Personnel Certification and the Limits of the Level III's Role
A Level III IR thermographer is asked by a client to (a) certify two Level I candidates by administering the client's in-house written exam and practical, (b) sign the inspection report as the 'certifying authority' for a survey performed by a Level I thermographer, and (c) approve a written practice that omits any requirement for near-vision acuity or annual vision exams. The Level III holds a certification from a recognized certification body. The client's contract states 'personnel shall be qualified and certified per the applicable ASNT standard.'
1. Evaluate each of the three requests against the applicable qualification/certification framework.
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The governing framework is ASNT CP-189 (qualification and certification of NDT personnel) and/or SNT-TC-1A (recommended practice, employer-administered), depending on what the contract and the certification body require. Key principles:
- (a) Certifying candidates: Certification is the employer's responsibility under an employer's written practice. A Level III can train and examine candidates and can recommend certification, but cannot unilaterally 'certify' personnel who are not their employer's employees unless the employer's written practice and the certifying body authorize it. Administering the client's exam is fine; signing the certification is the employer's act, not the Level III's.
- (b) Certifying authority for a survey: A Level III can review and approve a report, but the certification of the inspection is a quality-system function (the employer's authorized signatory), and the Level I's work must be within the Level I's scope and under Level II/III supervision per the written practice. The Level III cannot substitute personal certification for the employer's quality-system sign-off.
- (c) Written practice omitting vision requirements: Not acceptable. CP-189/SNT-TC-1A require near-vision acuity (e.g., Jaeger 1 at 12 in / 30 cm) and annual vision examinations (with color perception as applicable). A written practice that omits these is noncompliant and the Level III should refuse to approve it.
2. What should the Level III do, and how should the report and written practice be handled?
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Actions:
- Decline to 'certify' the candidates as an individual act; instead provide training/examination records and a written recommendation to the employer, who certifies per its written practice. Confirm the certification body's rules on who may examine and who may certify.
- Sign the report as the reviewing Level III, stating the scope of review and the supervision provided; the employer's authorized signatory certifies the inspection. Document that the Level I worked within scope and under supervision.
- Reject the written practice as written and require it be revised to include near-vision acuity (Jaeger 1 at 30 cm, corrected or uncorrected) and annual vision exams, plus the required training/experience and examination structure for each level. Only approve a compliant revision.
Reporting: the report should identify personnel by level, state who supervised and who reviewed, and reference the written practice and the standard (CP-189 or SNT-TC-1A) actually applied. If the client insists on the noncompliant practice, the Level III should document the objection in writing and not sign as approving authority.