on the wall and four incompatible programmes underneath. It surfaces the first time a technician transfers between branches and their file will not reconcile, or the first time an auditor samples two sites and compares. The fix is structural: one written practice approved by one Level III, site annexes carrying only what is genuinely local, one examination bank, one records register with local originals, and a defined internal audit cycle that visits every branch. Harmonisation is a documents-and-records exercise, not a reorganisation.
Source: ASNT Recommended Practice No. SNT-TC-1A (2024 edition with addendum); ANSI/ASNT CP-189 (2020); IAF MD 1:2018, Mandatory Document for the Certification of Multiple Sites Based on Sampling; Nadcap AC7114 audit criteria and PRI eAuditNet facility registration rules; 10 CFR 150.20 and NRC Form 241 reciprocity requirements.
| Dimension | One practice with site annexes | Separate practice per site | How it reads at audit |
|---|---|---|---|
| Approval | One Level III signature; annexes list the scope of each named site | One signature per site, often several Level IIIs with different interpretations | One approval chain is verified in minutes; several invite comparison |
| Examinations | One question bank, one pass mark, one grading standard | Divergent banks; the same job title certified against different exams | Comparing two sites' exam records for one job title is the standard cross-site test |
| Recertification | One interval company-wide, one diary | Intervals drift between branches; transferring technicians fall between them | The file of a technician who moved branches is a favourite sample |
| Records | Central register, originals or certified scans held locally | Local only; head office cannot answer a question about a branch | A register that answers in minutes reads as control; a phone call to a branch does not |
| Adding a site | New annex, qualify local personnel, update the register | New practice, new approval cycle, new drift | An annex demonstrates a system that scaled; a fifth practice demonstrates four precedents |
| Acquisition | Acquired site becomes an annex after a documented gap assessment | Two live programmes coexist indefinitely under one company name | Two live written practices in one legal entity is a finding waiting to be written |
The divergence you already have and cannot see
Multi-site divergence never arrives as a decision. It arrives as a series of reasonable local accommodations. The Odessa branch runs its own practical examinations because flying a candidate to Houston costs two billable days. The new office adapts a UT procedure because their refinery client references a different acceptance clause. A branch manager arriving from a previous employer sets a three-year recertification interval out of habit. Each choice is defensible on its own and the aggregate is a company with four programmes.
It surfaces in two places. The first is an internal transfer: a Level II moves from one branch to another and their certification file will not reconcile with the receiving branch's practice, because the training hours, the examination content or the interval differ. The second is an auditor who samples two sites and compares the same job title. Both discoveries happen at the worst possible moment, and both are cheap to prevent and expensive to explain.
The reason it is unserved is that harmonisation looks like an internal tidying exercise with no revenue attached. It is actually a growth constraint. A contractor with divergent branches cannot bid national framework agreements credibly, cannot move crews between regions without a paperwork exercise, and cannot integrate an acquisition without inheriting a fourth programme. The tidying is what makes the next contract and the next acquisition possible.
One practice, with annexes that carry only what is genuinely local
SNT-TC-1A places responsibility for qualification and certification on the employer, and the employer is the legal entity rather than the building. One written practice, approved by one Level III, therefore covers every branch the company operates. That is the structure to aim at, and it holds whether the company has two offices or twelve. The practice defines methods, levels, training hours, examination structure, pass marks, recertification interval, vision requirements and records.
The annex carries the short list of things that are genuinely site-specific: the methods and levels certified at that location, the equipment held there, the client codes and specifications worked to locally, the named site responsible person, the examination arrangements including proctor and specimens, and where the local original records sit. An annex is two or three pages. Anything longer means requirements are drifting into the annex that belong in the practice.
The test for whether something belongs in the annex is simple: would a technician transferring between branches have to be requalified because of it? If yes, it belongs in the practice and must be identical everywhere. If no, the annex is the right home. Applying that test to an existing multi-branch programme is the first hour of written practice development work on a harmonisation project, and it usually shortens the document set considerably.
How one Level III legitimately covers five branches
The Level III's authority is over documents and examinations, not over geography, which is why one person covers multiple sites without living on a plane. They approve the practice and every procedure. They own the single question bank and the grading keys. They appoint site examination proctors in writing, against written proctoring instructions, and SNT-TC-1A paragraph 8.1.1 still applies at every site: no candidate is examined by themselves or by a subordinate, which frequently means the proctor comes from a different branch.
