The Written Practice: the Document Behind Every Certificate You Issue
Your written practice is the document that makes every NDT certificate you issue valid or void. It fixes methods and levels, training and experience hours, examination content and grading, vision checks, recertification intervals, and the Level III who approves all of it. In petrochemical work an auditor rarely reads it: they sample three certification files and try to break the claims.
Petrochemical clients attack the written practice harder than any other document in an NDT quality system, because it is the one place where a paperwork failure invalidates years of completed inspection at once. If the practice was silent on phased array while your technicians ran phased array, every one of those reports is open. If a certificate was issued against a revision already superseded, the auditor will ask which revision governed on that date and expect a controlled copy. If experience hours were logged in three methods for the same forty hour week, the arithmetic fails without any technical argument at all. None of this is about better prose. It is about a document whose contents match what the company actually sells, whose records survive being traced back to timesheets and graded examination papers, and whose revision history carries an approval signature on every line.
Source: Written against ASNT SNT-TC-1A as a recommended practice and ANSI/ASNT CP-189 as a standard, with ASNT ACCP and ISO 9712 as alternative certification routes, OSHA process safety management at 29 CFR 1910.119 for mechanical integrity documentation, API 510, 570, 653 and API 577 for owner user expectations of NDE personnel, ISO 9001 clause 7.5 for document control, ISO/IEC 17020 and ISO/IEC 17025 where the inspection body or laboratory is accredited, and, for Alberta scopes, the provincial Safety Codes Act regime with CSA B51 and personnel certification under CAN/CGSB-48.9712.
| Element of the practice | Usual position under SNT-TC-1A or CP-189 | Evidence the auditor asks for |
|---|---|---|
| Level III of record | Named in the document, in house or an outside agency Level III with the role scoped | Current certification in each method claimed, and a contract or employment record covering the certification dates |
| Training hours per method and level | Tabulated by method and level, with Level I hours additive when certifying directly to Level II | Course outline, attendance roster with signatures, instructor identity, and dates that predate certification |
| Experience hours | Tabulated by method and level, accrued while performing work in that method | Job records or timesheets that reconcile with the hours claimed and with the calendar |
| Examinations | General, specific and practical, with question counts, source and grading rules stated | The graded papers, the answer key, the practical specimen, and the report the candidate produced |
| Vision requirements | Near vision acuity verified annually, colour contrast differentiation at the interval the practice states | In date records signed by the examiner the practice authorises, for every certified person on site |
| Recertification | Three years for Levels I and II and five years for Level III are the common recommended intervals | Evidence of the basis used, whether examination, technical performance evaluation or continuing activity |
| Exceptions to the recommended practice | Every deviation stated explicitly in the document itself | The exceptions list, and a rationale that the client's own specification accepts |
What the Written Practice Is, and What It Is Not
The written practice is the employer's own rule book for qualifying and certifying NDT personnel. It states which methods and levels the company uses, what education, training and experience each level demands, how examinations are built, administered and graded, what vision is required and how often, how long a certification lasts and how it is renewed, and who has the authority to approve all of it. Everything downstream, every certificate, every report signature, every acceptance decision, derives its validity from this one document.
It is not a quality manual, and it is not a procedure. The quality manual describes the management system; the procedures describe how a method is applied to hardware. The written practice sits between them and governs people. Companies that fold it into the quality manual as an appendix usually end up with a practice that is revised on the manual's schedule rather than when the technical scope changes, which is exactly the wrong trigger.
It is also not a document you can borrow. A practice copied from another company describes that company's methods, levels, training courses and Level III. Auditors recognise borrowed practices instantly, usually because the methods listed do not match the services sold, or because the document still references an organisational structure the company does not have. The purpose of the practice is to describe what you actually do, in enough detail that an outsider can test it.
SNT-TC-1A Is a Recommended Practice; CP-189 Is a Standard
The distinction is not pedantic. SNT-TC-1A is a recommended practice written in permissive language: it provides guidelines that the employer adapts, and it requires that the employer's written practice describe the guidelines used and state every exception taken. That flexibility is the point, and it is also the trap, because a practice that quietly reduces hours or simplifies examinations without declaring the deviation has failed the one requirement SNT-TC-1A genuinely imposes on it.
