The Written Practice: Every Certification on Your Alberta Site Rests on It

SNT-TC-1A is a recommendation; your written practice is the requirement

ASNT SNT-TC-1A is written in permissive language. It recommends what an employer's written practice should address and then explicitly leaves the employer to establish the actual requirements. That is why two contractors working the same unit can hold entirely defensible practices that differ in training hours, examination structure and recertification interval. It is also why no auditor is impressed by a written practice that simply restates SNT-TC-1A clause for clause. Restating a recommendation is not the same as making a decision, and the decisions are what get audited.

The binding document is yours. Every certificate your organisation issues draws its authority from it, which means a defect in the practice is a defect in every certification underneath it — not a paperwork irritation but a live exposure across your whole workforce. When a client rejects a technician at the gate of an Alberta site, the rejection is almost never about that technician's skill. It is about a clause written years earlier by someone who has since moved on and never revisited.

There is a simple test. Hand the practice to a competent person who has never seen your operation and ask them to certify a UT Level II from scratch using only that document. If they cannot — because the training hours are not stated, or the examination structure is described but not defined, or the practical specimen is not identified, or the grading rule is ambiguous — then an auditor cannot verify your existing certifications either. They are relying on institutional memory, and institutional memory is not evidence.

Where CP-189 changes the rules

ANSI/ASNT CP-189 is a standard rather than a recommended practice, and the shift from should to shall changes how it is read and how it is audited. CP-189 sets minimum qualification requirements directly instead of delegating them, and — the point most operators miss until it costs them — it requires the Level III to hold ASNT NDT Level III certification rather than employer certification. An employer-certified Level III who is entirely acceptable under SNT-TC-1A does not satisfy CP-189.

Oil sands owners and their EPC contractors invoke one or the other by name in the inspection and test plan, and on large projects sometimes both, across different work packages executed by the same crew. If your written practice is built on SNT-TC-1A and the contract flows down CP-189, you have a gap that no volume of additional training hours will close, because the gap is in who signs. Read the ITP before writing the practice rather than after the first rejected submittal.

There is a third possibility on Canadian sites, and it catches people out repeatedly: certification to CAN/CGSB-48.9712, the national scheme administered through Natural Resources Canada. It is a central certification body model, structurally closer to ISO 9712 than to SNT-TC-1A, with independent examination and a certificate that belongs to the individual rather than the employer. No employer written practice, however good, produces it. If your scope touches pipeline, you need to know which of your people hold it before you bid the work.

What the document must actually contain

The core content list is not long, but it has to be complete: the scope of methods and levels the organisation certifies; education, training and experience minimums for each method and level; training outlines and hours, usually against the CP-105 topical outlines; general, specific and practical examinations with a defined structure, grading method and composite pass rule; examiner qualification; annual near-vision acuity and colour contrast differentiation requirements; certification and recertification intervals; interrupted service provisions; technical performance evaluation; records and retention; and the identity and authority of the Level III.

Certain clauses are skipped almost universally, and they are the ones auditors go to first because they know that. Interrupted service — what happens to a certification when a technician is off the tools for six months, which on a rotational Alberta workforce is not hypothetical. Limited certification, which is how you legitimately certify someone for thickness measurement only, or for a single technique. Technical performance evaluation, which is how a certification is maintained between formal examinations. And the outside agency clause, which is how a contracted Level III is brought inside your system rather than existing beside it.

Vision requirements deserve their own paragraph because they generate more findings than their importance warrants. The requirement is near-vision acuity demonstrated annually at a stated reading distance, plus demonstrated ability to distinguish and differentiate contrast among the colours used in the methods concerned. What sites usually file is a general optometrist letter that certifies the technician can drive, says nothing about near-vision at reading distance, and a colour vision test performed once at hire in 2014. Both fail, and both are trivially cheap to fix once someone notices.

Two certification regimes on one Alberta site

The pressure equipment path runs through ASME and ABSA. Piping built to ASME B31.3 and vessels to Section VIII Division 1, registered under CSA B51, operated under an owner-user integrity management programme meeting ABSA's AB-506 requirements. Personnel performing the NDE are certified under an employer's written practice to SNT-TC-1A or CP-189, and the whole chain is auditable through your own documents.

The pipeline path runs somewhere else entirely. Gathering, transmission and much of the interconnecting scope falls under CSA Z662, and Z662 carries an expectation of NDE personnel certified under the national CGSB scheme rather than an employer practice. That is a structurally different credential: examined and issued by a certification body, held by the individual, portable between employers, and impossible to produce internally no matter how thorough your written practice is.

On an integrated oil sands site both regimes are live at once, sometimes within a hundred metres of each other, and the recurring finding is a technician performing Z662 scope on the strength of an employer-issued card. Closing it needs two things. The written practice must contain a scope table that maps personnel and credentials to code regimes with explicit limits, and the person dispatching work must be able to read that table without interpreting it. A practice that is technically correct but unreadable by a scheduler at five in the morning will be violated by lunchtime.

Who controls the document

Somebody has to be named, and the naming has to mean something. The Level III of record holds the authority to approve the written practice itself, approve examination content, administer or approve the administration of examinations, certify personnel, and approve the procedures those personnel work to. SNT-TC-1A permits that person to be an outside agency Level III, but the employer keeps responsibility for the programme regardless. That arrangement belongs in the document: the individual, the methods their own certification covers, the scope of delegated authority, and the frequency of on-site presence.

