Who Signs Off the Procedure When the Certifying Body Has Not Enumerated the Scope?
A fabricator holds a Certificate 10 scope. The written scope statement reads only 'welding supervision and certification under AS/NZS 1796' with no list of processes, positions, or thicknesses. A new contract requires gas tungsten arc welding of 6 mm austenitic stainless tube in the 5G position, a process the workshop has never run. The quality manager argues the certificate is silent on process, so the scope is unlimited until the certifying body says otherwise. The welding supervisor has drafted a preliminary WPS from a published generic source, qualified no procedure, and scheduled production to start in nine days. Two welders hold current qualifications in carbon steel only. The client's inspector has asked, in writing, for the documentary basis on which the supervisor will certify the work.
1. Is the quality manager's 'silent means unlimited' reading defensible? State the reasoning the supervisor should give the client inspector.
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No. A scope statement that names an activity but enumerates nothing is an incomplete record, not an unlimited authorisation. The supervisor's duty is to certify only what the certificate actually covers, and an unenumerated scope cannot be read as covering a process, material group, and position the organisation has never demonstrated competence in.
The defensible position has three parts. First, the certificate is a document of defined extent; where the extent is unstated, the supervisor must obtain clarification from the certifying body rather than assume breadth. Second, certification of work implies the certifier has a qualified procedure and qualified personnel behind it, so the absence of both is itself evidence the work is outside current capability. Third, the supervisor should record the request for clarification and hold production until a written answer arrives.
A practical response to the inspector: the organisation will not certify 5G stainless GTAW until (a) the certifying body confirms the scope extends to it, or the scope is varied, and (b) procedure qualification and welder qualification are complete. Silence is resolved by asking, not by assuming.
2. Production is scheduled in nine days. Set out the sequence the supervisor should follow to be in a position to certify, and identify which step cannot be compressed.
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Sequence:
- Write to the certifying body requesting written confirmation or variation of scope for GTAW, austenitic stainless, tubular 5G. Do this on day one; it is the long-lead item.
- Prepare a specific WPS from the generic draft, defining joint design, purging, filler classification, heat input, interpass temperature, and cleaning regime for stainless.
- Qualify the procedure by test, with destructive or non-destructive examination as required, and record the results.
- Qualify at least one welder on that procedure in the 5G position on stainless; carbon steel qualifications do not transfer across material group or process.
- Only then release production, with supervision and records in place.
The step that cannot be compressed is procedure qualification, because welder qualification must be performed on a qualified procedure. Compressing it means the welder test proves nothing about the production joint. Nine days is feasible only if the certifying body responds quickly and test pieces can be prepared and examined without queueing; if not, the supervisor should tell the client now rather than certify retrospectively.
3. What should the supervisor put in writing to the client before production starts, and why does the form of that communication matter?
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A short letter or email stating: the current certificate scope as written; that the organisation has requested clarification from the certifying body; that no WPS is yet qualified for this joint; that no welder holds a relevant qualification; and that certification will not be issued until both exist. It should name the person who will certify and the records that will support the certificate.
The form matters because certification is an act of attestation. If the supervisor later signs, the file must show that the decision was made on stated grounds, at a stated time, on stated evidence. An undocumented verbal assurance cannot be defended if the joint fails, and it invites the client to believe production has been released under certification when it has not. A written hold also shifts the commercial pressure back to the correct place: the scope question is for the certifying body, not for the workshop to resolve by optimism.