The Written Practice Is the Document Every Certificate Rests On

What the document is, and why it outranks the recommended practice

SNT-TC-1A is a recommended practice published by ASNT. It is guidance, deliberately written so that an employer can adapt it to the methods, techniques and scope of work it actually performs. The employer's written practice is the adaptation, and it is the document with legal and contractual force inside your company. Once you have issued a certificate under it, that practice is the standard you are held to — not the recommendation it was derived from, and not what a reasonable person might consider adequate.

This inversion catches people out. Managers prepare for an audit by rereading SNT-TC-1A and are surprised when the auditor never opens it. He opens your practice, reads what you promised, and then goes to the personnel files to see whether you did it. If your practice sets a higher bar than the recommendation — and many do, usually because a client contract demanded it years ago and nobody rolled it back — you are held to the higher bar. A promise you did not need to make is still a promise you have to keep.

The stakes in refining are not administrative. A technician's certificate is the warrant behind a thickness reading, and that reading sets a corrosion rate, which sets a remaining life, which sets an inspection interval and sometimes a run-or-repair decision. Every one of those sits in the mechanical integrity file for a PSM-covered process. The written practice is where that whole chain of reliance starts.

The clauses an auditor opens first

The scope clause comes first, and it must state the edition of SNT-TC-1A or CP-189 adopted and the methods and levels the company certifies. Vagueness here is expensive: a practice that says it follows "the current edition" quietly changes its own requirements every time ASNT publishes, and your existing certificates fall out of compliance with your own document without anyone touching a file. Name the edition, and manage the transition deliberately when you change it.

Next come the qualification requirements per method and level: classroom training hours, documented experience hours, and the education route that modifies them. These are per method — the hours for MT are not interchangeable with the hours for UT, and pooling them is a finding. Then the examinations: general, specific and practical, with a stated passing grade for each part and a composite requirement, and a rule for how many attempts are permitted and after what waiting period. Then vision: near-vision acuity to a stated Jaeger equivalent at a stated distance, plus colour contrast differentiation, at the frequency the practice sets.

The back half of the document is where practices thin out and audits concentrate. Recertification interval and the basis for it. Interruption of service and what re-examination it triggers. Revocation and reinstatement. Records retention — what is kept, where, for how long, and who can access it. Control of the practice itself: revision, approval, distribution. Auditors have learned that a practice with a strong front half and a vague back half describes a company that certified people once and never maintained the system.

Who controls it, and the limits of a Level III signature

The written practice is prepared, approved and maintained by the Level III, and the employer certifies personnel on his recommendation. That relationship is the spine of the whole system, and its most-abused joint is scope. A Level III's authority is bounded by the methods in which he is himself certified. If your practice covers UT, RT, MT, PT, VT and ET but your Level III holds three of those, then either a second Level III covers the rest or those methods do not belong in your scope. Certificates signed outside a Level III's method scope are void, and the technicians holding them have to be recertified by someone qualified to do it.

The second limit is continuity. A practice names a Level III; when that person leaves, the practice is instantly out of date and every subsequent certification lacks a signatory with authority. The gap is usually filled by whoever is nearest to the paperwork, and it is discovered months later when a client audits the file. A practice should say what happens on departure — who holds interim authority, what may and may not be signed in the interim, and how long the interim may run.

The third limit is independence of the examination process. Where an outside Level III prepares, administers and grades examinations, the practice must say so and must describe how examination material is controlled. Practical examination specimens that circulate among candidates are a real and recurring problem in high-turnover contractor environments; if the same three welds have been the practical for six years, the examination is measuring familiarity, not capability.

SNT-TC-1A, CP-189 and ISO 9712 in a refinery contract

Three regimes turn up in refinery contracting and they are not interchangeable. SNT-TC-1A is a recommended practice under which the employer certifies. ANSI/ASNT CP-189 is a standard with mandatory language, and it requires the Level III to hold an ASNT NDT Level III certificate in the applicable method — an important difference for companies whose Level III was qualified internally. ISO 9712 is a third-party certification scheme in which an accredited body certifies the individual, and the certificate travels with the person rather than the employer.

Contracts collide with this regularly. A US refinery specification calls for SNT-TC-1A certification; the contractor arrives with a crew holding ISO 9712 certificates issued in another country and assumes they are equivalent or better. They may well be more rigorous, but they are not employer certification under your practice, and the owner's specification asked for the latter. The resolution is a documented crediting process inside the written practice, applied person by person with Level III review — not an assertion of equivalence in a covering email.

