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Industrial Plant & Structures
NDT and It's Importance to Industrial Plants and Equipment
Smallbone C, Executive Director, Welding Technology Institute of AustraliaContact
| Home Table of Contents Industrial Plant & Structures | NDT and It's Importance to Industrial Plants and EquipmentSmallbone C, Executive Director, Welding Technology Institute of AustraliaContact |
Major changes to business, industry and governments are taking place globally. Regulatory changes in Australia are towards competition, self-regulation and reduced prescriptive regulations and reduced government inspection and advice. This places much more "duty of care" on many manufacturers and users of a welded plant.
To cope with this, industry is making a significant revision of Australian standards to provide optimum practices for industry. However, manufacturers and users need to recognise these changes and make appropriate modifications, but they should also take this opportunity to improve their performance.
Recent initiatives to help industry include guidance on optimum welding/fabrication management systems, the introduction of a major industry co-operative network for the welding/fabrication industry, and the changes in certification to encourage competence of personnel.
A unique international approach on controlling the quality of welding is explained in some detail.
A table has been prepared showing how a number of countries have introduced qualification and/or certification programmes to promote the use of competent personnel in the engineering field.
A recommendation is made to make such programmes international or at least regional.
The importance of maintaining the integrity of such programmes is emphasised.
KEYWORDS: Self-regulation, Risk Management, Management Systems, Competence, Network
Major changes to business, industry and governments have been taking place globally during this decade. It has not yet stopped. In Australia, there has been an important general move by legislation for greater industry self-regulation and substantial change in Government involvement.
The implications of self-regulation legislation for Australian business and industry - particularly for those manufacturing or using welded plant and equipment are significant. These changes greatly increase the importance of proper risk management of business, OHS, environment and effects on society. Recent societal examples are power supply in New Zealand and Queensland, water in Sydney and gas in Melbourne.
OHS changes, particularly those removing prescriptive requirements and government inspection and advice, now place much more duty of care on manufacturers and users than most appreciate. Thus, national and company strategies and actions are needed to minimise all of these risks economically to ensure compliance with legal obligations, to meet business performance targets, and to be competitive.
While meeting new legal obligations may be a main focus, advantage should be taken of this opportunity to improve all operations when this is needed and is practicable. Improvements are more likely to be needed in knowledge of the changing local and global position, in competencies at all levels (particularly in management and areas replacing government controls), and in technology (5).
Some national initiatives already being taken to assist improvement are also outlined i.e., provision of optimum plant; competence of inspection personnel; and a major national network being implemented through a $10.5 million Technology Support Centres Network Project.
The Commonwealth, States and Territories have made significant moves toward industry and business self-regulation. These became clear at the time of the 2nd Russian Revolution in 1991 when the world recognised the value of democracy, competition and reduced governments. Australian business and systems do not need wide ranging detailed controls by governments which was so essential in the very early days of colonization; banking, tax etc and particularly OHS are examples. Basic objectives are the same and regulation still requires proper actions and outcomes - however with the government role modified to largely enforce and monitor performance.
This fundamental change recognises that:
In the areas of OHS, the National Standard for Plant 1994, has and is forming the basis of State/Territory laws which use self-regulation by industry. Plant OHS incidents cost over $500 million/year in worker's compensation claims, and the expected cost of implementing this standard is $4.7 billion over 10 years. It places clear duties in general terms on various parties - designers, manufacturers, suppliers, employers (user/owners/operators), contractors and employees to suitably manage and minimise OHS risk.
There have been extensive inquiries into OHS by Worksafe Australia, by all States/Territories, by the Industrial Commission 1995, by a NSW Parliamentary Committee and by WorkCover Authority NSW. The trend is for the new OHS Acts etc to apply to all industry and business and could apply to mining.
Similarly, legislation for controls of environment and of major hazard facilities is in place or shortly to be in place throughout Australia.
The move in these three areas of legislation is for suitable controls to manage risks to as low as reasonably practicable and aim to improve. Some guidance is given on "reasonably", but final interpretations will be given by courts and will depend on many factors.
An excellent paper on "Risk Assessment and Risk Management - Developments and Liability Law" - 1994 by Patrick Ibbotson, highlighted many lessons to be learned by industry and advised on legal goals of risk management systems:
Almost all of these goals should be achieved by strategies outlined below.
