The Document Every Certificate at Your Terminal Depends On

The written practice is not paperwork; it is the certificate

An NDT certificate has no independent existence. It is a statement that a named person satisfied the requirements of a specific employer's written practice on a specific date, recommended by a specific Level III. Remove the practice and the certificate says nothing at all — which is why an auditor who wants to test a terminal's inspection data starts at the practice rather than at the reports.

This is poorly understood in tank terminal operations, because the technicians are usually contractors and the certificates arrive as PDFs in a mobilisation package. The terminal reads the front of the card, sees a level and a method, and files it. Nobody asks which document that card was issued under, whether that document exists, or whether it contains anything a competent person would recognise as a control.

The practical consequence lands years later. A tank's remaining-life calculation rests on a thickness survey; the survey rests on a Level II's interpretation; the Level II's authority to interpret rests on a certificate; the certificate rests on a written practice nobody has ever read. If the practice is hollow, the chain does not fail loudly — it just turns out, at the worst moment, never to have been load-bearing.

SNT-TC-1A or CP-189: what you are actually choosing

SNT-TC-1A is a recommended practice. Its tables are recommendations, and the employer's written practice is the controlling document; deviation is permissible where the employer documents and justifies it. That flexibility is genuinely useful — a terminal that runs only ultrasonic thickness measurement and visual examination has no business copying a nine-method aerospace training matrix — but it is also the mechanism by which weak practices get written. Flexibility with no justification recorded is just a lower standard.

CP-189 is a standard, written in mandatory language, with minima that the employer cannot relax and a requirement that the NDT Level III hold ASNT certification. It removes the drafting freedom and, with it, most of the drafting failures. API 653 accepts either route for NDE personnel qualification, so the choice is commercial and structural rather than technical.

The rule of thumb we apply: if the same corporate entity also serves nuclear, aerospace or defense clients, write to CP-189 once and let one document serve every market, because those clients will demand it anyway. If the terminal is a standalone liquids operation, SNT-TC-1A is appropriate — provided every deviation from its recommendations is written down with a reason, in the practice, where an auditor can find it without asking.

What "contains" actually means, clause by clause

Most practices contain every required heading. Very few contain content behind them. The difference shows up on the training clause: a practice that states forty hours of ultrasonic training for a Level II candidate has satisfied the heading, but it has not defined the course, the syllabus, who may deliver it, what record proves attendance, or whether hours from a previous employer count. An auditor holding a certification file needs those answers to close the loop, and if the practice does not supply them the file is unverifiable regardless of how tidy it looks.

The examination clause is where the most damage hides. A practice must define the general, specific and practical examinations, the passing score for each and the composite rule, who is qualified to prepare and grade them, and how examination material is controlled. In terminals we routinely find one specific examination per method, forty questions, unchanged for the better part of a decade, stored on a drive every technician can browse. Whatever that examination measures, it is not knowledge.

The practical examination clause is the one to write carefully. It must identify the specimen set, what the candidate is required to detect or measure, how performance is scored, and who witnesses it. Without a specimen list you cannot demonstrate afterwards that the practical examination for a Level II doing shear-wave weld work covered anything other than thickness — and that gap converts, silently, into every report that technician has signed since.

Who controls the document

The employer owns the written practice and issues certifications under it. The Level III named in the practice is the technical authority: he approves the document and its revisions, approves procedures, controls examination content, and recommends certification. Those are separate roles and the practice must say which person, by position, does each. Where it is silent, the roles collapse into whoever is available, which is how a QA manager ends up signing certificates a Level III should have recommended.

Outside Level III services are entirely legitimate and extremely common in terminals, which rarely employ one. What is not legitimate is leaving that arrangement undocumented. The practice must state that outside services are used, define exactly what the outside Level III performs — approving procedures, preparing or approving examinations, grading, recommending certification, or all of it — and require evidence of his current certification by method. Auditors ask a specific question here: who wrote and graded this examination? A practice that cannot answer it has an outside Level III in name only.

Revision control is the last piece and the most neglected. Every revision needs a date, an author, an approver and a change description, and the certification forms and records in circulation must reference the revision actually in force. A practice at Rev 4 with certification forms still quoting Rev 2 clause numbers is a finding on its own, and it tells an auditor the document is not being operated.

The contractor certificates you accept but never audit

A terminal's own written practice covers its own employees, and in many terminals that is a handful of people or none. The inspection work is contracted. Which means the certificates that actually matter — the ones behind the floor scan, the shell survey, the repair weld examination — were issued under somebody else's written practice, a document the terminal has never seen.

