Questions Concerning PRI NADCAP Assessments

Acceptance of PCN certification as satisfying the qualification criteria of EN 4179

When Nadcap audits are carried out on UK organizations employing NDT personnel holding PCN certificates of competence, major non-compliances are raised that can be cleared only if the Nadcap Assessor has direct access to the examination scripts relating to the award of specific PCN certificates of competence.

It is accepted that Nadcap auditors need to ascertain that the PCN Scheme satisfies EN 4179 qualification criteria (including training and examinations) for subsequent certification of competence of NDT personnel by the employer.

Although it is most unusual for QA and Regulatory organizations to seek access to qualification examination records when a third party certification body has issued a certificate, BINDT does facilitate informal access to examination records and test specimens at its Authorised Qualifying Bodies (AQB) by any organization that feels a need to satisfy itself in this way about the veracity of the PCN Scheme’s qualification examinations. PCN document CP19 (Informal Access to BINDT Authorised Qualifying Bodies by Third Parties) describes in detail the access provided and how to initiate such access.

Moreover, the fact that all examination scripts are centrally issued and controlled by BINDT provides a unique opportunity for Nadcap to be provided with controlled copies of PCN aerospace general and specific examination papers in order to ascertain their suitability in terms of qualification criteria for employer certification against EN 4179.

In order that we may continue to serve the needs of the UK aerospace industry (as we have done since the inception of the Scheme by the PCN Aerospace Specialist Board in 1985), BINDT seeks to gain recognition by Nadcap that it is an “Outside Agency” as defined in EN 4179. In particular, your attention is drawn to clause 6.1.2:

When an outside agency is used, the outside agency shall provide the cognizant NDT organization with the names, qualifications and, if applicable, the certifications held by the instructors and test administrators employed in the training and examination process. Supporting evidence shall be made available to the prime contractor, its auditors, or to applicable regulatory agencies upon request.

BINDT is prepared to make such information available and, together with the offer to provide Nadcap with controlled copies of centrally issued examination papers, it is considered that the acceptance of PCN certification as satisfying the qualification criteria of EN 4179 should be acceptable to all parties.

In October 2006, PRI (Europe) responded to the above with the issue of Nadcap Auditor Advisory NDT 06 – 0007

Proposal to establish a UK National Aerospace NDT Board

Background

A meeting of interested parties was held at the British Institute of NDT, 1 Spencer Parade, Northampton, at 11h00 on Wednesday 3 April 1996 to discuss prEN4179, its implications for the United Kingdom aerospace industry, and the need to form a National Aerospace NDT Board (NAndtB) to regulate the implementation of the standard.

Although there was general UK support for the proposal to establish a NAndtB, it was never realized due, in part, to a lack of support from the SBAC NDT SIG.

Since the implementation of EN 4179 and the PRI Nadcap (Europe) scheme, the need for a NAndtB has become evident. This is particularly evident in the area of Nadcap audits, with regard to recognition and acceptance of PCN aerospace certificates and acceptance of qualification services provide by other outside agencies.

Potential role(s) for a UK National Aerospace NDT Board

The primary role(s) for such a body are seen to be:

Approve and promulgate guidelines for
employers implementing EN 4179
outside agencies providing training and examinations to EN 4179 criteria
Provide a mechanism for interpretation, adjudication and arbitration in cases of dispute regarding the implementation of such standards
Accreditation of training organisations and validation of training course
Approval of outside agencies
Consider and make recommendations on the acceptance of third party certification as meeting the qualification criteria of EN 4179
Seek multilateral or bilateral mutual recognition of UK schemes
with other European National Aerospace NDT Boards,
with North American organisations having similar aims, and
with any other pertinent body in order to benefit the United Kingdom Aerospace industry and to minimize duplication and multiple audit

The British Institute of NDT currently provides for items 3 and 4 above.

Extracts from pr EN 4179 relating to the role of a NAndtB are provided at Annex A, the most pertinent of which is as follows:

3.17 national aerospace NDT board (NANDTB)

An independent national aerospace organization representing a nation's aerospace industry that is chartered by the participating prime contractors and recognized by the nation's regulatory agencies to provide or support NDT qualification and examination services in accordance with this standard. Such services may include participation in certification.

