by Antoinette (Toni) Bailey
Editor’s note: This NDT Ethics case study is published in conjunction with the December 2022 issue of Materials Evaluation. Published quarterly, each NDT Ethics column will present a case study and invite readers to respond here on ASNT Pulse with their comments. Readers are also invited to email column editor Toni Bailey with their own ethical scenarios, which may be featured in future columns.
Welcome to a new installment of NDT Ethics. In this month’s column we will discuss ethics in scenarios regarding production, management, and quality assurance’s (QA’s) approach to NDT, and the effects those behaviors could have on NDT. In my experience, in years past management would often use the word “teamwork” to encourage a cohesive relationship between management, quality (NDT included), and production.
Today, the relationship between NDT, quality, and management has changed significantly. There seems to be an increasingly dividing line between these three teams, who all have completely opposite goals. Let us take a look at a couple scenarios in which the reader can determine if each scenario is ethical or unethical.
—Toni Bailey, NDT Ethics Editor
___
Scenario #1:
The director of quality ignores NDT audit findings in favor of production needs.
An aerospace company had a Level III on staff who was a 30-year employee, and over the years management continually ignored his authority. QA performed all of his duties, with exception to his signature on documents. Eventually, the responsible Level III passed away. Within weeks of his passing, the company hired a new responsible Level III, who was an outside agency.
The new Level III conducted an initial audit and found multiple violations to National Aerospace Standard (NAS) 410, ASTM, and customer quality control requirements. The new Level III documented the findings and asked the director of quality to input the findings into the corrective action system. The director of quality and entire QA department agreed, but never acted on their promises to cooperate or assist in correcting the audit findings.
One year later, the company was on the verge of a major compliance audit but still had open NDT audit findings because management did not want to spend the money to fix them. The director of quality then fired the Level III and hired a new, underqualified Level III as a way to “pencil whip” compliance.
___
Scenario #2:
Due to the impact of the COVID-19 pandemic, management (engineering, production, and QA) considers NDT as a cost burden and would not support NDT training and correct certification.
In this scenario, the company had initially suffered financially from impacts during the COVID-19 pandemic, but then rebounded financially and attained new contracts that required full compliance to Recommended Practice No. SNT-TC-1A. In the past, the company allowed their inspectors to attend in-person instructor-led classroom training, where the inspector could learn the theory and receive hands-on applications training taught by qualified and certified instructors.
Now the inspectors only attend online classroom training classes and receive no hands-on training after the online training. This hands-on training is needed to ensure that the student understands and can apply the theory and acquire practical knowledge. The company claims that losing the inspector for one full week to attend “in-person training” has an impact on production needs. They only allow the inspectors to periodically attend the online training for a few hours per day over months so they can utilize them for production at the company’s leisure.
The QA manager has been keeping data on inspector knowledge, inspection results, and the impact on the product’s quality. The QA manager has noticed a decline in all areas of NDT and has data showing an increase in flawed parts going undetected and customer complaints about non-conforming products. When she (the QA manager) presented the data to the engineers and management, the data was dismissed as unrelated to NDT technical skills and knowledge, so no corrective actions were taken.
___
We now ask you, the reader, to think about the two scenarios above and determine if each scenario violates the general code of ethics. Is there a divide between NDT, management, and QA? Are NDT personnel asked to compromise their ethics for the sake of increased production or unethical management practices?
We would like to hear from the NDT community. Please comment here.
_______
Editor
Antionette (Toni) Bailey: ASNT NDT Level III/NAS 410 Level 3 (MT, PT, RT, UT, and ET), IRRSP; TB3 NDT Consulting LLC, Manorville, NY; toni@tb3ndt.com
For more information on ethics:
- NDT Ethics: Combating Unethical Certification Examination Practices
- NDT Ethics: Rewriting Your Written Practice According to Your Needs
- Professional Ethics: The Role of the “Whistleblower”
- Hear A Discussion of Ethics in NDT with Todd Sellmer in Latest Chat NDT with ASNT
- The ASNT Code of Ethics can be found on asnt.org
In composing my comments below, I assumed that the Code of Ethics that applies is the one in the link “ASNT Code of Ethics” for ASNT members:
Scenario 1:
Since it is an “aerospace company”, we can assume that there are sufficient potential “life and safety” issues. This would require the Level III to adhere to point 9 of the Code of Ethics.
Since the scenario does not say the the “under qualified” Level III actually did participate in the “pencil whipping” of any documents, one cannot conclude that point 9 was ignored by the new Level III. (The scenario does not state what capabilities are missing that made the new Level III “under qualified”)
(The scenario also does not say if the Quality Director or any other managers are ASNT Members, in which case, they would be held to point 9 of the Code of Ethics.)
So, what we have here is a failure of management to manage.
The Quality Director and other management persons (who did not want to spend money) bear the responsibility for creating or fostering a culture where “pencil whipping” is allowed and maybe even encouraged.
The “under qualified” Level III would be violating Point 9 of the Code of Ethics if the the Level III actually participated by signing off on documents without review or knowledge.
One side issue is the role and responsibility of the 30 year Responsible Level III who signed documents but whose duties were done by QA. It should be noted that NAS 410 says the RL3 is responsible for the qualification and certification process (NAS 410 Rev.5; 4.3.2), so more detail is needed about what duties QA did and what “authority” was ignored.
In any case, the primary responsibility rests with Management.
Scenario 2:
(In the interest of full disclosure, the Company I work for does provide NDT Level I and Level II courses in several Methods, both public and on site)
Scenario 2 does not state if any of the perps including the QA manager are ASNT Members and if there is an ASNT Level III on board or one provided by an outside service.
