Editor’s note: Welcome to Material Evaluation’s new column on NDT ethics. Toni Bailey, an ASNT NDT Level III in five methods with NAS 410 Level III and IRRSP certifications, is the editor. Each month, she will present an ethics case study and invite readers to respond here on ASNT Pulse with their comments. Readers are also invited to email Bailey with their own ethical scenarios, which may be featured anonymously in future columns.
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This month, we will discuss an ethics scenario regarding the validation and documentation of work experience for initial nondestructive testing (NDT) qualification, along with examples of potentially unethical behavior when proving the validity of documentation.
All industries have requirements for the validation of an employee’s capabilities, skills, and training. NDT work experience/on-the-job training (also referred to as OJT) hours is one of the core requirements to obtain advancement in the NDT industry.
In NDT, the employer must verify that the technical knowledge and skill sets (qualification) for Level I, II, and III candidates are valid and true. The intent and/or requirement of most qualification and certification documents is that the experience hours be documented in written form and truthfully witnessed (in writing) by another qualified and certified NDT technician. The witness requirements depend on the level of NDT certification that is sought.
Let us discuss a scenario regarding some claimed Level II experience hours in NDT used toward initial Level III qualification for company certification.
A trainee was hired to work for Company 1 in the automotive industry, where she began working in the radiographic testing (RT) department performing computed tomography (CT). The candidate was selected due to her claimed two years of college studies in mechanical engineering, but she actually only attended one semester of college curriculum rather than two years. The candidate was provided 24 hours of hands-on training by the computed radiography (CR) equipment manufacturer and after the training, she continued to work unsupervised in the CT department where she accumulated 2476 experience hours. The candidate did not document these hours in written form, and there was no company NDT Level II or III to witness her work because the company was an automotive manufacturer and did not have a company written practice. Additionally, the candidate never attended initial Level I or II formal classroom training for RT.
After working for the automotive company for two years, the CT candidate left Company 1 and was hired by a new employer, Company 2, to perform CR per the ASME Boiler and Pressure Vessel Code, Section V: Nondestructive Examination (2021). The candidate stated that she was eligible for ASNT NDT Level III certification because her hands-on CT experience was equivalent to her now-required CR experience. She provided an experience letter from her prior employer, which she wrote herself on company letterhead along with her falsely stated college credentials. Company 2’s NDT Responsible Level III was brand-new and did not know that he was required to validate her credentials and did not contact Company 1. Therefore, the Responsible Level III verbally accepted her claimed credentials and approved her qualifications as meeting the company’s written practice in accordance with Recommended Practice No. SNT-TC-1A: Personnel Qualification and Certification in Nondestructive Testing (2020).
The candidate was enthusiastic to obtain ASNT certification, so she attended a 40-hour Basic refresher course and a 40-hour RT Level III refresher course, which were both taught by a certified ASNT NDT Level III in the method of RT. The candidate applied for her ASNT certification examinations by providing her experience letter and her two classroom training certificates, signing the name of her ASNT-certified instructor on the ASNT application without his knowledge. She went on to pass her Basic and RT examinations and then obtained her ASNT certification in RT. When the candidate returned to work with her new ASNT certification, her Responsible Level III immediately certified her as a CR Level III for Company 2.
We now ask you, the reader, was this candidate eligible for initial CR Level III certification for Company 2? Were the candidate’s actions considered ethical behavior? We would like to hear from the NDT community. Please engage in the conversation by leaving a comment.
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Acknowledgments
The author would like to thank Greg Weaver, ASNT NDT Level III/NAS 410 Level III, of Weaver NDT for his helpful review.
Author
Antionette (Toni) Bailey, ASNT NDT Level III/NAS 410 Level III (MT, PT, RT, UT, ET), and IRRSP, TB3 NDT Consulting LLC, Manorville, NY. toni@tb3ndt.com
There are two major issues within NDT companies that seem to amplify these kinds of ethical issues: lack of formal documentation for OJT/Classroom, and pushing through certifications during times of high production. Both are partly to blame on the nature of the industry. By giving employers (rather than an outside governing body) the right to certify, there is an inherent conflict of interest. Many companies do not want their employees to maintain OJT/Classroom logs independently, as this gives them leverage to seek a similar position from a competing company. And when production gets out of hand due to the boom-and-bust nature of the industry, there is an incentive to quickly certify new personnel to fill the gaps. This pushes companies towards a system of “here is a cert with your name on it, we will keep all the logs to prove it, just trust us”. Anyone in the industry has probably seen this firsthand.
