by Greg Weaver
Editor’s note: This NDT Ethics case study, written by Greg Weaver, is published in conjunction with the June 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.
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This month we discuss an ethics situation regarding the development of a company’s written practice that did not meet the intent of Recommended Practice No. SNT-TC-1A or customer requirements. We are using an example of unethical behavior by a company regarding the qualification and certification of nondestructive testing (NDT) personnel. SNT-TC-1A, and other standards, are designed with a simple framework for ease of implementation for the NDT method and all certification levels. Customary practice is that an employer’s written practice should, at a minimum, mimic or even exceed the intent of SNT-TC-1A or other standards required by the customer.
No matter which qualification for certification document is selected for use by the employer (SNT-TC-1A, ANSI/ASNT CP-189, NAS 410, ISO 9712, or EN4179), the intent is well defined for formal training and experience for all certification levels. The different standards do have minor differences, but in general, the levels go in sequence beginning with limited levels through Level I, Level II, and finally Level III. Per SNT-TC-1A, there is also a path to obtain Level III certification by working in a position comparable to Level II, but in those cases, the full formal training and experience requirements of Level II are required. The approach to reaching Level III is clear in all the previously mentioned documents. Knowing this, let’s discuss a scenario where a company modified its written practice to allow for a Level I to obtain certification directly to Level III without meeting initial Level II qualification requirements.
Modifying a Written Practice
In this scenario, a company rewrote their written practice to accommodate their internal needs, knowing it was outside of the governing qualification for certification requirements. The company manufactures parts for the aerospace and power generation industries. They have an NDT written practice that is based on a hybrid of SNT-TC-1A and NAS 410. They have been in business for many years and have approximately 20 certified NDT employees. Their program encompasses several NDT methods and all levels of certification, and they have several Level IIIs on staff. The method we are discussing in this scenario is ultrasonic testing (UT), and it is a method that they have been performing for many years. The highest level of certification within the UT method allowed by their written practice is Level I. This is mainly because the only UT inspection performed is simple wall thickness measurement and their previous customers did not require any level of certification in UT, only qualification.
As the written practice is limited to only allowing up to Level I, it was surprising to find that the UT inspection oversight and supervision was being performed by two Level II UT inspectors. Both inspectors stated that they were evaluated and certified to Level II by the company.
Remember, this is not possible, as there is no allowance for UT Level II within the company.
After investigation, it was discovered that the company was using previous outside formal training and qualification testing to “certify” the two inspectors to Level II, even though it was not allowed within the written practice. One of the operators may have held a Level II at a previous company, but the other only had work experience from within the current company. No experience hours were ever documented for the Level IIs. We could stop here, but it gets worse.
Level III Certification
The company won a new contract, but this customer had a requirement for a UT Level III to perform inspection oversight. So, the company decided they would modify their procedure to allow for all levels of UT certification. This is fine, but they also decided to allow for the previous “Level IIs” to test directly to Level III. This decision came from “the top down,” so the written practice was modified and away they went.
Questions
So, are these Level IIIs qualified? Should they have been certified? Will their NDT records pass an audit? Is the work they are approving valid? These are all questions that might raise more questions for the company than they intended.
We now ask you, the reader, to think about the scenario presented and determine if the company’s approach to qualification and certification violates the general code of ethics.
We would like to hear from the NDT community. Please comment below!
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Greg Weaver: ASNT NDT Level III (RT and PT) and NAS 410 (RT, PT, and UT) Responsible Level III, Weaver NDT Non-Destructive Testing & Consulting, Las Vegas, NV
Column Editor
Antionette (Toni) Bailey: ASNT NDT Level III/NAS 410 Level III (MT, PT, RT, UT, and ET), IRRSP; TB3 NDT Consulting LLC, Manorville, NY; 516-885-5007; toni@tb3ndt.com
This is an interesting scenario that appears to have gone sideways in several ways and could be a good learning tool for us all. We are all tasked with making good (ethical) decisions and are pressured sometimes by others that have differing opinions and goals. We all need oversight (audits), at times, to help keep us on the straight and narrow path!
After reading this, and keeping in mind the ethical complications, I think this is probably a “corruption of public morals.” I assume, and hope that I am correct, that the Level IIIs were not ASNT certified so the “Code of Ethics” would not be applicable. Maybe ETHICS should be added to SNT-TC-1A and/or CP105? These situations also reflect badly on ALL Level IIIs (ASNT & company certified).
Without passing on too much judgement to this particular situation, it seems that common sense and ethics seem to be hard to find. In the training of others, I try to pass on the importance of both and the possible consequences.
This all sounds very shady indeed. The fact that their written practice only allowed for Level I UT in the first place while having (2) UT Level II inspectors on the floor is ridiculous.
It is no surprise that this company went a step further and allowed these guys to certify up to UT Level III.
Did they even have a Level III to sign off on any of this?
I bet if they did they achieved the Level III status much the same way. Unclear records, written practice modifications to meet their needs, and no telling what else.
This is shameful.
Hello Eddie,
I can’t be too descriptive in my response, but I will say this:
They did have a Level III that signed off on it and I have not had an opportunity to review the new Level III records.
Thanks for the comment!
Greg
They do not meet the intent of SNT-TC-1A or the Code of ethic’s in any way, shape or form, which was in this instance was ‘corrupted’ through upper management pressure.
We have as you alluded, many schemes available, some totally ‘over policed’ to try and remove these ‘peer pressure’ scenario’s, and I for one have paid the price on my ethic’s and integrity, on in-house schemes, where the commercial facet has found the process has become just a little bit to hard, which speaks volumes, as they were previously overjoyed with the program when it was securing major projects!
I would say their approach to qualification and certification violated the general code of ethics: number 9 specifically. It appears they acted very unprofessional and disregarded any sense of safety in terms of allowing inexperienced, unqualified and uncertified “level II’s” perform work without oversight. How can anyone say that any of the inspections they performed were valid? If there were no formal training or any examination who says what they did is in compliance with what their customer paid for? The higher ups?
Are these higher ups motivated, trained or even work without the NDT area: or do they work from a “production” stand point.
I believe in the line between production and NDT and forgoing one to benefit the other never goes well. Pencil whipping some some certs’ onto someone does not justify their lack of having a qualified individual.
It seems the “bottom line” was more important here than proper training and integrity.