Revision control is where most practices are silent in the one place it matters. It is common to find a clause stating who may revise the document and who approves the revision, and rare to find a clause covering what happens to certifications issued under the superseded revision. That is the first question an auditor asks after any revision, and the honest answers range from all existing certifications remain valid until expiry, to affected certifications are reviewed against the new clause within ninety days. Either can be defended. Silence cannot.

The other control question is distribution. If the practice lives on a shared drive with no distribution record, you cannot demonstrate that the people bound by it have seen the current revision, and you almost certainly have a printed copy of an old revision in a site office somewhere. Controlled distribution is unglamorous, and it is the difference between a finding and a clean sample.

How an auditor samples it

The mechanics are consistent enough to rehearse. The auditor selects three technician files, usually not at random despite appearances — they pick the newest certification, the most senior technician, and someone who signed a report that caught their eye. From each file the chain runs outward: certification record, then training records against the stated outline, then examination papers with grading sheets, then the practical specimen and how it was scored, then the annual vision records, then a signed examination report, then the procedure that report cites, then the Level III approval on that procedure and the approver's own certification.

Every link in that chain is a document that either exists or does not. There is no technical judgement involved, which is why this stage of an audit is unwinnable by argument. If the training records show sixty hours against an outline that requires eighty and there is no documented basis for the reduction, the finding is written. If one sample fails, the auditor widens rather than closes: three files become eight, and eight becomes the whole roster.

The most useful preparation is to run the same trace in reverse on yourself. Take three completed reports at random from the last quarter, work backwards to the practice, and stop at the first document you cannot produce within ten minutes. That document is your finding. Doing this quarterly costs an afternoon and removes almost all the surprise from an external audit.

The drift that fails a good practice three years later

Examination integrity degrades first. A general examination bank written once gets reused until the answers circulate, and the tell is a run of near-identical scores among technicians of visibly different ability. The same practical specimen used for a decade stops being an examination and becomes a memory test. Neither problem is dishonest in origin; both are what happens when nobody owns the bank and nobody is funded to refresh it.

Then the credentials drift. Training hours get quietly discounted for prior experience that nobody documented at the time. Recertification is granted on the basis of continued satisfactory performance in a practice that does not permit that route at that interval. A technician is certified in a method the scope statement never listed, because the work came in and the certificate had to exist. And on the cover page, the Level III who signed everything left in 2022 and no formal transfer of authority was ever executed, which means the approvals since then rest on nobody.

Finally the scope drifts. Phased array arrives, then corrosion mapping, then guided wave screening, then computed or digital radiography with a different sensitivity regime and different image quality indicators, and none of it appears in the practice. Each of those is a technique-level qualification question, and each is being answered informally on the deck by whoever is most confident. That is the state most practices are in when they are handed to us, and none of it requires removing anything already in the document — it requires adding what the last four years of work quietly assumed.

Oil sands scope the template never covered

Most written practices in circulation descend from a template written for weld examination on new construction. Oil sands operations do something else. Hot-service thickness measurement with temperature correction, encoded corrosion mapping on erosion scars, corrosion under insulation programmes that combine profile radiography with pulsed eddy current and targeted insulation removal, coker drum fatigue crack detection and sizing — these are technique-level competencies, and if the practice does not describe how someone becomes qualified in them, then nobody is.

The Alberta winter changes method requirements outright, not just comfort. Liquid penetrant and magnetic particle examination under ASME Section V carry a qualified temperature band, and work outside that band requires the technique to be qualified at the temperature actually used. Field work at minus thirty is comfortably outside it. A practice that certifies PT Level IIs without addressing low-temperature qualification is certifying people to perform an examination that, as performed, is not code-compliant — and that is a finding against the practice, not against the technician.

Rotational schedules interact with the certification clauses in ways that surprise people. A fourteen-and-fourteen rotation, a seasonal shutdown of a SAGD pad, a technician moved to a different subsidiary for a project: each can trigger interrupted service provisions or an employer change. If the practice does not define these situations, the site defines them informally, and the informal definition will not be the one you would have chosen.

Rebuilding without invalidating what already exists

The tempting fix is to buy a clean template, reissue the practice and quietly recertify everyone under it. That is the worst available option. It creates a documented discontinuity, invites the question of what was wrong with the previous revision, and puts every certification issued in the last five years into an ambiguous state on a single day. It also throws away genuine training and experience records that were perfectly adequate.

The additive approach works better and audits better. Build a gap register that maps each clause of the current practice against what the certification files actually contain and against what technicians are doing on the unit today. Most clauses will be fine. A minority will need a bridging action: a documented experience credit, a re-examination, a technique-specific qualification, a corrected vision record. Each becomes a dated entry with an owner, and the register itself becomes evidence of a controlled programme rather than a panic.

Sequence matters. Fix the Level III appointment and revision control first, because nothing else can be validly approved until those are sound. Then the scope table and the code-regime mapping, because that is where the client-facing exposure sits. Then examination content and specimens. Then the records themselves. A rebuild run in that order stays defensible at every intermediate stage, which matters if an audit lands while it is in progress. Atlantis can run the gap register, draft the revised practice, and act as the named Level III where you need standing authority rather than a report — contact info@atlantisndt.com for a consultation.

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