This is the gap that client audit programmes have started to close. The question is no longer "is your technician certified?" but "under which written practice, at which revision, and may we see it?" A terminal that cannot answer is relying on inspection data it cannot substantiate, and its SPCC plan certifier is relying on it too.

The fix is procedural and cheap. Add a contractor qualification step that obtains the written practice, checks the Level III's certification by method and its expiry, samples two certification files against the practice, and records the result with an expiry of its own. We build that step, the review checklist and the acceptance criteria as part of the practice engagement, because a terminal's own practice is only half of its exposure.

How the audit actually runs

An experienced auditor does not read the written practice front to back. He reads the scope, notes the methods and levels claimed, then pulls three certification files and traces each one backwards. It takes about forty minutes and it is close to unbeatable if the files are weak.

The trace runs: certificate date and signature; is the signatory the person the practice names, and was his own certification current on that date? Training hours claimed; does a course matching that description exist in the practice's outline, and is there an attendance record with an instructor and dates? Experience hours; is there a dated record, signed by someone with standing, identifying the method? Examination results; are there graded papers, a controlled version number, a composite calculation that matches the practice's rule, and a qualified examiner? Vision; is it dated within twelve months, with the chart identified and corrected or uncorrected stated?

Then he asks one question the files rarely survive: show me the practical examination specimens. If they exist, he will ask what flaws they contain and whether the candidate found them. Terminals that have rehearsed this trace once before an audit almost never fail it. Terminals that have not, fail it on the first file.

The drift that makes a good practice fail

Drift is more common than bad drafting, and much harder to see. The practice is sound; the operation stopped matching it. The composite score rule says eighty percent and a file shows seventy-four, passed anyway. The training minimum says forty hours and the record shows thirty-two, with a note saying the candidate had prior experience — which the practice never authorised as a substitution. The recertification interval is honoured but the basis is not documented, so nobody can say whether recertification rested on re-examination or on evidence of continuing satisfactory performance.

The catastrophic version is the lapsed Level III. His certification expires, nobody notices for fourteen months, and every certificate recommended in that window is issued on an authority that did not exist. This is not a technicality an auditor will wave through, because the remedy is expensive: review, and in most cases re-recommend, every affected certification. We have seen it consume a terminal contractor's entire audit response for a quarter.

The quiet version is edition mismatch. A referencing code invokes a specific edition of SNT-TC-1A; the practice cites a different one, or worse, cites "latest edition," which makes every file in the cabinet a moving target. Set the edition to the one your governing code invokes, state it, and change it deliberately with a revision — never by drift.

What a terminal's regulator and client regime change

Terminals sit under a regulatory arrangement that surprises people who came from refining. If the site holds breakout tanks on a regulated hazardous liquid pipeline, 49 CFR 195.432 applies and points at API 653, which in turn requires NDE personnel qualified and certified under the employer's written practice. That chain gives a federal pipeline inspector a lawful route into your certification files, and inspectors have taken it.

SPCC works differently but lands in the same place. 40 CFR 112.8(c)(6) requires integrity testing on a regular schedule in accordance with industry standards, and 112.3(d) requires the plan to be certified by a professional engineer. The engineer's certification rests on testing performed by people whose qualification he has to be able to defend. A hollow written practice quietly transfers risk onto that engineer's licence.

Process safety management is where terminals should resist over-applying a rule. OSHA's PSM standard at 29 CFR 1910.119 excludes flammable liquids stored in atmospheric tanks, kept below their normal boiling point without chilling or refrigeration, at 1910.119(a)(1)(ii)(B) — so a straightforward gasoline terminal is generally outside PSM mechanical integrity for those tanks. That exemption does not extend across the fence: a pressurised butane or propane sphere, or blending with a listed highly hazardous chemical above threshold, brings that equipment back in. Write the practice knowing which parts of your site sit on each side of that line, and stop paying for a compliance posture the rule never asked for.

How Atlantis builds and maintains a written practice

We start with what the site actually does: methods genuinely in use, levels genuinely needed, the container and equipment population the certificates support, the client and regulatory regimes that will inspect the result, and whichever practice and files already exist. Existing certifications are preserved and mapped forward, never voided for convenience — the objective is a defensible document, not a restart.

The deliverable is the practice itself, the training outlines behind it, examination control arrangements, certification and recertification record templates, an interrupted-service clause the site can actually operate, a contractor qualification checklist, and a revision-control regime. Where we act as the named Level III we state the methods our certification covers, in writing, before signing anything; where a method falls outside that scope we say so and help you cover it rather than papering over it.

Then we rehearse the audit. Three files, traced backwards, exactly as an auditor would, with the findings written up as findings. It is the cheapest hour in the engagement and it is the one that changes outcomes. Consultation and scoping on request through info@atlantisndt.com.

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