EXC3 contract in a shop certified to ISO 3834-3 with 8 mm welder qualifications
A workshop holds ISO 3834-3 certification and has for years produced EN 1090-2 EXC2 members. It wins a contract for EXC3 members in S355J2+N, 20 mm thick, where the specification requires Charpy 27 J at 0 °C. The QA manager's plan is to use the existing WPSs, supported by PQRs from 2011 with tensile, bend and macro tests but no impact tests; the existing welders, whose ISO 9606-1 certificates are based on 8 mm plate butt welds in the same material group; and the usual NDT subcontractor, whose UT technician holds a level 1 certificate. Production is due to start in four weeks. The QA manager argues that "nothing technical has changed - same steel grade, same welds - only the paperwork class is higher". The contract also requires the manufacturer's welding coordination personnel to be identified and their responsibilities evidenced.
1. Assess the QA manager's argument. Identify each gap and the requirement it breaches.
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The argument confuses the welding operation with the system required to control it, and it misses three technical changes as well.
Quality system. EN 1090-2 links execution classes to the parts of ISO 3834. For EXC3 the comprehensive requirements, ISO 3834-2, apply; the shop holds ISO 3834-3. That is a system-level gap affecting consumable control, document control, welding coordination, calibration and records - not a paperwork formality. Confirm the exact clause in the current edition, but the direction is clear.
WPS/PQR. ISO 15614-1 requires impact testing where the parent material specification or the contract demands it. A 2011 PQR with tensile, bend and macro tests does not support a 27 J at 0 °C requirement, and it must also cover the material group and the 20 mm thickness range.
Welders. ISO 9606-1 qualifies a thickness range around the test piece, roughly 0.5t to 2t for a plate butt test. An 8 mm test therefore covers only about 5–16 mm, so 20 mm production is outside the welders' qualification and a new test is required.
NDT. A level 1 UT technician is below what EXC3 normally requires; level 2 to EN ISO 9712 is the usual requirement. The contract must be checked, but this is a likely nonconformity.
Coordination. The contract requires the welding coordination personnel and their responsibilities to be identified and evidenced - a named, qualified coordinator with defined duties.
2. Set out a realistic four-week plan to close the gaps, and state what you would do if management insists on starting production on time.
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Four weeks is tight but feasible if work starts immediately:
- Week 1: appoint or contract a qualified welding coordinator (IWE/IWT/IWS as appropriate) and define responsibilities in writing; agree the ISO 3834-2 route with the certification body and begin extending the system (consumable control, WPS/PQR register, calibration, inspection and test plan).
- Week 1–2: manufacture WPS qualification test pieces in S355J2+N at 20 mm through the production processes, with impact tests at 0 °C, plus tensile, bend, macro and hardness; arrange radiography or UT as required. Testing and reporting is the long lead item.
- Week 2–3: qualify welders on 20 mm plate to cover the production range; book the tests before the WPS results if the sequence allows.
- Week 2: replace or supplement the NDT subcontractor with a level 2 UT technician and agree the NDT plan and acceptance levels.
- Week 3–4: update the ITP, WPS register and inspection records; brief the client on the plan and any residual deviation.
If management insists on starting before the WPS and welder qualifications are in place, production must not start. I would state that in writing, escalate to the responsible person, and inform the client of the actual status. Welding EXC3 work without valid qualifications creates a record problem that cannot be corrected afterwards, and the inspector must not sign documents that the evidence does not support.
3. The client asks you to sign off the existing WPSs as suitable so that production can begin. What is your answer, and what is the minimum acceptable evidence?
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The answer is no. The steel grade being unchanged is not the test; the test is whether the documented evidence covers what the contract requires. Signing would misrepresent the qualification status and would leave the shop without a defensible position if the joint failed or the client audited the records.
Minimum acceptable evidence before I would support release to production:
- a WPS supported by a PQR qualified to ISO 15614-1, covering the material group, the 20 mm thickness, the process and consumables actually used, with mechanical tests including impact at 0 °C meeting 27 J;
- valid welder qualification certificates to ISO 9606-1 covering 20 mm and the production positions;
- NDT personnel certificates to the level the contract and EN 1090-2 require, with the NDT plan and acceptance levels agreed;
- the welding coordination personnel named, with their responsibilities and qualifications evidenced;
- a quality system consistent with ISO 3834-2, or a documented, time-bound route to it accepted by the client.
If the client wants production earlier, any concession must come from the client with technical justification, and the inspector records the request, the response and the residual risk. The inspector documents; the inspector does not manufacture the evidence.