The document behind every NDT certification your mill issues

What the written practice is, and what it is not

The written practice is a governance document. It is the single place where a mill or an NDT service company states, in its own voice, what it requires of the people who produce inspection data. Everything downstream depends on it: every certificate, every signature on a report, every thickness reading credited in a fitness-for-service calculation. If the document is weak, the data is not defensible, however good the technicians happen to be.

It is not a copy of SNT-TC-1A with a logo on the cover. SNT-TC-1A is a recommended practice, written in permissive language, offering recommended training hours and experience for guidance. The employer is expected to adopt, modify or take exception to those recommendations and to state the result. A practice that simply reproduces the recommended tables, unmodified and unexamined, has not made any of the decisions the document exists to record.

It is also not the same thing as a procedure. Procedures control how an examination is performed. The written practice controls who is permitted to perform it, on what evidence, and for how long. The two documents are audited together and fail together, which is why the same Level III should own both.

What the document must actually contain

At minimum the practice must define its own scope, listing every method and every level the organisation uses, with any limited certification categories named explicitly rather than left implicit. It must state education, training and experience requirements per method and per level, and where those depart from the SNT-TC-1A recommendations it must say so, deliberately, as a stated exception rather than a silent omission.

It must describe the examination regime in enough detail that a stranger could administer it: general, specific and practical examinations, who writes them, who administers them, who grades them, how the answer keys are controlled, the passing scores for each part and for the composite, and how a failure is handled including the waiting period before re-examination. It must set the vision requirements, near acuity and colour contrast differentiation where the method needs it, together with the testing frequency and who is competent to administer the test.

Finally it must handle the lifecycle: the certification period and the recertification route, whether by evidence of continuing satisfactory performance or by re-examination; interrupted service and what happens after a long absence; technical performance evaluation; the treatment of certifications from a previous employer; acceptance of subcontracted or agency technicians; the qualification of the Level III of record; records retention; and revision control with a history of what changed and when.

Who owns it, and the limits of each role

The employer owns the written practice and issues the certifications. That is not a formality. It means the company, not the individual and not ASNT, carries the consequence if a certificate turns out not to be supported. Mills sometimes assume the certificate travels with the technician; it does not, in the employer certification model, and a technician arriving from another company starts from the receiving employer's practice.

The Level III of record is the technical authority inside that structure. He or she approves the practice and its revisions, establishes and approves procedures and techniques, provides or approves the technical content of examinations, conducts or oversees the practical, recommends personnel for certification, and interprets the codes and standards the programme works to. The Level III cannot certify himself, and should not be the person auditing his own programme; where a mill wants genuine independence it separates the Level III of record from the internal auditor.

The third role in the room is the one most often conflated with the other two: the API 510, 570 or 653 inspector, who authorises and signs the in-service inspection of the vessel, piping circuit or tank. That inspector relies on the NDT data but does not own the NDT programme. The Level III approves the procedures the technician works to and the practice itself; the technician is certified under the practice; the API inspector makes the in-service call. Three roles, three documents, three sets of evidence.

How an auditor actually samples it

Audits are sampled, not exhaustive. A competent auditor, whether from a client, an insurer, a National Board survey team or an accreditation body, will take the crew list for the day and pick two or three names. From each name the trail runs backwards through the certificate to the examination papers, the practical record, the training record, the experience log and the vision test, and every one of those has to satisfy the revision of the practice that was in force on the date of certification.

The questions are consistent. Does the training record show the hours the practice demands, evidenced by an outline and an instructor, or just a line in a spreadsheet? Was the specific examination written against the equipment and procedures actually used here? Was the practical taken on something that resembles the work? Who graded it, and is the answer key controlled? Is the vision test inside twelve months? Is the Level III whose name is on the certificate still certified in that method today?

The second sample is documentary rather than personal: the auditor asks for the revision history of the practice and the distribution record, then checks whether the revision on site matches the revision filed with the client. A mismatch there is worse than a technical gap, because it says the control system itself is not working.