AS/NZS 4360 Risk Management gives an excellent outline of the elements required to manage all types of risk. It is qualitative but allows for quantifying risk when this is necessary. There are many other excellent references and Standards which deal with general approach to risk.
3.2 For industry, it is necessary for each particular sector to provide more specific yet simple guidance on risk management. Some are given in the National Standard for Plant, others as Codes of Practice by Government bodies, and a number covered in Australian Standards.AS/NZS 3931-1998 Risk Analysis of Technological Systems - Application Guide is identical with IEC 60300-3-95 Part 3 Section 9. This focuses on technological risk.
Fig 1: Pressure Equipment Standards
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Australian Standards dealing with Pressure Equipment used in the Petro/ Chemical, Power and most other industries already include sections on risk management for pressure vessels (AS 1210); operation/maintenance (AS 3873); in-service inspection (AS/NZS 3788); and pipelines (AS 2885). Fig 1 shows the latest arrangement of many of these standards.
3.3 Regulatory requirements still vary significantly and probably none of the above Standards will be mandatory for general industry and possibly for mining in the future. It is recommended for major business however, that they be complied with where their requirements are applicable or are not improved upon. This is one of the main results of a more flexible policy. For SMEs who do not have sufficient time and resources, these Standards provide an excellent guide but obviously may not cover every aspect of an enterprise. 3.4 All of the above Standards are a distillation of world wisdom, experience and R&D. Compliance with these Standards goes a long way to complying with law and should ensure continued coverage by insurance policies. 3.5 The information and experience available indicates that a number of companies have reasonable strategies and systems to cover the above matters, but many do not or are unaware of the impact of legislative changes. Overall industry's performance can and should be improved. 3.6 One area of concern is the major interface between business and contractors of all types. This is increasing as a result of down-sizing on both sides at the time when government inspection has been removed or reduced. It requires particular attention if the risks to business, OHS and environment are to be managed properly by both groups. The law is currently not clear on risk management by purchasers of hazardous plant but users are first in line for legal action.Many others and SMEs (who are so important for welded plant equipment and products) should also take this opportunity to benefit from these changes.
4.2 Excellent guidance on many aspects is given in the above new Standards and should be used where applicable. Companies should also consider planning however, to review their whole operations for improvement over the next year or two by reviewing business plans and overall management systems (documented or not). 4.3 For the reasons listed earlier and to help improve the performance and competitiveness of SMEs and their interaction with major organisations, WTIA, with others, is introducing a series of Expert Technology Tools (ETTs). These will help create improvement across the range of management systems such as Quality, OH&S and Environment, as well as give substantial technical support in numerous areas. 4.4 General support and encouragement from industry should result in benefits to all - including reduction in workplace incidents, worker compensation premiums and costs, and improved overall performance by doing it right first time, on time and on budget.To meet the above goals and be competitive it is also necessary that an organisation be competent i.e. it and its personnel at all levels must have the appropriate knowledge, experience and skill and also the ability and systems to use them effectively.
For industries which rely heavily on technology, the need for competence in technology and its application is essential. In the USA and UK in the mid 1800s there were huge numbers of deaths/year due to mining incidents or boiler explosions, but now are much less - less than 1% of the earlier numbers for boilers. However, the major incidents noted in the introduction, the accidents in mining and failures still occurring in industry, confirm that continual improvement in performance should be a company policy. Generally the Australian industry has done an excellent job.
With safety there is no fixed safe standard but the aim is to reduce to "as far as reasonably practicable" (AFARP) and to keep improving. This is also essential to be competitive. Competence is the key.
No organisation has all the expertise - competence (i.e., knowledge, experience and skill) for all matters it is involved with. Australia has collectively great competence however, but this is not always available because of the difficulties resulting from our State/Territory System, great distances and smaller companies.
To help industry become globally competitive, a major National Technology Support Centres Network Project was initiated in 1998 by WTIA with major support from DISR, Federal , State and Territory Governments and leading players in industry. Contributions totalled $3.5 million for the initial 3 year period(1).
The objective of this project was to harness national competence through a network of over 100 organisations and many persons cooperating for mutual benefit while still maintaining confidential information and competition. In this way:
The focus was on the provision of quality products and services relating to welding in its broadest sense i.e. design, materials, manufacture, installation, operation, maintenance and inspection. Not so long ago a "one-liner" overseas provided the key to saving above $10 million in avoiding panic shut down of major plant with cracked welded piping.