However, this is not a viable excuse for any employer. It is their responsibility to maintain formal documentation and properly certify personnel. Vetting credentials is an integral part of any hiring process. But even lacking formal documentation (for example, only having a sheet of paper saying I have 10000 hours in X method from working at Y company), thorough testing for certification should theoretically validate said experience. Passing the ASNT RT III test does not necessarily validate this, especially when in your example Company 2 immediately certified to internal CR III which is not extensively covered in the ASNT tests. I think we have all met Level IIIs before who clearly lack practical experience, but were smart enough to pass some tests. Knowing the physics behind how a method is performed does not mean you are capable of an accurate inspection, much less audit or manage someone who is. This is where the OJT and Practical Testing comes in.
Regardless, lying about education or experience and forging signatures is unacceptable to begin with. I would only add that NDT companies really need a more clear-cut way of accurately tracking OJT/Classroom (other than just a form that personnel or managers are expected to keep up with), or perhaps a automated system of doing so to avoid it falling through the cracks.
Toni – Thank you for this column.
While it addresses; “Moral, Legal, Ethical and Fair” (topics), I care to provide comments specifically from the “Legal” prospective. Please understand, this is NOT my professional opinion as to how programs are to be imlemented. I’m presenting a LEGAL prospective.
Your paragraph 2 – “ALL INDUSTRIES have requirements for the validation of an employee’s capabilities, skills, and training….” I believe your sentence is mis-leading. There are industries that do not address NDT personnel qualification requirements.
Your paragraph 3 – “In NDT, the employer must VERIFY that the technical knowledge and skill sets (qualification) for the Level I, II and III candidates are valid and true…” I’m hung up on the word “VERIFY”. I’ll agree there are Codes and Standards regarding the implementation of an organizations Quality Program, and the NDT Qualification and Certification program could be an element incorporated into the Quality Program. However, it’s commonplace to see Code and standard cite, or incorporate by reference ASNT documents such as, i.e., (SNT-TC-1A). I cannot find the word “VERIFY” being cited in SNT-TC-1A. (I will agree that verification is a requirement of CP-189).
In your example of the individual performing CR into ASME V, (your paragraph 6), excluding the reference to SNT-TC-1A in ASME V (and the Article 2 Appendix additional training required for DRT / CRT equipment above and beyond, e.g., SNT-TC-1A), I do not know of any ASME V Code citing on an NDT personnel qualification program.
As a (previous) employer we took the initiave to “VERIFY” all qualification pre-requisites as a matter of doing our own ethical due-diligence, to assure compliance with ….. SNT-TC-1A, ASNT CP-189, ASME III (NB-5000), ASME XI (IWA 2300 and Appendicies VI and VII), MIL-STD’s, NAVSEA Standards, etc. which was incorporated into our Quality Program.
However, “OUR INDUSTRY” (ASNT NDT) needs to help. Consider strengthening documents like our “Recommended Practices”, i.e., (require these documents to addreee the word “VERIFY” (and how to conduct VERIFICATION).
Hello Marty. Thank you for your comments. Unfortunately, there is no way to capture legal accuracies for every industry nor for the specific code or standard. I am only allowed 600 to 700 words for the column and I can’t be too specific. The point of the column to address improper behavior from the individual documenting their own experience hours and using someone’s signature without approval. The point is not to address the legality codes and standards but rather to help the reader to understand that improper behavior exists in the area of documented experience hours. Thank you for writing in the blog. I am sure many can benefit from your view and maybe encourage the reader of the blog to review their own Code requirements.
Edgard, you are absolutely correct in your comments. As for the guilty person by passing ASNT, I can tell you that this person was definitely a con artist and not afraid to forge other people’s names, signatures and plagiarize documents. I am not sure about who is responsible at ASNT but I believe all matters of ethics violations are brought to the ASNT board of directors. I do know that this situation was reported to ASNT but the company involved was so embarrassed by their errors, they just fired the person and moved on without making a case against the guilty person. I hope to educate more company’s and Level III candidates about how to prevent violations in the first place. I hope to succeed and wish me luck.
Company’s 2’s NDT Responsible Level III being “brand new” does not hold any merit. If this individual is acting as the responsible Level III, he needs to be aware of the verification requirements of the companies written practice. Which brings into question, does this companies written practice require verification of Education, Training and Experience as defined by “Recommended” Practice SNT-TC-1a? The only way to answer that would be to perform an audit of the companies Quality Program. Final thought – The companies Responsible Level III needed to verify that their written practice meets the requirements of SNT-TC-1a, then implement those requirements into the qualification and certification process. To answer your original question, none of this scenario is anywhere close to being ethical.
