The Written Practice an LNG Audit Actually Tests
The written practice is the employer document that controls every NDT certification issued. On LNG work it is audited harder than anywhere else, because a federal facility rule, a process safety obligation and an international EPC specification all point at the same file. An auditor does not read the practice. He samples a certification file and traces it back.
Almost every written practice in circulation is adequate on the page and indefensible in the file. It quotes ASNT SNT-TC-1A faithfully, lists methods and levels, and then loses the argument at the first personnel record an auditor opens, because the record was made under a different revision, or the examination was graded by someone the practice never authorised, or the technician was hired mid-project with a certificate from a previous employer that nobody re-examined. LNG makes each of those gaps more expensive. Commissioning brings a surge of travelling technicians, an EPC specification often invokes ISO 9712 third-party certification alongside the employer-based ASNT route, and PHMSA can ask what qualified the person who examined a containment weld. The practice has to answer all of that from records that were created correctly on the day, because nothing about it can be reconstructed honestly afterwards.
Source: Written against ASNT SNT-TC-1A and ANSI/ASNT CP-189, with ASNT CP-105 topical outlines; ISO 9712 where an EPC specification invokes third-party certification; ASME Section V Article 1 for the personnel qualification the examination codes rely on; 49 CFR Part 193 and NFPA 59A for LNG facility obligations; OSHA 29 CFR 1910.119 for mechanical integrity; and ISO 9001 and ISO 17020 for the management system the practice sits inside.
| Dimension | ASNT SNT-TC-1A | ANSI/ASNT CP-189 | ISO 9712 |
|---|---|---|---|
| Nature of the document | Recommended practice; guidance the employer adapts into its own written practice | National standard written in mandatory language, adopted as written | International standard for third-party certification of individuals |
| Who certifies the individual | The employer, under its own written practice | The employer, but against fixed minimum requirements it cannot relax | An accredited independent certification body |
| Status of the Level III | May be certified by the employer or hold ASNT certification | Required to hold ASNT NDT Level III certification in the applicable method | Certified by the body; the employer authorises the scope of work separately |
| Portability between employers | None; the new employer must certify the person itself | None; the new employer must certify, though prior records support experience | The certificate travels with the individual, subject to employer authorisation |
| Where it usually appears on an LNG job | US fabricators and inspection contractors | Owner specifications demanding a harder line than SNT-TC-1A | International EPC contractors and non-US fabrication yards |
What the document has to contain before anyone can be certified under it
A written practice is not a policy statement. It is the operating document that decides, for each method and each level, who may be certified and on what evidence. It must identify the employer and the scope of work, list the methods and levels it covers, and state for each of them the required education, training hours and documented experience. It must contain or reference the training outlines used, define the examinations, general, specific and practical, together with the pass marks and the composite scoring rule, and name who is authorised to prepare, administer and grade them.
It then has to define the surrounding controls that are usually treated as afterthoughts and are usually where files fail. Vision requirements and their frequency, including near-vision acuity and colour contrast differentiation at the interval the referenced document specifies. Rules for interrupted service and for recertification, with the intervals stated rather than implied. Requirements for certification of the Level III and, when an outside Level III is used, the exact scope of methods he is authorised to act in. The content and retention of certification records. And how the practice itself is revised, approved and distributed.
Two further items belong in an LNG practice specifically. First, an explicit statement of which techniques inside a method require separate qualification, because phased array, TOFD and encoded corrosion mapping demand their own training, examination and demonstration. Second, a statement of how employer-based certification interacts with any third-party certification the contract requires, so that a technician holding both knows which one authorises the work in front of him.
SNT-TC-1A or CP-189: know which one your LNG contract invoked
The two documents look similar and behave very differently. SNT-TC-1A is a recommended practice: it offers guidance, uses permissive language, and expects the employer to write a practice that adapts it to the work actually performed. That flexibility is the point, and it is also the exposure, because every place the employer diverges from the recommendation has to be identified and justified rather than left for an auditor to discover. ANSI/ASNT CP-189 is a national standard written in mandatory language. It sets minima the employer cannot relax and, notably, requires the NDT Level III to hold ASNT certification in the applicable method.
That difference decides real arguments. Under SNT-TC-1A an employer may certify its own Level III against the practice. Under CP-189 that route closes. If the LNG owner specification invokes CP-189 and your Level III of record is employer-certified, every certificate he signed within the CP-189 scope is challengeable, and the remedy is neither quick nor quiet. The time to discover which document the contract invoked is at the bid review, not at the first client audit six months into fabrication.
