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Approval of NDT Personnel under the Provisions of the European Pressure Equipment DirectiveJohn Thompson
Manager, Certification Services Division, British Institute of NDT
1 Spencer Parade, Northampton NN1 5AA, United Kingdom.
The Pressure Equipment Directive (97/23/EC), which was formally adopted by the European Parliament and Council on 29th May 1997, and was published in the Official journal of the European Communities No. L181 of 9th July (ISBN 011 916 0927), entered into force on 29th November 1999.
The purpose of the directive is to harmonise European national laws regarding design, manufacture and conformity assessment of pressure equipment and assemblies (vessels, storage containers, heat exchangers, shell and water tube boilers, industrial pipework, safety devices and pressure accessories).
The Qualification and Certification requirements for NDT personnel as specified in the harmonised standards are clear, but what are the requirements for NDT personnel when a harmonised standard is not invoked?
This paper will discuss the requirements of the Directive in terms of approval of NDT personnel, and explain how those bodies notified as 'Recognised Third Party Organisations' confer 'Approval' upon NDT personnel.
Within the Directive, Pressure Equipment is categorised at four levels (I to VI) according to degree of hazard: category III and IV equipment, with potentially the greatest hazard, will require conformity assessment by 'notified bodies' and 'recognised third party organisations'.
The following extracts are relevant to this paper:
97/23/EC Article 13 clause 1: Members states shall notify the Commission and the other member states of the third party organizations which they have recognised for the purposes of the tasks referred to in Annex 1, sections 3.1.2 and 3.1.3.
97/23/EC Annex I clause 3.1.3: Non-Destructive Tests. For pressure equipment, non-destructive tests of permanent joints must be carried out by suitable qualified personnel. For pressure equipment in categories III and IV, the personnel must be approved by a third party organisation recognized by a member state pursuant to Article 13.
97/23/EC Annex IV: Criteria to be met when designating the notified bodies referred to in Article 12 and the recognised third party organizations referred to in Article 13.
prEN 13480 : part 5 - Inspection and testing - clause 8.4.3 (Personnel qualifications). Personnel performing tests shall be qualified and certified in accordance with EN 473 for the appropriate testing method (this requirement is repeated in clauses 8.5 to 8.9 which cover NDT methods VT, MT, PT, RT and UT).
prEN13445 part 5 - Inspection and testing - clause 2 (Normative references) includes reference to EN 473.
prEN13445 part 5 - Inspection and testing - clause 188.8.131.52.7 (Qualification of NDT personnel): NDT personnel shall be qualified and certified in accordance with EN 473 except for visual examination and leak testing (for which personnel shall be qualified but not certified). NDT personnel shall hold an appropriate certificate of competence at level 1, 2 or 3, as appropriate, which is delivered as described in tables H-1 and H-2 depending on the conformity assessment module (tables H-1 and H-2 state that for category III and IV equipment, qualification and certification of NDT personnel may be (is?) carried out by recognised third party organisation).
At this juncture information is provided on how the requirements of the PED have been addressed at the national level in the United Kingdom, where the Secretary of State has appointed the British Institute of Non-Destructive Testing as a Recognised Third-Party Organisation under regulation 20 of the European Pressure Equipment Regulations (1999)
The scope of the appointment is for the approval of personnel to carry out non-destructive tests on permanent joints for pressure equipment in categories III and IV in accordance with section 3.1.3 of Schedule 2 to the Regulations. The UK Secretary of State has accordingly notified the European Commission and other EEA States of this appointment to act for the purposes stated above.
If a 'harmonised standard' such as EN13445 or EN473 is invoked, the British Institute of Non-Destructive Testing offers PCN qualification examinations satisfying EN473 criteria through it's network of Authorised Qualifying Bodies in the United Kingdom and in many locations throughout the world. All existing valid PCN certification related to the testing pressure equipment is encompassed within this approval.
Where a 'harmonised standard' is not invoked by a client or regulator, the PED does not itself require EN473 certification. It does however require that NDT personnel be 'approved' by a recognised Third Party Organisation.
Many companies manufacturing or inspecting pressure equipment presently do so under ASME requirements. This inevitably leads to the SNT-TC-1A approach for qualification and certification of NDT personnel and, in many cases, companies do not have personnel qualified and certificated under EN473 criteria.