ANSI/ASNT CP-189 is a standard. Its language is mandatory, it sets minimum requirements the employer cannot relax downward, and it is more prescriptive about the qualification of the Level III and about examination administration. Some petrochemical owners and many nuclear adjacent clients specify CP-189 precisely because it removes the employer's discretion. Others accept SNT-TC-1A but layer their own supplementary requirements on top through the contract, which has the same practical effect.
So the first question in any written practice engagement is which document the market you sell into actually requires, and whether your contracts have already answered it for you. A practice claiming compliance with SNT-TC-1A while the client specification invokes CP-189 is a finding waiting for an audit. Where both apply across different clients, the practice should state the stricter baseline and identify where client specific requirements exceed it, rather than maintaining parallel documents that will drift apart.
The Contents Auditors Check First
Auditors have a habit of opening the same pages. The exceptions list, because it reveals where the company has departed from the recommended practice. The tables of training and experience hours by method and level, because that is where arithmetic can be tested. The examination section, because question counts, question sources, grading rules and re examination provisions are either specific or they are not. And the named Level III, because everything else is approved by that person and their status is checkable in minutes.
The examination section deserves more care than it usually gets. It should state how many questions each general and specific examination contains, where the questions come from, the composition of the practical examination including the specimens and the report the candidate must produce, the grading rules with the pass thresholds applied to each part and to the composite, how examinations are kept secure, and what happens when a candidate fails. The commonly recommended position is a minimum on each part with a higher composite requirement, and if your practice states different numbers it must say so as an exception.
Then there are the sections that only matter when something goes wrong: interrupted service, suspension and revocation of certification, transfer of certification from a previous employer, and record retention. These are the clauses that get invoked after an incident or a dismissal, and they are the ones most often left as generic filler. Write them as though they will be read by somebody hostile, because that is when they will be read.
Who Controls the Document, and Why the Outside Level III Cannot Certify
Certification is an employer act. The employer certifies its own personnel against its own written practice, and no consultant, agency or training provider can absorb that responsibility. This is the most persistently misunderstood point in the whole subject, and it is misunderstood in both directions: some companies believe a training school's certificate certifies their technicians, and some believe that hiring an outside Level III transfers the liability. Neither is true.
What an outside Level III legitimately does is substantial: author or revise the written practice, be named in it as the Level III of record for specified methods, write and grade the general, specific and practical examinations, approve the NDT procedures, recommend candidates for certification, and represent the programme technically during a client audit. The practice must define that scope explicitly, including what happens when the Level III is unavailable and who may act in the interim.
The failure mode here is silent expiry. A practice names a Level III who leaves the company, retires, or lets a method certification lapse, and certificates continue to be issued under a signature block that no longer has authority behind it. An auditor establishes this with two questions and a date comparison. The remedy is a review trigger written into the practice itself: any change in the Level III of record forces a practice revision and a check of every certificate issued since the change.
How an Auditor Samples: Three Files, Traced to Ground Truth
A competent auditor does not read the practice cover to cover. They read the tables, then pull three certification files, usually across two methods with at least one recent certification, and try to break each claim by finding independent evidence. Training hours must reconcile with a course outline and a signed attendance roster naming the instructor. Experience hours must reconcile with job records, timesheets or dispatch logs. Examination scores must be supported by the graded papers themselves and the answer key, not a summary sheet.
The practical examination is where files most often fail. The auditor wants the specimen used, the instructions the candidate was given, the report the candidate produced, and the grading against a defined key. Frequently what exists is a line on a form saying practical passed, signed by the Level III. That records an opinion rather than an examination. Where the practical was performed on hardware that no longer exists, the record has to be strong enough to stand in its place.
Then they will talk to a technician. Which revision of the practice were you certified under, where is the procedure you work to kept, when did you last have a vision test, what is your certification limited to. Those four answers, checked against the files, tell an experienced auditor more about the health of the programme than the document ever will. Programmes fail here not because technicians are unqualified but because nobody has ever told them what their own certificate says.