The practical answer is to write the practice to the stricter of the regimes you may plausibly be held to, and to state in the practice which document governs which contract scope. Converting recommended language into mandatory language costs nothing at the writing stage. Discovering that a client reads should as shall, after two hundred certificates have been issued, costs a great deal.
Who controls the document, and what happens when the Level III is external
The employer owns the written practice. The NDT Level III named in it approves the technical content and is answerable for it. That separation matters when the Level III is a contractor rather than a staff member, which is normal in this industry and entirely acceptable when it is set up properly. The practice must name the individual, list the methods and levels he is authorised to act in, state how his approval is recorded, and describe how examinations are administered when he is not on site.
The failure mode is scope. A Level III certified in three methods ends up signing certificates in a fourth because he was the only Level III available the week the job started. An auditor finds that by placing the certificate list next to his credentials, and it takes about ten minutes. The related failure is continuity: certificates signed by a Level III who has since left, with no record of who assumed responsibility and no review of the certifications he issued.
Revision control is the third control and the one that quietly decides audits. Every revision needs a number, a date, an approval signature, a change record saying what changed and why, and evidence that the superseded version was withdrawn from site. Personnel files must be traceable to the revision in force on the day of certification, because an auditor who finds a file created under revision three being judged against revision five will ask which document was actually applied, and the honest answer is usually that nobody knows.
What an auditor samples, and how the trace-back works
Audits of written practices are conducted backwards. The auditor picks names, often the technicians whose reports appear on the welds he is already interested in, and asks for their files. From each file he expects to reconstruct the entire certification decision: documented training with hours and content matched to the outline in the practice, experience recorded by method with dates and a supervisor attestation, the actual examination papers with marks, evidence the practical examination used equipment and specimens representative of the work, a current vision record, and a certificate signed by the authorised Level III on a date consistent with everything else.
He will then test the joins. Does the examination content match the topical outline the practice claims to follow. Was the person who graded the papers authorised to do so. Does the experience claimed overlap with dates the person was demonstrably working elsewhere. Was the technique used on the job, phased array rather than manual pulse-echo, covered by the certificate. Does the report the technician signed cite a procedure revision that existed on the date of the report. Any one of those joins failing is a finding; two or three failing turns into a systemic finding against the practice itself.
The countermeasure is a cross-reference matrix built at the same time as the practice, mapping every requirement in the referenced document to the specific artefact that evidences it and where that artefact lives. It is unfashionable and it is the single most effective audit defence we deploy, because it converts an open-ended examination into a document retrieval exercise that your own staff can rehearse.
The drift: how a compliant practice decays into an indefensible one
Nothing dramatic goes wrong with written practices. They erode. The examination bank written in 2014 has been used unchanged since, and the answers now circulate informally, which means the examination no longer measures anything and an auditor who asks two candidates the same question in the corridor will establish that in a minute. Practical specimens get lost or damaged and are replaced with whatever is in the scrap bin, so the practical examination no longer represents the work. Vision examinations lapse quietly while a technician spends fourteen months on a site posting.
Then the technical scope drifts away from the certificates. The company buys a phased array unit, wins encoded corrosion mapping work and starts producing data, but the certification structure still says UT Level II and nothing else. Nobody made a decision to do that; it happened because the equipment arrived faster than the paperwork. The same drift happens with acceptance codes, where technicians certified against ASME acceptance criteria are quietly evaluating welds to an EPC specification nobody trained them on.
The last form of drift is organisational. The Level III changes, or the quality manager who understood the system leaves, and the practice becomes a file nobody has read. Annual and biennial reviews become a signed list rather than a review. New hires are processed by pattern-matching against the last person hired. The document is still technically correct and the organisation behind it has stopped executing it, which is the state most practices are in when the first serious audit arrives.
Why LNG raises the bar on the same document
A US LNG facility is regulated under 49 CFR Part 193, which incorporates NFPA 59A and carries explicit nondestructive testing obligations during construction. PHMSA inspectors do look behind the weld records. Part 193 also carries personnel qualification and training obligations for the operator, which are distinct from your NDT technicians and are frequently confused with them: the operator obligations apply to operating and maintenance personnel, while your technicians are qualified through the written practice and reach the facility through contract flow-down. Knowing which mechanism covers whom prevents a great deal of confused correspondence during an inspection.