BINDT proposal to establish a NAndtB

PRI/Nadcap neither recognizes or accepts PCN aerospace sector certification, in spite of the fact that the PCN Scheme is open to audit by external quality assurance/regulatory bodies.

The question “will Nadcap accept PCN certification as evidence of satisfying the qualification criteria (training and examinations) of prEN 4179” was put to the PRI Europe Staff Engineer (Phil Ford) at a 5th February 2004 meeting with the BINDT Service Inspection Group. The response was that PRI/Nadcap would do so only if PCN certification was recognised by a UK NAndtB (established as defined in prEN 4179 clause 3.17).

BINDT already provides an administration for a number of external boards, committees and working groups, and it would be willing and able to provide backup, administration and facilities for a NAndtB.

In order to provide for the establishment of a NAndtB, BINDT is seeking the support, in principle, of theSociety of British Aerospace Companies through it’sNDT Special Interest Group. It already has the support of the UK Civil Aviation Authority.

Given that support, a meeting of the nominated representatives of potential member organisations will be convened early in 2004 with a view to agreeing the constitution, terms of reference and method of working of a UK NAndtB.

Would PRI (Europe) take up the offer of a seat on a UK NAndtB?

Annex A - Extracts from pr EN 4179 P4 : Strawman, October 27, 2003(where reference is made to a NANDTB)

1.2.1 Implementation

This standard merges the NDT personnel certification requirements of NAS 410 and EN 4179. It introduces the concept of a National Aerospace NDT Board (NANDTB) from EN 4179, but it is not mandatory to have such a board for compliance with this document.

3. Definitions

3.11 formal training

an organized and documented program of activities designed to impart the knowledge and skills necessary to be qualified to this standard Formal training may be a mix of classroom, practical and programmed selfinstruction as approved by the responsible Level 3 or NANDTB.

3.17 national aerospace NDT board (NANDTB)

an independent national aerospace organization representing a nation's aerospace industry that is chartered by the participating prime contractors and recognized by the nation's regulatory agencies to provide or support NDT qualification and examination services in accordance with this standard Such services may include participation in certification.

3.27 technique

a category within a method; for example, ultrasonic immersion testing or ultrasonic contact testing Specific techniques within a method are defined by the cognizant NDT organization or NANDTB.

4.1 Written practice

The cognizant NDT organization shall develop and maintain a written practice for the qualification and certification of their NDT personnel. The written practice shall be in accordance with the requirements of this standard. A subcontractor or supplier may work to the same written practice as the prime contractor or may prepare a written practice of their own. This standard may be referenced in whole or in part to meet this requirement provided the subparagraphs of 4.1 are satisfied. The written practice and applicable NANDTB procedures shall be available for review by the facility's customer(s) and regulatory agencies.

4.1.3Training program

The written practice shall include outlines or references of the instruction provided by the cognizant NDT organization, NANDTB, or outside training source(s).

4.3 Methods

For the common methods listed in 1.3, the requirements for training, experience and examination are detailed in Clauses 6, and 7 of this standard. These requirements shall serve as a guideline for methods not listed in 1.3. Specific techniques within each method shall be as defined by the cognizant NDT organization or NANDTB and documented in the employer's written practice.

4.5 Responsibility

The employer is responsible for implementation of, and compliance with, this standard and for certifying qualified personnel. Where a NANDTB is used, 4.5.1 shall apply. Where a NANDTB is not used, 4.5.2 or 4.5.3 shall be used as applicable.

4.5.1National aerospace NDT board

When used, the NANDTB shall administer procedures for qualification and certification of NDT personnel according to the requirements of this standard. It is entitled, in conjunction with the employer, to recognize equivalencies of qualification and certification, and may be requested to provide general guidelines in accordance with this standard regarding facilities for NDT training, course outlines, examination questions and exam procedures. For countries where no NANDTB exists, the employer may use the services of other NANDTBs.

NANDTBs defined in this standard apply solely to boards meeting the definition of 3.17 of this standard. Other agencies performing examination, qualification and/or training activities shall be considered outside agencies as defined in 3.19.

6.1 Training

Candidates for certification as Level 1 "Limited", Level 1, or Level 2 shall complete sufficient organized training to become proficient with the principles and practices of the applicable test method and technique(s). The training shall be conducted in accordance with a detailed course outline approved by the responsible Level 3 or NANDTB. At a minimum, the training shall cover basic theory, test principles, products, equipment operation and standardization, safety, operating procedures, applicable techniques, the applicable specifications, codes, and written instructions used by the employer, and, if applicable, interpretation of indications. The outline shall include a list of references from which the training material is derived.