It does say new contracts required “full compliance with Recommended Practice No. SNT-TC-1A”, so some NDT Level III involvement can be assumed per 5.5 of the 2020 ASNT-SNT-TC-1A:
“The employer’s Written Practice shall be reviewed and approved by the employer’s NDT Level III”
So, as in Scenario 1, what Scenario 2 presents is a failure of management.
Assuming the employer’s Written Practice had been reviewed and approved by their NDT Level III or an outside provider, it should be noted that SNT-TC-1A does not specifically state that hands on/applications training needs to be done, let alone specify the content and contact hours for it. (If it does, please tell me where; I could not find it.) (Of course, it does state that one of the exams is the Practical {hands on} exam)
It should also be noted that SNT-TC-1A does not recommend that the Level III, be proficient in using and/or training others on using the NDT equipment in use at the Employer or the Client in the case of an outside Level III service provider.
In addition, in the course outline source mentioned in 7.3 of SNT-TC-1A, 2020 for ET and UT Level I, I could not find any allocation of time for hands on training. (Please tell me if I missed it.) The closest reference is UT level I in 3.0 and 4.0 “examinations to specific procedures”, but the text description is vague. One might conclude that “specific procedures” are Work Instructions. (I did not check other methods and Levels)
So it cannot be clearly shown that any violation of the Code of Ethics occurred in Scenario 2. It can be said that the lack of hands on training and documenting it is a world class lapse of common sense and good judgement.
What to do?
The solution starts with getting management to realize that the quality and content of NDT training is one ingredient to getting any benefit from NDT. This is not easy to do unless there is a strong NDT presence in the user Company, an attribute I rarely see in today’s production environments.
This NDT presence is rarely provided by the Quality department or Quality Manager due to the inherent differences in the two cultures. This is because NDT is Nondestructive “TESTING”, not “measurement”. The output of many common NDT methods is a signal, not a measurement output as a “number” that the Quality department can work with. (This is not meant to criticize the Quality person, nor to praise the NDT person, but only to point out one reason for the different “mindsets” between NDT and Quality.)
In any case, while SNT-TC-1A allows for organized training to also include virtual, computer based and web based training ( TC-1A; 7.1), I am convinced that there is no substitute for in person training.
So:
1. The Written Practice should include a provision for hands on application training in addition to the classroom theory course. This can also be a separate document and referenced in the Written Practice.
2. If the Instructor is qualified in the application and proficient in using the equipment in use, the Instructor can provide the hands-on training.
3. If not, the equipment vendor or vendor’s qualified rep should be tasked to provide it. ( an on-site qualified person from another department may also be tasked.)
4. The hands on training is more effective if done before the classroom part. The attendees will be in a better position to ask questions and challenge the material presented in class.
5. Hands on training should also be repeated if new equipment is installed, regardless of certification status to assure qualification. Note that while SNT-TC-1A does address Technical Performance Evaluation (TC-1A: 10.0), certification under SNT-TC-1A is not NDT equipment model/brand specific. That is: certification does not lapse if different equipment doing the same test is purchased.
6. For new start-up NDT installations, it is absolutely necessary that the user Company insist that no classroom training and testing be done until the equipment vendor has installed and checked out the NDT and ancillary equipment, and passed the Final Acceptance Tests, if required.
7. It should also be noted that one key ingredient needed for the hands on training is a relevant Work Instruction.
I will also suggest that hands on training today’s heavily software based equipment, PAUT for one example, is initially better done by the vendor, for obvious reasons.
In conclusion, while violations of the Code of Ethics might be debatable, there is no doubt that both scenarios illustrate basic conflicts between NDT, Management and QA. I have seen these divides for many years, but have no insights on eliminating them.
Respectfully submitted at Wexford PA USA by:
Patrick W. Sansieri, ASNT Certified NDT Level III, UT/ET/MT, # 17434
NAS 410 Level 3, UT/ET
PWA SIM 4 Level 3
Toni: I clicked the link to the “ASNT Code of Ethics” and see that it is the one for “members of the ASNT. Will now have a look at the scenarios.
Toni: did you mean the Code of Ethics for ASNT Members or the L3 COE-Rev. 02 for ASNTLevel III’s. I assume the latter, but wanted to check with you b/c it says “general code of ethics” in the last paragraph on page 72.
Great article Toni. Scenario 1 is one I’ve seen far too often with manufacturing companies who perform in house NDT. Quality and NDT should never report to Production. Ideally the individual who was fired would speak up about these issues to initiate some deeper investigations by that customers end user.
Scenario 2 is interesting. While industry approved online classroom training has come a long way the key word there is “classroom”. Our company does sell that service but we make it VERY clear that this is for the classroom portion only. We impress upon our clients that they are then required to go through the approved hands on/OJT requirements spelled out in NAS-410 or SNT-TC-1A. We will also recommend companies we work that our clients can contract with that can assist in the OJT portions of the certification process. It is imperative in scenario 2 to explain the entire complaint process.
Hola Tony. This is Toni Bailey replying and it seems that we Tony/Toni folks think alike haha. Thank you for taking the time to respond and for commenting on the post. I will have to contact by phone about scenario #1. I personally experienced something similar but I was not fired, I decided to no longer represent the company as the outside Level 3.
For scenario #2, you are very correct about the company’s responsibility to provide hands-on training after the online training. Some companies do a great job with the follow-up. Unfortunately these days, companies NDT departments are not managed by the Level 3s but rather they are managed by production. It’s difficult to get people trained in person, online, or even through osmosis haha 😄. I don’t know what the solution is.
I feel QA, Engineering and Production people just really need more Ethics and Risk training. There is a further divide between NDT and those in management and it needs to stop soon. Many blessings to you Tony and let’s chat soon!