They review certification packages before the employer signs. This is the control that holds the whole structure together. A site assembles the training record, the experience log, the examination results and the vision record; the Level III reviews the package against the practice and signs as qualifying authority; the employer's authorised signatory certifies. Reviewing packages remotely is entirely workable and it is where divergence gets caught before it reaches a certificate.
They visit. A defined internal audit cycle that reaches every site on a fixed frequency is the part firms skip, and it is the part that keeps the other controls honest. Where a company's growth has outrun one person's capacity, ongoing ASNT Level III consulting support supplements rather than replaces the designated Level III, taking procedure work and site audits while approval authority stays in one place.
Making the examination the same in Houston and Odessa
Written examinations harmonise easily and nobody argues about them: one bank, one specific examination per method and level, one pass mark, controlled distribution to proctors, grading keys held centrally. The failure mode is a branch that quietly built its own bank when head office was slow to answer, and the remedy is to retire the local bank and re-examine only where the local questions cannot be shown to meet the practice's content requirements.
Practical examinations are where cross-site equivalence actually breaks. A practical is only as consistent as its specimens, and branches left to source their own end up examining candidates on different flaw types, different thicknesses and different difficulty. Control the specimen set: hold a master set, replicate it with documented equivalence, or rotate a travelling set on a schedule. Record the specimen identifiers on the examination record so equivalence is provable rather than asserted.
Vision screening is the third leg and the easiest to standardise, so standardise it once and stop revisiting it. SNT-TC-1A recommends near-vision acuity to Jaeger Number 2 or equivalent at not less than 12 inches, annually, with colour-contrast differentiation at initial certification and five-year intervals. Under ANSI/ASNT CP-189 the near-vision requirement tightens to Jaeger Number 1. Pick one standard for the whole company and hold every site to it.
Central register, local originals: the records split that survives an audit
The two failure patterns are mirror images. Fully centralised records mean a site audit stalls while somebody in head office emails a scan. Fully local records mean nobody can answer a company-level question, including how many Level II UT technicians the company has, or how many recertifications fall due next quarter. Both are common in firms between three and ten branches, and both read badly to an auditor who expects the company to know what it holds.
The split that works: a central register holding the searchable data for every certified individual, being name, site, methods, levels, certification dates, recertification due dates and vision dates; and the original certification file, or a certified scan, held where the technician works. The register is authoritative for dates and levels. The local file is the evidence pack behind the register entry, and it is what gets sampled during a site audit.
At scale that register stops being a spreadsheet. Once a company passes roughly a hundred certified individuals across three or more sites, expiry tracking, equipment calibration schedules and site scope all need to sit in one system with alerting, which is the argument for an NDT-configured ERP rather than a shared drive. The trigger is not headcount alone; it is headcount multiplied by the number of sites that have to be reconciled.
What an auditor actually samples across sites
For accredited management-system certification, the sampling is arithmetic rather than judgement. IAF MD 1:2018 sets the initial-audit sample at the square root of the number of sites, rounded up. Annual surveillance is 0.6 times the square root, rounded up. Recertification returns to the initial sample size, reducible to 0.8 times the square root where the management system has proved effective across the cycle. Nine sites means three on initial certification and two at surveillance.
Client auditors sample differently and less predictably. They visit the site where their work is performed, and they compare it against whatever the company says applies everywhere. That comparison is the exposure: a client auditor reading a company-wide written practice and then finding a site running a three-year recertification interval against the practice's five, or a locally written procedure with no Level III signature, has found a systemic issue rather than a local one.
The samples that expose divergence fastest are the same three every time. The file of a technician who transferred between branches. The same job title and method certified at two sites, compared line by line. A locally revised procedure compared against the controlled master. Run those three yourself, across your own sites, in a structured NDT program audit and gap assessment before anyone else runs them for you.
The accreditations and licences that do not travel
Harmonising the written practice does not harmonise everything else, and the distinction matters commercially. Nadcap NDT accreditation is granted against a facility: each facility carries one address in PRI's eAuditNet, and every location seeking accreditation is audited for it. A harmonised practice makes those audits easier and shorter because the underlying system is identical, and it does not make one site's accreditation extend to another.
Radiography carries its own geography. A radioactive materials licence is issued by the NRC or by an Agreement State and names locations and people. Working outside the issuing jurisdiction runs through reciprocity: under 10 CFR 150.20 an Agreement State licensee files NRC Form 241 at least three days before the first activity in a calendar year and is limited to 180 days of such activity per calendar year. Track that day count centrally, because branches individually will not.