6.1.1Responsible Level 3

The responsible Level 3 or NANDTB who prepares the training and examination program shall have a thorough knowledge of the written instructions, codes, specifications and standards used by the prime contractor. He/she shall also have a thorough knowledge of the materials, components, product technologies, methods and techniques used by the employer.

6.1.2Outside agencies

6.2 Minimum required training hours

6.2.1Previous training

Previous training must be documented to be accepted by the employer. For personnel credited with prior training, or those not certified within 12 months of their training, refresher training must be provided. At a minimum, refresher training shall cover products, equipment setup, operation and standardization, specific operating procedures, applicable techniques, interpretation and evaluation of NDT results, safety, and applicable codes, standards and specifications. The depth of instruction on each subject shall be determined by the responsible Level 3 or NANDTB.

6.2.2Equivalent training

For personnel previously certified under NAS 410, EN 4179, or other recognized NDT qualification program, the adequacy of their previous training to the requirements of Table 1 will be determined and documented by the responsible Level 3 or NANDTB.

6.3.1Previous experience

A candidate's documented experience with a previous employer may be accepted by the current employer if approved by the responsible Level 3 or NANDTB.

6.3.2Equivalent experience

For personnel certified under other qualification programs, the equivalency of their previous experience tothe requirements of Tables 2 or 3 will be determined and documented by the responsible Level 3 or NANDTB.

7. Examinations

7.1.1Visual acuity

The vision examination for all levels shall assure that the applicants near vision and color perception meet the requirements of Table 4. Near vision tests shall be administered annually and color perception tests shall be administered prior to certification or recertification. These tests shall be administered by personnel designated by the responsible Level 3, NANDTB, or the outside agency utilized for the qualification examination of personnel. Any limitations in color perception shall be evaluated by the responsible Level 3 prior to certification and must be approved in writing.

7.1.3Specific

The specific examination for all levels shall be a closed book examination and shall cover the requirements and use of the specifications, codes, equipment, operating procedures, and test techniques the candidate may use in the performance of his/her duties with the employer. The responsible Level 3 shall determine the specific examination requirements for Level 1 "Limited" personnel, but shall not be less than 25 % of those required for Level 1 in the applicable method. A minimum of 30 questions shall be used for the specific examination at Levels 1, 2, and 3. Reference material such as specifications, tables, formulas, etc. may be provided as determined by the responsible Level 3. Questions utilizing such material shall require understanding of the information contained therein rather than merely finding its location.

NOTEWhere a NANDTB is used, the specific examination may cover a wider scope within the method used withinthe aerospace industry.

7.1.4Practical

The practical examination shall consist of a demonstration of proficiency in performing tasks that are typical of those to be accomplished in the performance of the candidate's duties. Test samples used in the examination may be actual hardware if the candidate is required to demonstrate proficiency in the application of the process as well as interpretation of results, or may be images, such as radiographs if the candidate is only required to interpret the results and not perform the process of generating the image. Written checklists covering the topics detailed in the following subparagraphs shall be developed by the responsible Level 3 or NANDTB to assure adequate coverage and to assist in the administration and grading of the examination.

NOTEWhere a NANDTB is used, the practical examination may cover a wider scope within the method used withinthe aerospace industry.

7.2 Administration of examinations

The administration and grading of all examinations shall be the responsibility of the responsible Level 3 for the method for which the examinations are given or the applicable NANDTB. The responsible Level 3 may delegate in writing the administration and grading of all examinations using multiple choice or true/false type questions. Responses to essay questions must be evaluated by the responsible Level 3 to verify the certification candidate's adequate understanding of the subject matter. In no case can an examination be administered by one's self or by a subordinate.

8.6 Recertification for Level 3

Level 3 personnel shall be recertified at intervals not to exceed five years. Recertification shall be accomplished in accordance with Annex A or by specific and practical reexamination equivalent to initial certification. If equipment operation or accepting production hardware is required as a part of the Level 3's duties, a full practical examination equivalent to Level 2 is required unless otherwise defined by the applicable NANDTB.

Revision A1dated 16th February 2004