The reverse also happens. A company adopts CP-189 because a single client demanded it, applies it across the whole business, and then discovers it has bound itself to a stricter regime than most of its work requires. The written practice can distinguish scopes — but only if it does so explicitly and consistently, and only if the certificates say which regime they were issued under. Silence here is what produces two incompatible certification populations inside one company.

What an owner-user audit actually does to the file

Refinery quality audits of NDT contractors are sampling exercises, and the sample is almost always drawn from the last turnaround. The auditor picks two or three technicians who signed reports on that job, then works backwards. Certificate. Examination records — general, specific and practical, with the graded papers, not a summary. Training records showing the hours the practice requires, in that method. Experience documentation with dates, supervision and method. Current vision examination. Then the procedure revision in force on the day the work was performed, and finally the report itself.

Each link in that chain is either present or it is not, and the auditor is not looking for elegance. The finding that recurs most is the practical examination reduced to a signed statement: "candidate demonstrated satisfactory performance". No specimen identification, no flaw map, no checklist, no grade. That is not an examination record, and it means the certificate has no demonstrable basis in performance at all.

The second most common is documented experience. Hours are claimed, but there is nothing behind them — no job numbers, no supervisor, no method breakdown. In a contractor business where technicians rotate across methods on the same shift, reconstructing this after the fact is nearly impossible, which is exactly why the practice should require it to be captured contemporaneously. A monthly hours-by-method sign-off takes minutes and closes the finding permanently.

The drift that makes a good practice fail

Written practices rarely fail because they were badly drafted. They fail because the organisation moved and the document did not. A company adds phased array to its service offering and starts certifying to it, but the practice still lists conventional UT only. A new client demands CP-189 and the sales team agrees, but the practice remains an SNT-TC-1A document. The company begins subcontracting technicians during peak turnaround season, and those technicians work under certificates issued by their own employer while appearing on reports under yours.

The subcontracting case deserves particular attention in refining, because turnaround demand is spiky and every contractor supplements. A technician certified by another employer is certified by that employer, under that employer's practice. If he signs a report on your letterhead, the owner is relying on your certification system for a person your system never assessed. The practice has to state exactly how sub-tier personnel are handled — accepted under a documented review, certified under your practice, or reported under their own employer's name — and then the field has to actually do it.

The quieter drift is edition and interval. A practice adopted an edition in 2014 and the certification records were built against a later one, or the recertification interval in the document does not match what the records show being applied. Neither is a safety issue on its own. Both tell an auditor the system is not being maintained, which changes how deeply he samples everything else — and depth of sampling is what turns a clean audit into a bad week.

How refining's regulatory and client regime changes what 'adequate' means

Refineries in the United States operate process safety management under 29 CFR 1910.119, and mechanical integrity is where NDT enters that rule. The regulation requires inspection and testing to follow recognised and generally accepted good engineering practice, requires the people performing it to be trained in the procedures they apply, and requires the results to be documented. It does not name SNT-TC-1A. But the RAGAGEP for in-service inspection is API 510, 570 and 653, and those documents lean on qualified NDT personnel, which routes straight back to your written practice.

The consequence is that the owner, not the regulator, is your effective auditor — and the owner is auditing because his own file depends on your file. This is why refinery audits of NDT contractors are noticeably harder than generic quality audits: the auditor knows the certificate is load-bearing. It is also why an invalid certificate is treated as a data-integrity problem rather than a paperwork problem, and why remediation almost always includes a technical review of the affected inspection results, not just reissued cards.

Contractor prequalification adds a second layer. Owner specifications routinely stipulate the certification regime, sometimes site-specific qualification on top of it, and increasingly a documented demonstration for high-consequence techniques. Reading those requirements once, at bid time, and reflecting them in the written practice is far cheaper than discovering during mobilisation that half the crew is not acceptable to the site.

What we do with your practice, and what we do not

We rewrite or build the written practice against the regime your contracts actually require, align it to the methods and techniques you genuinely perform, and then rebuild the certification records so the file supports the document. That includes examination material that is controlled rather than circulated, practical examination specimens with recorded flaw maps and grading sheets, an experience capture routine your supervisors will actually use, and a records structure an auditor can navigate without your help. Nothing that already works is thrown away; the gaps are closed.

Where the engagement includes it, the Level III of record function is provided as a continuing relationship — approving procedures, preparing and grading examinations, recommending certification within method scope, and representing you on technical questions during a client audit. The boundaries are explicit: Atlantis is not a PSM auditor, and does not act as the API 510, 570 or 653 inspector of record. We supply NDT technical authority and independent review of inspection data, which is a different and complementary role.

If you are heading into a turnaround with a practice you have not read in three years, the useful first step is a gap review: the document against the contracts, and the personnel files against the document. Consultation and quote on request — info@atlantisndt.com.

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