Included in the network were many major players in industry where cooperation and feedback is improving through:
This project was so successful that DISR, State and Territory Governments and industry have extended the Project into the $10.5m SMART TechNet Project.
People make things happen and hence there is a need to ensure the availability of the necessary numbers of competent people in all important sectors.
Pressure equipment design approval, fabrication inspection, and commissioning and periodic in-service inspection of boilers, is virtually no longer required to be done by government personnel. This is part of the self-regulation. Major industries like the petro/chemical/mining/power, which use plant that wears out and is complex and critical, recognise the need for competent purchase, operation, maintenance and inspection. Fig. 1 shows the almost complete revision of major pressure equipment standards for design, manufacture, supply and operation which will help industry.
For example, AS/NZS 3788 Pressure Equipment In-Service Inspection gives excellent information and has been revised to extend its risk-based requirements to allow for more flexibility where risk-based inspection (RBI) is used competently. The American Petroleum Institute is reported to have spent about $700 million on developing a major RBI Standard for the petroleum industry. A major Conference(5) was recently held in Australia where many examples of RBI and its successful use around the world were presented.
To drive the above, competent people are needed. Hence, in the field of welding, fabrication, pressure and other equipment the following actions are being or have been implemented to help industry comply with risk responsibilities and at the same time be competitive:
The certification systems for pressure equipment, welding and NDT personnel:
With the advent of globalisation, there is a growing need for internationally recognised qualification and certification programmes.
Companies such as owners, users, manufacturers, fabricators, constructors, maintenance organisations are being required more and more to show that they are utilising competent welding personnel particularly related to safety critical equipment (2)(4).
The competence of the company and its welding personnel is a key feature of two ISO Standards ISO 3834 "Quality Requirements for Welding-Fusion Welding of Metallic Materials-Parts 1 to 4" and ISO 14731 "Welding Co-ordination: Tasks and Responsibilities" respectively.
A key driver for these Standards has been the European Codes which are based on directives from Brussels. Directives specify the fundamental safety criteria for products and structures.
It is important that companies can satisfy the above Standards by being in a position to demonstrate the competence of the people they employ or engage to carry out welding and welding related functions.
Good management systems and procedures, as summarised in ISO 3834, are essential for optimum fabrication, construction and maintenance. However good these may be, it is the competence of people which is the key to success in any organisation. In welded components this fact is recognised in ISO 3834 in which manufacturers are required to appoint competent Welding Co-ordinators to take responsibility for the 'co-ordination' of welding operations.
9.1 Introduction
Welding coordination is basically ensuring that welding related tasks are properly performed and recorded. ISO 14731 provides more details about the specific tasks which Welding Co-ordinators are expected to undertake. Table 1 summarises the list of tasks and responsibilities in ISO 14731, and the selection of those appropriate to any organisation will depend on the nature of its activities and products.
| Task | Task |
| Contract review | Equipment |
| Design review | Fabrication procedures |
| Materials | Inspection and testing |
| Welding consumables | NDT |
| Welding operations | Assessment of inspection and testing results |
| Working environment | Weld repairs |
| Health and safety | Acceptance |
| Weld procedures | Documentation |
| Table 1: Welding Co-ordination - Tasks and responsibilities | |
The scope of welding co-ordination appropriate to each company will usually be decided by the manufacturer/contractor, but could be imposed by contract requirements or an application standard.
The identified scope may be the responsibility of a single person or the tasks may be spread over a number of persons. Job specifications will demonstrate how the welding coordination activities are to be covered, and ISO 3834 expects these documents to identify the tasks and responsibilities assigned to each member of the welding coordination team.
The type and number of welding co-ordinators required for a particular company will therefore depend on the size of company, the technology used or required by the company, the complexity of the products or services involved and the code or customer's requirements.
ISO 14731 also recognises the category of Authorised Welding Coordinator, notionally the person authorised to sign for all welding matters on behalf of the organisation.
The welding coordinator will almost always have dual function, particularly the Authorised Welding Coordinator such as in small companies, the Quality Manager, Works Manager or Technical Manager if suitably qualified and experienced could be appointed. In larger companies, the Welding Engineer, Technologist or Specialist may be the Authorised Welding Coordinator.