Rather than insisting that ASME approved companies wishing to satisfy PED requirements are forced down the EN473 route, the British Institute of Non-Destructive Testing offers an alternative approval service for 'in-house' qualified NDT personnel.
This involves an audit of company written practices against external criteria such as SNT-TC-1A, the validation of training and qualification provided within the Company Written Practice, and the issue of a statement of approval for specified personnel conducting specific non-destructive tests.
This can be provided as a stand-alone service or in conjunction with services provided by a Notified Body (according to PED Article 12) against all conformity assessment procedures (PED Annex III) as well as for European approval of material (PED Article 11), approval of operating procedures of permanent joints (PED Annex I, 3.1.2) and approval of personnel for permanent joining (PED Annex I, 3.1.2). This latter option provides a 'one stop shop' for conformity with the PED.
The company seeking 'approval' of NDT personnel submits an application, together with a controlled copy of the documented NDT personnel qualification procedure (hereafter referred to as the 'Company Written Practice'), to the British Institute of NDT (BINDT).
Upon receipt of an application BINDT instigates a desk-top review of the Company Written Practice to ascertain compliance with the relevant criteria, e.g., SNT-TC-1A or ANSI-CP-189. If this is found to be satisfactory, BINDT appoints a qualified assessor to carry out an on-site audit to ensure correct implementation of the Written Practice by the employing company. The on-site audit involves
Minor deficiencies found during audit must be corrected by the organisation within three calendar months, or within a lesser period which is agreed by all parties and defined in the assessors report and recommendations. The corrective action for such deficiencies is subject to lead assessor and BINDT approval. This may be achieved by correspondence, but could involve a further audit by BINDT appointed assessors.
Upon completion of the on-site audit and receipt of satisfactory evidence of any agreed corrective action, the appointed assessor submits a report and recommendations to BINDT.
The details of this 'alternative approach' are set out in a series of documents published by the British Institute of NDT and listed in PED/01 - see references.
If, in the opinion of BINDT, the organisation satisfactorily trains and qualifies its NDT personnel for particular non-destructive tests performed on specified pressure equipment, and the non-destructive tests witnessed by the assessor were correctly carried out in accordance with documented NDT procedures, a detailed schedule of approved personnel is issued.
The schedule of approvals, which must be must be issued before the organisation is permitted to claim compliance with the Pressure Equipment Regulations (with respect to approval of NDT personnel), will name the approved NDT personnel and the specific NDT procedures that they are approved to carry out.
BINDT must be advised immediately of any change in the personnel named on the schedule of approvals and will reserve the right to review continuance of approval consequent upon such changes.
After approval is granted, a controlled copy of the applicant's written practice and a formally controlled internal NDT personnel surveillance procedure (which is an integral part of the company's quality management system) will be retained by BINDT for future reference.
The approvals are valid for three years, during which period the organisation will be required to implement and submit to BINDT evidence of surveillance conducted in accordance with the internal documented procedure developed for this purpose and approved by BINDT.
Existing approved organisations wishing to extend the scope of NDT personnel approvals will be audited for compliance with requirements in respect of the tests and/or NDT personnel to be added to the schedule of approvals. This may involve a further site visit. Application for extension or reduction of approved scope, which will be considered at any time, must be made in the same manner as for initial approval.
Representatives of the BINDT, authorised in writing, must be accorded access for surveillance of approved NDT personnel at all reasonable times to verify any aspect of NDT operations applicable to the Pressure Equipment Regulations.
Within this approach, BINDT reserves the right to visit any approved organisation without notice or to withdraw any NDT personnel approvals, wholly or in part, at any time.
The PED does not, in itself, require certification according to EN473.
The PED does not, contrary to a widely held view, represent a European 'barrier to trade'.
Any competent third party can apply to be recognised and notified by a member state of the European Union as a 'Third Party Organisation'.
Harmonised standards are unlikely to be widely specified by clients or regulators, especially where pressure equipment is presently satisfactorily manufactured to ASME standards.
The 'alternative approach' is cost effective and utilizes a similar approach to that available through ASME, except that ASME is a 'Second Party' rather than an independent 'Third Party', approving body.
Codes and Regulations
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