The Experience Hour Arithmetic That Fails Audits
Experience hour claims fail for three reasons, and all three are arithmetic rather than judgement. First, certifying a candidate directly to Level II without logging the Level I experience as well: the direct route requires the sum, and files routinely show only the Level II hours. Second, counting the same clock hours toward several methods simultaneously. A technician cannot accrue full method experience in ultrasonics, radiography and magnetic particle during the same forty hour week, yet the summary sheet often says exactly that.
Third, misapplying education reductions. Practices commonly allow reduced hours for candidates holding relevant engineering degrees or technical qualifications, and the reduction applies to specific rows and specific levels. Applying it broadly, or applying it to experience where the practice permits it only for training, converts a defensible file into an indefensible one. If your practice permits reductions, it should show the arithmetic with a worked example so nobody has to interpret it under audit pressure.
Auditors test plausibility before they test detail, and plausibility is quick. A technician certified in five methods within eighteen months of hire, or a certification date that precedes the training course date, ends the discussion. The defence is not better filing after the fact; it is an experience log kept contemporaneously, tied to actual jobs, and reviewed by the Level III before a certification is granted rather than as part of preparing for an audit.
PSM, RAGAGEP and What the Regulator Turns the Practice Into
In a US petrochemical plant the written practice stops being purely a quality document. OSHA's process safety management standard at 29 CFR 1910.119 requires mechanical integrity: written procedures, employees trained in the process and the maintenance activity, inspection and testing that follows recognised and generally accepted good engineering practice, and documentation of each inspection and test recording the date, the person who performed it, the identifier of the equipment, a description of what was done, and the results. Deficiencies must be corrected before further use, or otherwise assured safe.
Read that documentation list against your NDT report template. The two fields that most often fail are the equipment identifier, which is frequently a line number without the circuit or component that the integrity programme actually tracks, and the identity of the person who performed the test, which is sometimes only a company name or an illegible initial. Both are trivial to fix in a template and expensive to fix retrospectively across a turnaround's worth of reports.
RAGAGEP is where the written practice connects back in. Certification under SNT-TC-1A or CP-189, examination to ASME Section V, and in service inspection under API 510, 570 and 653 are the recognised practices, and the owner is entitled to see that your personnel are certified under a practice that actually implements them. Contractor prequalification systems and owner audits then apply the same test from the commercial side. The practice becomes an operating licence for the site, not just a quality artefact.
Alberta: Where Employer Certification Stops Working
Companies serving both the US Gulf Coast and the Alberta olefins and derivatives complexes, in the Industrial Heartland northeast of Edmonton and around the ethylene complex near Red Deer, discover that the certification model changes at the border. Pressure equipment in Alberta is administered provincially under the Safety Codes Act, with CSA B51 as the governing construction and registration standard and an owner integrity management regime layered on top. Non destructive testing on pressure equipment is normally performed by personnel certified centrally by Natural Resources Canada under the CAN/CGSB-48.9712 scheme.
That is central certification, not employer certification. Your written practice does not qualify anyone for that work, and hours accrued under it do not automatically count toward the national scheme. Contractors who plan a Canadian scope on the assumption that a US Level II certificate transfers end up either subcontracting the examination or standing down a crew. The written practice remains necessary, because it still governs your programme, your procedures, your internal levels and any work outside the pressure equipment scheme, but it stops being the certification authority.
The clean way to handle this is to write the practice so that jurisdiction is an explicit variable. State that where a jurisdiction or client requires certification under a national or third party scheme, that certification governs and the practice's internal levels do not substitute for it. That single clause prevents the most expensive mistake in cross border NDT work, and it signals to a Canadian client that you understand their regime before they have to explain it.
Drift: How a Compliant Practice Goes Bad in Three Years
Practices rarely fail on the day they are written. They fail through drift. The commercial team sells a technique the practice never defined, usually phased array or encoded corrosion mapping, and the technicians run it under a general ultrasonic certificate. A second location is acquired with its own practice and its own Level III, and the two documents are never reconciled. A new certificate template is created in a hurry and quietly drops the limitations field. Each step is small and none of them is recorded as a change.