9.2 Demonstration of Knowledge
All welding coordination personnel must be able to demonstrate adequate technical knowledge, skill and experience to enable the assigned tasks to be performed satisfactorily. Each member of the team will need to show that he or she has appropriate general technical knowledge related to the tasks and products involved. In addition, each member must have had appropriate experience to show competence in undertaking their assigned tasks.
The requirements covering Authorised Welding Coordinators are more explicit. ISO 14731 requires a minimum of three years appropriate experience, and specifies three levels of technical knowledge related to the nature and complexity of the products.
These 'Recommendations' are not a mandatory feature of the Standard, but they do provide an unambiguous route for a company to demonstrate that the knowledge requirements for the company's Authorised Welding Coordinator are met. It is also clear that 'acceptable national qualifications' suffice in this respect.
When the Standard was drawn-up, there was no International Institute of Welding qualification programes, hence, the European Welding Federation (EWF) programmes.
International Institute of Welding Qualifications
The International Institute of Welding (IIW) launched an international system in July 1997 for the qualification of welding personnel and these cover:
The IIW qualifications are intended to testify that the holder of the qualification has been able to demonstrate reasonable familiarity with a body of welding knowledge as defined in the appropriate syllabus. They are a statement of training and academic attainments but do not identify current competence of the holder to do a particular job. The EWF programmes have now amalgamated into the IIW ones.
WTIA reviewed Australian Qualifications and Certifications to align where practical with IIW requirements, and submitted existing Australian qualifications for recognition under the IIW transitional arrangements. Besides 26 countries already recognised through the EWF and hence IIW, China, Japan, USA and Australia have also been recognised.
It is intended that these IIW qualifications will satisfy the appropriate welding coordinator and be recognised in ISO 14731, and thus assist industry and personnel.
The IIW qualification is confirmed by the issue of a diploma which, like a university degree, is valid for the life of the holder.
This IIW system is now fully supported by the 40 member countries and will become increasingly important.
9.3 Certification of Personnel for Welding Coordination
Welding coordination is a job function and it is the responsibility of the company employing the welding coordinator to issue an appropriate certificate of competency within the company's welding management system (ISO 3834). This certification does not require any official third party blessing but ultimately only client blessing.
Certification requires on-going surveillance of job activity and competence and is subject to periodic renewal by the employer. Besides being an excellent concept to control quality and reduce failures, it also assists a company whether in fabrication, construction or maintenance to improve its competence and competitiveness.
ISO 14731 "Welding Coordination: Tasks and Responsibilities" does not discriminate against welding coordinators educated in schemes other than those devised by IIW or EWF but the process of compliance with ISO 14731 may be more prolonged if the company has no IIW qualified personnel at its disposal. This could be so in the future as the scheme is gradually implemented, particularly for work outside one's country.
It is useful to define the terms qualification and certification as used in this paper. Qualification is evidence of education, training, and knowledge gained.
Certification is the procedure by which a Certification Body gives written assurance that a person is competent for a specified class of work. The document issued is a Certificate of Competency.
A Qualification is valid for life and cannot be withdrawn if earned correctly e.g. a degree, IIW diploma.
Certification however can be withdrawn either by an employer of the person's services or the organisation issuing the certification, if it can be proven that the person's competence has dropped below the competency standard required for certification.
It can be re-issued upon proof of satisfactory competency returning.
Some important questions on certification arise which are worthy of discussion.
When an organisation such as AINDT, CSWIP, AICIP or AWS issue their certification to an individual, they are stating that the person certificated was found to be competent, on the day examined, against the competency standard. It is then the responsibility of the organisation employing that person's services to ensure his/her competency for the job required.
In this era of self-regulation, one would hope that this would not be a problem with organisations such as power stations, petro chemical companies etc. Consider however, the dry cleaning shop in a busy shopping centre, which previously was subjected to annual inspection by a competent boiler inspector. How does one ensure that such an organisation's owner honours his/her 'duty of care' and continues the competent inspection process? In these days of outsourcing, how does one ensure that a certificated person honours the "Code of Ethics" he/she signed.
With the globalisation of world trade now a fact, the internationalisation of personnel qualification and certification programmes either through mutual recognition agreements or truly international programmes is moving closer.