Above that sits process safety. LNG facilities hold flammable inventories well above the OSHA thresholds, so mechanical integrity requirements apply: inspections and tests must follow recognised and generally accepted good engineering practice and be performed by trained and qualified personnel, with results documented. The written practice is the evidence for the NDT half of that statement. Atlantis supplies that technical content and represents you on technical questions; it is not a process safety management auditor and does not act as the API inspector of record.
There is also a structural gap worth naming. API 653 was written for atmospheric ambient-temperature tanks built to API 650, while a full containment LNG tank is built to API 620 Annex Q and API 625 and has no directly equivalent in-service inspection standard of the same maturity. Where the code framework is thinner, the owner leans harder on the quality of the procedures and the credibility of the personnel behind the data. The written practice carries more weight on an LNG site, not less.
Commissioning surges, subcontractor flow-down and what to ask for
LNG projects do not consume NDT personnel evenly. Fabrication is steady; hydrotest, commissioning and the first turnaround are spikes, and spikes are filled by travelling technicians and subcontracted crews. Every one of those people has to be certified under the practice of the employer they work for, and every one of those employers has to be flowed down the same requirement in its contract. The compliant version of this is boring: verify the subcontractor written practice before mobilisation, sample two files, confirm the Level III is certified in the methods being sold, and check the vision records are current.
The non-compliant version is also predictable. Crews arrive, the schedule is already late, the certificates look official, somebody photocopies them into a folder and the job proceeds. Twelve months later a client audit samples that folder, finds certificates issued by an employer whose written practice nobody has seen, and the finding lands on the owner because the owner accepted the work. Verification before mobilisation takes an afternoon and is the highest-return hour of quality work on the entire project.
If you want that reviewed properly, the useful package is your current written practice and its revision history, the certificate list with the Level III credentials, two or three complete personnel files chosen at random, and the client or EPC specification that states which certification regime applies. That is enough to tell you where you actually stand before an auditor does. Send it to info@atlantisndt.com and ask for a written practice review; the work is affordable, accessible and fully customisable to the methods and scope you actually sell.
What does an auditor look at first in a written practice?
Not the practice. The auditor pulls three to ten personnel certification files and works backwards to the document. He is checking whether the file contains the evidence the practice promises: documented training hours, experience by method with dates, the graded examinations, the practical demonstration, a current vision examination and a certificate signed by the authorised Level III. The practice is only judged by whether the files match it.
Can we accept a technician certified by their previous employer?
Not as a transfer. Employer-based certification under SNT-TC-1A or CP-189 belongs to the issuing employer. You may credit documented training and experience from that employer if it is verified in writing, but you must administer your own examinations and issue your own certificate before the person works. During LNG commissioning, when travelling technicians arrive in waves, this is the single most commonly skipped step and the easiest finding to write.
Who is allowed to change the written practice?
The employer owns the document and the NDT Level III named in it approves the technical content, including training outlines, examination requirements and certification criteria. Revisions need an approval signature, a date, a change record and a controlled distribution. An outside Level III may sign only within the methods he is certified in. A practice revised by quality staff without Level III approval is a finding no matter how sensible the change was.
How does an LNG regulator or client change what adequate means?
By adding readers. A US LNG facility falls under 49 CFR Part 193, which incorporates NFPA 59A, so a PHMSA inspector may ask what qualified the person who examined a weld. OSHA process safety management requires inspection and testing by trained and qualified personnel. An international EPC will often layer ISO 9712 certification on top. The practice must reconcile all three explicitly rather than hoping only one shows up.
What drift makes a good practice fail two years later?
Silent decay. Examination question banks never refreshed and quietly circulating among candidates. Vision examinations lapsing during a long site posting. Certificates signed by a Level III who left the company. Technique-specific work such as phased array performed under a certificate that only names UT. Files created under revision three while the current document is revision five, with no record of what changed between them or why.
Is API 510, 570 or 653 inspector training part of this offer?
No. Atlantis does not sell API inspector certification training and does not act as the API inspector of record. This engagement covers the NDT written practice, method training outlines, examination banks and practical specimens, the certification records framework, and representation on technical questions during an audit. Certification is issued by you as the employer; we build the system that makes each certificate defensible. Consultation on request.