Phil, this is Toni Bailey, author of the column. Indeed, the Written Practice does require validation of education, training and experience. Unfortunately, the Responsible Level III chose to make a decision on his own rather than reading what the Written Practice required. Thank you so much for your comments.
Toni – You nailed one of the most common ethics violation in the world of the NDT qualification and certification process. First of all the answer to your questions. No to whether the candidate is eligible for initial Level III certification and no to the candidate’s actions being ethical. Let me add a no to the ethical behavior of the employer and certifying body. This candidate is not even qualified to sit for any NDT certification level (I, II or III) examination. The ethics violation regarding formal education and the nondocumented experience hours in the method themselves should exclude this individual from holding a certification. The lack of proper documentation of experience hours is an issue that repeatedly is identified by any well conducted audit but sadly more often than not is not written up as a violation. In my opinion this is a major reason for the NDT industry’s reputation for unreliable testing results from certified personnel. If the industry wishes to improve the validity of the certification process this should be ground zero. Adding more certification testing schemes without valid verification of education, training and experience do not solve the problem they just generate more certified individuals without the basic skills to deliver accurate dependable data. Back to the basics of true verification of all prerequisite certification parameters is the answer to producing quality technicians. This added to true enforcement of ethics violations will go a long way in cleaning up the industry’s history of representing under qualified, poorly prepared individuals as certified personnel. Love the new NDTETHICS column it is long past due. Your column was well done Toni and I thank you for your efforts in this arena. You have a wealth of items to address in your upcoming columns – inadequate training programs, hands-on experience not specific to the application, poorly developed and administered certification examinations, lack of or incorrectly administered practical examinations, incorrect utilization and supervision of Level I personnel, unethical reporting, the list goes on and on.
Rod, thank you so much for your very well explained comments on this situation. The scenario actually happened, and unfortunately when I brought it up to the company’s QA and the Responsible Level III, they all defended the guilty person and were trying to justify the person’s actions. The sad thing is eventually the guilty person forged their signatures on documents which led to the guilty person being fired. However, the guilty person still has an ASNT certification and unless the company reports the person to ASNT, that person is still out there committing fraud and forgery. Unethical behavior is getting worse, which is why ASNT asked me to write about it.
This was clearly an Ethics violation. All the forgery and lies are just blatant… The more systematic issue to me is that she was still allowed to test by ASNT. Did they and do they not verify the information provided by the applicant? There are many factors here, but with the dramatic reduction of experience hours provided for a 4-year and even 2-year engineering-related degree, I would have thought that at a minimum, the education would have been verified and validated.
In Edgard’s first comment he asked, “what I don’t understand is how he got past the ASNT filters and got his Level III credentials.” I have that same question and I wonder how many other “Level IIIs” are out in the industry that should have never been allowed to test. Is the only filter whatever is put on the application?
I know a few ASNT Level IIIs that had never really performed any work as a Level II, but they are out there making decisions, and it is quite scary.
Hello Greg and thank you so much for editing this column and helping to “reign in” the emotion that I put into this TRUE story. I am so happy that ASNT acknowledged your contribution. As for ASNT vetting the applicant’s credentials, that is a very good question for ASNT. Maybe we should start a conversation on that or help ASNT understand what proper documentation should look like. Thank you for your posts on LinkedIn as well. You are truly helping to educate the next generation.
The answer to both questions are NO. It appears there were at least three times that the certification process should have been stopped and questioned. The original OJT hours with Company 1 were unsupervised and therefore invalid. The Level III for Company 2 should have required proof of her education, Level I and II classroom hours, and documented OJT hours signed off by a certified Level II or III in CR. I’m surprised that her application got accepted by ASNT. I would not consider the applicant to be ethical.
Hello Rob and wow ….. you nailed it as well. You are absolutely correct that this person slipped through the cracks 3 times. Unfortunately, the automotive industry does not meet any standards although they use NDT extensively in all methods for automotive and locomotive parts. The company’s take advantage that no one is vetting their “quality system” correctly. Company #2 missed the mark because they knew the requirements, just did not enforce them. For ASNT, maybe training is needed on how to properly validate credentials. Thank you for commenting.
I am new to ASNT and am currently a level II thermographer. However, I agree with the preceding comments. Anything built on a lie is bound to crumble. Without a firm foundation, all work completed will be called into question.