Table 2 shows a first draft showing the organisations in a number of trading countries who have Q&C programmes for associated personnel.
| Country | ||||||||
| Types of Personnel or Company Programmes | South Africa | Australia | U.K. | USA | Canada | New Zealand | International Standards | |
| Non-Destructive Testing Operators | SAQCC(NDT) | AINDT | PCN CSWIP | ASNT | CGSB | CBIP | ISO 9712 | |
| Welding Inspectors | SAIW | WTIA | CSWIP | AWS | CWB | CBIP | IIW Potential | |
| Fabrication Inspectors | SAQCC(IPE) | WTIA | - | National Board | - | CBIP | - | |
| Design Verifiers | - | I.E.Aust | - | - | - | I.PENZ | - | |
| Welding Supervisors | SAIW | WTIA | CSWIP | - | CWB | N.Z.I.W | - | |
| Welding Engineers | University | University | University | University | CWB | N.Z.I.W. | IIW (Q) (1) | |
| International Welding Engineer | - | WTIA (Q) | CSWIP (Q) (C) | AWS (Q) (C) | - | WTIA (Q) | IIW (Q) (1) | |
| International Welding Technologist | - | WTIA (Q) | CSWIP (Q) (C) | AWS (Q) | - | WTIA (Q) | IIW (Q) (1) | |
| International Welding Specialist | - | WTIA (Q) | CSWIP (Q) (C) | AWS (Q) | - | WTIA (Q) | IIW (Q) | |
| In-Service Inspectors of Pressurised Equipment | SAQCC(Competent persons) | AICIP | - | National Board | National Board | CBIP | - | |
| Pressure Equipment Cos | - | - | CSWIP | ASME | ASME | - | ISO 3834 | |
| Structural Fabrication Cos | - | - | EN 729 | AISC | CWB | - | ISO 3834 | |
| Inspection Cos | - | NATA | - | - | CWB | - | ||
| Table 2: some Organisations Offering Q & C Personnel and Company Programmes | ||||||||
| SAQCC(NDT) - South African Qualification and Certification Committee (Non-Destructive Testing) | CGSB - Canadian General Standards Board |
| SAIW - South African Institute of Welding | AWS - American Welding Society |
| SAQCC(IPE) - South African Qualification and Certification Committee (Inspectors of Pressurised Equipment) | ASNT - American Society for Non-Destructive Testing |
| AINDT - Australian Institute For Non-Destructive Testing | CWB - Canadian Welding Bureau |
| WTIA - Welding Technology Institute of Australia | CBIP - Certification Board for Inspection Personnel |
| I.E.AUST - Institution of Engineers, Australia | NZIW - New Zealand Institute of Welding |
| CSWIP - Certification Scheme for Weldment Inspection Personnel | IPENZ - Institution of Professional Engineers New Zealand |
| NATA - National Associations of Testing Authorities | AICIP - Australian Institute for the Certification of Inspection Personnel |
Note 1. The EWF offers these as both Qualification and Certification Programmes.
Note 2. This table is being circulated to organisations in many countries both to verify the facts as well as update the table with more information.
The examples of the IIW qualification programme, the ISO 17431 involving certification of welding personnel, and ISO 9712 for the qualification and certification of NDT operators, are good for the world.
Now that the IIW and EWF programmes have amalgamated, there is an opportunity for an international qualification in welding inspection and possibly a certification programme for welding inspectors arising.
Bridging agreements already exist for the latter between AWS-CSWIP and CSWIP-SAIW.
If one considers programmes for design verifiers, in-service inspectors of pressurised equipment and fabrication inspectors then one encounters greater challenges in moving to international programmes. Initially the wisest move may be to work on a regional basis. In the South East Asian Region, discussions are taking place to utilise the Australian certification programmes, suitably modified, for these regions. Although there is a lot of work to do on this, it is definitely a move in the right direction.
No matter how good the intent in a country or an industry to have programmes to measure a person's competence, the value of those programmes can be disastrous if they are not administered through a system of high integrity.
One wonders about the ethics and morality of individuals and organisations who allow the culture of honesty to diminish.
Consider a few hypothetical cases as to where integrity can ruin the confidence in a particular programme whether based simply in a company, nationally or internationally.
This used to be known as being "blessed with the holy water". Also, within that system, there was always the problem of the trainer and the examiner being the same person, leading to concerns as to the validity of the final examination results.
The EN Standard has now been converted to an ISO Standard. The first question that should be asked for any certification programme is whether the organisation has a Management System conforming with EN 45013. Also, one will find organisations claiming that they are accredited organisations in accordance with the Standard but in reality, the independence they are talking about doesn't actually exist.
