Who Owns the Qualification? Agency Welders and an Inherited PQR
A mechanical contractor is field-erecting a Section VIII vessel. The welders come from a staffing agency. The agency's file holds "certified welder" cards issued by a community-college test lab (6G GTAW on 2 in pipe, dated last spring), and the agency asks the contractor's QC manager to sign the shop's performance qualification forms on the strength of those cards. Separately, the contractor intends to use WPS-7/PQR-7, qualified in 2016 by a fabrication shop whose equipment and paper files the contractor bought last year; the seller remains in business as a separate company, and the PQR's certification block carries the seller's name and signature. The customer's inspector has offered to "approve" both the WPS and the welder cards in writing.
1. Whose responsibility is welder performance qualification, and do the college-issued cards satisfy it?
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The responsibility sits with the organization performing the code work - here, the contractor - not with the agency, the test lab, or the customer.
- Section IX makes the Manufacturer/Contractor responsible for qualifying and certifying the people who weld its work. A test lab's card is third-party evidence that someone once passed a test; it is not the employer's qualification record and does not transfer with the welder.
- What the contractor needs is its own qualification test to the required variables (process, position, thickness, base metal), witnessed and recorded, with the results certified by the contractor and the record retained. The welders may be retested on the same variables and pass easily - that is fine; the point is that the record must be the contractor's.
- Two practical traps: the college card was run on 2 in pipe, which does not automatically reach the vessel's diameter and wall; and the card does not show which WPS essential variables were used. Re-qualify rather than argue.
2. Can the contractor run production on the 2016 PQR-7 that was certified by the shop it bought the files and equipment from?
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Not on these facts. A procedure qualification belongs to the organization whose quality program produced and certified it.
- The seller still exists as a separate company and its name and signature are on the PQR. The contractor is a different Manufacturer; buying the files and machines does not transfer a qualification, and the 2016 PQR cannot simply be re-captioned.
- The contractor's path is to qualify its own procedure: weld test coupons to the intended essential variables, run the required mechanical tests, certify the results, and write its own WPS. It may use the old PQR as a starting point for planning - the variables and ranges are useful information - but not as evidence of qualification.
- The distinction worth remembering: where the performing entity is truly the same organization (a name change, or a merger in which the qualification records and the quality program continue without interruption), the records can be carried forward with a documented trail. A purchase of assets from a still-operating seller is not that situation.
3. Does the customer's inspector's written "approval" of the WPS and the welder cards cure either defect?
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No. Approval is not qualification.
- Section IX does not vest qualification authority in the Inspector or in the customer's engineer; it requires the Manufacturer to hold valid, certified qualifications and to make the records available. The Inspector of the referencing construction code verifies; that role does not create a PQR or a welder qualification.
- A contractual requirement for customer review or sign-off may exist and should be met - but it sits on top of a valid qualification, never in place of one. If the shop treats a customer signature as the qualification, it has no defensible record when the AI or an auditor asks for the PQR and the performance records.
- Correct order of operations: qualify (procedure and performance), certify internally, then route for any contractual review.