Hello Brian. This is Toni the author and welcome to the ASNT community. We are working hard to improve qualification and certification for excellent new folks like you. Your perspective is spot on and we appreciate you for taking the time to comment. I hope to meet you at an ASNT section meeting or a conference someday. Feel free to send me a friend request on LinkedIn. I would love to stay in touch and encourage your career. Here’s my profile: https://www.linkedin.com/in/toni-bailey-19407811
Being someone who has been associated NDT and the automotive industry for over 20 years, I can so relate to this terrible example. The candidate failed, and certain parts of the system failed also. As to the basic question of wheather the candidates actions were ethical; of course they were not the minute she falsified or forged documentation. This would not be an example of integrity in the NDT environment or in any other environment that I have lived in. I was always told there was a reason why ASNT recommended experience (hrs.) plus training. Just because you had equivalence in one, did not override the need for the other. A person may be “Qualified” to do the job, but that does not mean they are therefore “Certified”. Of course the broader the method (eg. RT), the more requirements there should be.
Thank you, so much Harold for commenting. My background is Aerospace, I am an ASNT Level III and I am certified per NAS 410. I am a trainer for a few automotive companies, but I am not the Responsible Level III because many automotive companies do not want a true qualification & certification program. I find that most of them they do not want to invest in the cost of quality assurance correctly. Since digital radiography is used extensively in automotive, I am constantly seeing unethical people slip through the cracks. Some of them go on to acquire SNT-TC-1A, NAS 410 and even ASNT certifications, without proper documentation of training and experience. The scenario that I wrote about is not uncommon. I feel the NDT industry as a whole has a training gap and need more education on ethics.
Not a surprise that someone feels that they are entitled to a position because they bought into their own lie. Not only is this unethical, the company should terminate this employee for falsification of documents. I don’t believe that any organization would allow this individual to have this much responsibility and cause irreversible damage to the company or even worse, to an individual. I would also question the level III ability from Company 2.
Hello Ernest. You are correct that it is not a surprise because computer graphics allows more ease of falsification of documents. ASNT used to require signatures to be validated by Notary republic. Maybe we should go back to this type of signature validation or some form of verification of credentials. The sad thing about the scenario is the person could not stop their illegal behavior and was eventually fired but now the person left a mess for the company to clean up. Thank you so much for your excellent comments.
This is all too common an issue. You are nearly always found out. The candidate made false representation so clearly did not meet the requirements and puts in doubt the credibility around all the work undertaken. The other problem is pencil whipping i.e., just not going through the correct checks and balances and verifying that items are correct. If you are unable or disinterested in doing accurate verification just decline to be involved. The buck stops with the originators not the system. The system has gaps because we need ‘affordable’ systems. remember certification and competency to do a specific task are not the same thing.
Seems cut and dry to me. The candidate built the entire line of experience on a lie and continued that lie. Gross repeated ethics violation in my opinion. No certifications should have been issued and any that have should be revoked.
Failure to validate and obtain objective evidence of experience in accordance with a written practice is a failure on Company 2’s Level III. The written practice is a documented procedure that should be reviewed and followed to ensure compliance and/or prevent non-compliance.
Hello John and you hit the nail on the head. As the company’s designated examiner, I asked for the credentials before testing them and yes they were found out. Later, other auditors caught violations, pencil whipping and flat-out incompetence, so the person was eventually fired. Thank you so much for commenting.
Hello Jesse. You are correct that a person who lies and grossly violates ethics continually generally is unethical in all things. I was an outside agency brought in to test the person and I did ask the company to revoke certifications. Eventually, the person got themselves into more trouble and was fired but the guilty person left a mess for everyone else to clean up. Thank you so much for your comments.
I believe that one of the flaws is that the Level III person in charge of Company 2 did not fully fulfill his function of reviewing both the experience certified by Level III, the Level of Studies accredited by the institution where he studied, and the Level I or Level II prior to obtaining your Level III.
The Recommended Practice is very clear and easy to understand regarding the requirements that must be met to qualify for a given method and Level. It is not necessary to be Level III to verify that a candidate meets or does not meet the requirements and one of them is to be first level II before level III and have at least two other minimal techniques as level II.
What I don’t understand is how he got past the ASNT filters and got his Level III credentials; Something that is requested when applying for the exams is the ASNT Level III endorsement of the documentation. Who else is responsible for not complying with the codes of ethics that are handled within the Association?