Again being hypothetical, consider the consequences if these three questions cannot be answered truthfully, satisfactorily and with confidence. The 'system' would fail.
If people are sitting on an examination panel who have been training students undertaking the examinations, this would automatically point to a conflict of interests.
Consider a hypothetical case of a person being fired for major fraud from a company, manipulating the interviewing panel for the position of administering a national programme, not disclosing that he had been fired for fraud and being appointed in charge of the examinations, qualification and certification of people in the National Scheme.
The question of integrity of people involved in such schemes is raising its head throughout the world. The problems with programmes such as the SNT-TC-1A have been raised and it is pleasing to see that ASNT has moved more to the independent examinations as laid down in Standards such as ISO 9712 and in other programmes such as for Welding Inspectors, IIW Welding Engineers etc.
The IIW programmes previously mentioned now involve 30 countries. It is phenomenal that throughout the world, so many countries can have a united programme. It is therefore interesting to note that now that the IIW International Authorisation Board has been established and numerous Working Groups set up to ensure the continuing harmonisation of those 30 countries in this field, the question of procedures to avoid conflict of interests is being dealt with seriously.
A Working Group has been established by IIW to consider this whole issue and to attempt to ensure that no incidents can occur that can affect the integrity of this truly international programme.
In 1995, the author, through the South African representative to ISO TC proposed that ICNDT establish a similar administrative system to IIW or the EWF.
These have been very successful and it would be interesting to see what system ICNDT has introduced to control the international system to ISO 9712.
In this era of self-regulation, one area of concern is the major interface between business and contractors of all types. This is increasing as a result of downsizing on both sides at a time when government inspection has been removed or reduced. It requires particular attention if the risks to business, OH&S and environment are to be managed properly by both groups. Users will be first in line for legal action if things go wrong so they should be proactively ensuring that the contractors, including the organisations providing the qualification and certification of personnel, are of the highest integrity. It is very difficult to hide the truth when one is giving evidence in a courtroom. Individuals not rectifying cases of lack of integrity which they are aware of, are as guilty as those having the lack of integrity.
Governments in particular have provided a great opportunity for industry to become more competitive through competition, greater flexibility and self-regulation. Industry needs to respond and make necessary changes and to continue to improve. This includes ensuring the integrity and reliability of plant, equipment, structures etc. are maintained.
In Australia, recommendations to industry encourage it to:
As stated earlier, problems in one country can have significant effects in others.
A key recommendation is that the trading partners amongst others mentioned in Table 2 should work together to create internationally accepted qualification and certification programmes to ensure equitable competency of key personnel.
The WTIA will continue to act as one catalyst in promoting this recommendation.
Three questions taken from a questionnaire sent by AICIP in 1997 to organisations holding Q&C personnel programmes in the inspection field to gather information on the compatibility of such programmes throughout the world are shown below.
1) In accordance with which standard has your programme/certification system been implemented?
| EN 45013 "General Criteria for certification bodies operating certification of personnel" | |
| Other Standards (Please specify) __________________ | |
| None |
| 4.1 Each person signs a sworn affidavit that he/she has not been charged, or found guilty or dismissed for any corrupt or fraudulent activity. | ||
| 4.2 The independent auditor has the right to assess such people. | ||
| 4.3 Office Bearers, examiners and CEO need to supply written references from their employers during the previous 10 years. These are then verified. | ||
| 4.4 Only Office Bearers and Examiners are assessed e.g. Chairman, CEO,Secretary, Treasurer, Examiner | ||
| 4.5 Other: |
Reason for Question; If an office bearer or other responsible person was ever found to have been guilty of corrupt or fraudulent activities either through legal channels or being dismissed from previous employment then this would cast great doubt on the credibility of the certifications issued whilst that person was involved in the programme.
Australia is endeavouring to achieve high credibility in this area and for international mutual recognition to succeed, countries need to have confidence in each others programmes.
8) With reference to the criteria for the eligibility of a person to be an examiner or member of an examination panel, do you restrict such positions to those who:
| 8.1 will never apply for certification | ||
| 8.2 have already obtained the appropriate level of certification? | ||
| 8.3 Other: Trainers e.g. lecturers for approved training courses |
Reason for Question; There must never be an opportunity for people requiring certification to be accused of having access to, or undue influence over, examinations or questions for their own advantage.
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