Laboratory accreditation to ISO/IEC 17025 attaches to the location and its defined scope as well. The pattern across all three is the same: personnel qualification harmonises company-wide, while facility accreditations and radiation licences remain local instruments. Companies that assume otherwise discover it when a client asks a newly opened branch for the accreditation certificate the head office holds, and there is nothing to send.
The acquisition case: merging two incompatible programmes
Acquisitions are where multi-site divergence arrives all at once, fully formed and already certified. Two written practices, two Level IIIs with different interpretations, two examination banks, two recertification intervals, and frequently one company on SNT-TC-1A and the other on CP-189. The temptation is to leave both running until things settle, and that is the decision that turns a six-week integration into a two-year one, because divergence compounds while nobody is looking.
The sequence is a documented gap assessment first, comparing both practices requirement by requirement: methods and levels, training hours, examination structure and pass marks, recertification interval, vision standard, records content and retention. Then one practice is written, keeping the stricter requirement at every point of difference. Where one company works to CP-189 and the other to SNT-TC-1A, CP-189 sets the floor, and that decision drives the Level III qualification requirement for the merged entity.
Certifications issued under the retired practice stay valid; they were the employer's certifications and the merged employer inherits them. The surviving Level III reviews the acquired population against the new practice, records acceptance, and remediates only the individuals whose files fail to reconcile. Re-examining an entire acquired workforce as a matter of policy destroys goodwill with the very technicians the acquisition was meant to secure, and it produces no compliance benefit.
A harmonisation sequence that does not stop production
Weeks one to three: measure the divergence. Collect every written practice, procedure and examination bank in the company, and pull one certification file per method per site. Compare training hours, examination content, pass marks, recertification intervals, vision standards and records content across sites. Most firms find three or four material differences and a dozen cosmetic ones, and knowing which is which is the whole value of the exercise.
Weeks four to eight: write the single practice, keeping the stricter requirement at every difference, and draft a two-page annex per site. Consolidate the examination banks into one, retire the locals, and settle the practical specimen question with a master set or documented equivalents. Stand up the central register and load it from the local files. Nothing about this work interrupts inspection production, because existing certifications stay valid throughout.
Weeks nine to twelve: transition and prove it. Approve the practice, have the Level III record acceptance of the existing certified population, migrate anyone whose file fails to reconcile onto a remediation plan, and run an internal cross-site audit sampling exactly the way an external auditor would. To scope harmonisation across your own branches, tell us how many sites and practices you are running. Demo and quote on request.
Can one written practice legitimately cover branches in several states?
Yes. SNT-TC-1A makes the employer responsible for qualification and certification, and the employer is the legal entity rather than the building. One practice, approved by the employer's Level III, covers every location the company operates. Site annexes carry only genuinely local content: the equipment held there, the client codes worked to, the local examination arrangements and the named responsible person.
How does one Level III cover five branches without being present at each?
By controlling the documents and the examinations rather than the geography. The Level III approves the practice and every procedure, owns the single question bank and the grading keys, appoints and audits site examination proctors, reviews certification packages before the employer signs, and visits each site on a defined internal audit cycle. Presence at the examination table is delegated; approval authority is not.
What makes a certification examination consistent across locations?
One question bank, one pass mark, one specific-examination content per method and level, one practical examination checklist with the same specimens or equivalents at each site, and proctors appointed by the Level III against written instructions. Ship or replicate the practical specimens rather than letting each branch source its own, because specimen difference is where cross-site examination equivalence quietly breaks.
Should certification records be held centrally or at the branch?
Both, with defined roles. A central register holds the searchable data: name, methods, levels, certification dates, recertification due dates, vision dates, site. Originals or certified scans sit where the technician works, so a site audit is answered on site. The register is the single source of truth for dates and levels; the local file is the evidence pack behind it.
How many sites does an auditor sample on a multi-site certification?
For accredited management-system certification, IAF MD 1:2018 sets the initial-audit sample at the square root of the number of sites, rounded up, with annual surveillance at 0.6 times that square root and recertification at the initial size, reducible to 0.8 times the square root where the system has proved effective. Nine sites therefore means three on initial certification.
Two companies merged. Do we have to rewrite both written practices?
You write one and retire the other. Run a documented gap assessment against both, keep the stricter requirement wherever they differ, and issue a single practice with an annex for each site. Certifications already issued under the retired practice stay valid, and the surviving Level III records acceptance of that population. Nobody is re-examined without a specific reconciliation failure.