Revision control is where drift becomes visible. Under ISO 9001 clause 7.5 the practice is a controlled document, so it should carry a revision number, an approval signature, a date, and a distribution record. Certificates should identify the revision they were issued under. When an auditor asks which revision governed a certification date two years ago, a healthy programme produces the superseded revision from a controlled archive in a minute. An unhealthy one produces the current revision and hopes nobody notices the difference.
The defence is an annual review with a fixed agenda: has the method and technique list changed, has the Level III of record changed, have client specifications introduced requirements the practice does not meet, do the certificate templates still match the practice, and have any certifications been issued outside the tables. That review takes a few hours and it is the difference between a document that describes the company and a document that describes the company as it was three years ago.
How Atlantis Builds and Maintains a Written Practice
The work begins with a scope reconciliation rather than a drafting session. What methods and techniques does the company actually sell, to which clients, under which specifications, and in which jurisdictions. That list is then compared against the existing practice, the certification files and the certificate templates, and the gaps are ranked by exposure, with anything that could invalidate completed work listed first. Existing documents are revised and extended rather than replaced, so the company's certification history stays intact and traceable.
From there the deliverables are concrete: a written practice aligned to SNT-TC-1A or CP-189 as your market requires, with the exceptions stated explicitly; hour tables that match the levels and methods you use; examination structures with question banks, keys and security rules; practical examination specimens and grading criteria; certificate and record templates carrying the fields the practice and OSHA documentation requirements demand; and a named Level III of record with the scope of that role defined. Where certification lies with a national scheme, the practice says so instead of pretending otherwise.
Atlantis is led by an ASNT NDT Level III in multiple methods who also holds API 653 authorised inspector certification, and it supplies inspection management and reporting software, digital twin asset visualisation, NDT training and independent report validation alongside written practice and procedure consulting. Positioning is affordable, accessible and fully customisable. To review an existing practice or build one for a petrochemical scope on the Gulf Coast or in Alberta, request a consultation and a written quote at info@atlantisndt.com.
What must a written practice contain to survive a client audit?
Scope and methods, the levels used, the Level III of record by name, education, training and experience minimums for each method and level, training outlines, examination structure with question counts, question source and grading, examination security and re examination rules, vision requirements and intervals, certification and recertification intervals, interrupted service rules, record content and retention, and every exception taken to the recommended practice, stated explicitly.
Who owns and signs the written practice, the employer or the outside Level III?
The employer certifies its own personnel, and that responsibility cannot be contracted away. An outside Level III may write the practice, write and grade examinations, and approve procedures, and must be named in the document with the scope of that role defined. If your practice still names a Level III who has left, every certificate signed after that date invites an auditor to ask who was actually in authority.
How does an auditor test the practice rather than read it?
By sampling. Three certification files, ideally across two methods with one recent certification, then tracing every claim to independent evidence: training hours to a signed roster, experience to job records, examination scores to the graded papers and the answer key, the practical to the specimen and the report the candidate wrote, and vision to an in date record signed by whoever the practice authorises.
What experience hour arithmetic fails most often?
Certifying directly to Level II without logging the Level I hours as well, counting the same clock hours toward several methods at once, and applying a formal education reduction to the wrong row of the table. Auditors test plausibility first: a technician certified in five methods inside eighteen months cannot have accumulated full method experience in each, and no explanation recovers that file.
How do OSHA process safety rules change what adequate means?
Mechanical integrity under 29 CFR 1910.119 requires inspection and testing that follows recognised and generally accepted good engineering practice, performed by trained personnel, with each result documented by date, the identity of the person performing it, the equipment identifier, a description of the test and the outcome. Two fields fail most often, the equipment identifier and the named person, and both sit in your report template.
Is API 510, 570 or 653 inspector training part of this offer?
No. Atlantis is not a process safety management auditor and is not your API inspector of record. What it supplies is NDT technical authority: the written practice itself, procedure development and qualification, personnel certification within that practice, technical representation when an auditor questions the programme, and independent review of inspection data. Consultation and a scoped quote are available on request.