The drift that fails a practice that was once correct

Very few practices fail because they were badly written. They fail because the organisation changed and the document did not. A mill takes on encoded corrosion mapping and the practice still describes manual thickness only. A contractor starts phased array work on digester overlays and certifies people under a general UT endorsement that says nothing about the technique. Someone with a thickness-limited certificate is put on weld scanning during a busy outage because he was on the scaffold already, and the limitation on his card is never read.

Examinations rot quietly. A question bank that has not changed in six years is a question bank whose answers circulate. A specific examination bought with a template asks about equipment the mill does not own. A practical examination on a flat plate has nothing to say about whether the candidate can distinguish a bond line echo from cracking on a composite tube.

People drift too. The Level III leaves and the practice still names him. A method lapses on the Level III's own certificate while he continues to approve procedures in it. A recertification date passes in the middle of a shutdown and the crew keeps working because nobody is watching the dates during an outage. Each of these is easy to prevent with a calendar and a review; each is routinely found by an auditor instead.

What pulp and paper changes about the definition of adequate

The recovery boiler regime is the reason a pulp and paper practice cannot be generic. Inspection scope here is shaped by BLRBAC recommended good practice and by the property insurer as much as by the boiler code, because the loss scenario is a smelt-water explosion rather than a leak. Insurers and their engineers look for demonstrated competence on the specific asset, and they ask for the practical examination record, not just the certificate.

That has two concrete consequences for drafting. First, the practice should carry an honest limited certification category for composite tube thickness surveys, describing what the holder may and may not do, rather than issuing a broad UT Level II to someone whose entire competence is grid mapping. Second, the practical examination specimens should be furnace wall sections, overlaid coupons and digester seam mock-ups, so that the evidence of competence matches the work.

The wider regulatory frame matters as well. Mills operating chlorine dioxide generation, chlorine, sulphur dioxide or ammonia above threshold quantities fall under OSHA process safety management, whose mechanical integrity element requires that inspection and testing be performed by trained and qualified personnel following recognised and generally accepted good engineering practice. In an enforcement or incident review, the written practice is the document that evidences the training and qualification half of that sentence.

Crossing the border: a US practice does not travel

A significant share of North American pulp and paper capacity sits in Canada, and the certification model there is fundamentally different. Canada uses central certification: the Natural Resources Canada certification body certifies individuals to CAN/CGSB-48.9712, the national adoption of ISO 9712, after training and examination administered under that scheme. The employer does not issue the certificate and cannot issue it.

This catches out US contractors moving crews north for an outage. A perfectly valid SNT-TC-1A certificate, backed by an excellent written practice, is not what a provincial boiler and pressure vessel regulator is looking for, and the crew can be turned away at the mill gate. It also catches out Canadian owners who assume a US contractor's paperwork is equivalent because it is thicker.

The practical answer is a written practice that acknowledges both regimes explicitly. It should state which sites and which scopes of work fall under employer certification, which fall under central certification, how the company verifies a CGSB certificate's currency and scope, and who is responsible for checking before mobilisation. That one section prevents a class of expensive mobilisation failures.

How Atlantis builds and maintains the practice

We start with what you actually do. That means the method and technique inventory, the equipment in the store, the procedures in force, the sites and jurisdictions involved, the client and insurer requirements you are contractually exposed to, and the current certification population with its expiry dates. Most of the eventual findings are visible in that inventory before a word of the document is written.

We then draft the practice against SNT-TC-1A or CP-189 as appropriate, with stated exceptions rather than silent ones, limited certification categories that describe reality, and an examination regime that can survive being sampled. We build or rebuild the question banks so that the specific examination is about your equipment and your procedures, and we design practical specimens representative of composite tube walls and digester seams rather than convenient plate coupons.

Maintenance is the part that decides whether it holds. We run an annual review, reconcile the certification population against the current revision, refresh examination material on a defined cycle, and act as the Level III of record where you need continuing technical authority rather than a one-off document. Work in Canada is handled explicitly rather than assumed. To discuss a written practice development or audit-readiness review, contact info@atlantisndt.com for a consultation.

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