Friday, December 16, 2011

Understanding Intent

I work for a large U.S. Corporation that is made up of 15 manufacturers, each with well known brands throughout their markets.  It seems like since we all work for "X-Corp", we could share weld procedures (WPS) and procedure qualification reports (PQR) across the company and save on testing and qualification expenses.  Could a case be made for each division, to use centralized "X-Corp" WPS’s that are supported by the PQR’s run at the 15 different manufactures?
Mike I.
Welding Engineer - CWI

That's a good thought.  Let’s take a look at a couple of code provisions...

AWS-D1.1, states, "Each manufacturer or contractor shall conduct the tests required by this code to qualify the WPS".  That same provision goes on to talk about "consolidation with parent company(s)". 
For some, that may create a "gray area", but we as CWI’s, in addition to being able to reference code previsions, also have to understand code intent.  The best way I know to better understand codes intent is found in the Annex’s and the Commentary of the code.

You remember those sections.  They are the ones your CWI instructor suggested you steer clear of during your exam.  Well, they have a purpose.  Located in the back of your code book, the Commentary shares the same Clause and Provision numbering with the exception of a "C" at the beginning.

In D1.1 Annex K, "Contractor" is defined as "Any company, or individual representing a company, responsible for the fabrication, erection manufacturing or welding, in conformance with the provisions of this code".  The Commentary notes, "C- All contractors shall be responsible for their final product." X-Corp would have no interest in taking on that responsibility when they have little control over "fabrication, erection manufacturing or welding..."  That is the reason each "contractor" (or division of X-Corp) hires guys like us.

We can share the information gathered from the testing, but we can not share the PQR.  The PQR will only apply to the individual manufacturer (contractor), not to the group.  Having the information is certainly helpful but it would only be to aid you in the processing of your own testing. 


Tuesday, December 13, 2011

Integrity doesn’t get a mulligan

The Company I work for regularly gets into more than we can handle. The more we take on jobs at the last minute, the harder it is for me to do my job at the level that is required by the customer. I do 100% visual, weld mapping, pressure testing, setting up NDE... The one area that seems to gradually get worse is providing Material Test Reports (MTR). I can not provide all MTR's our customer requires. Often we don't get them from our vendor, or parts have sat for so long that they can't be traced.
I've tried to convince my employer that this paperwork needs to be received and verified before fabrication, but that hasn't gotten me anywhere. I am not even given the authority to stop fabrication when we have exceeded our own qualified procedures.
It can be a tough spot to be in, so I have a couple serious questions to ask…
• How much trouble can a CWI get into if something like MTR's can not be provided to the customer, when it is required?
• Do I have to walk off the job to protect myself from losing my certification when I know that things aren't being done right?
• Do I have a legal obligation because of the code, or does the company?
T.C. - CWI

In the words of Ulysses Everett McGill, you’re “…in a tight spot.” The reason certification programs exist is this very reason.

Section 11 of AWS-QC1 “Standard for AWS Certification of Welding Inspectors” states:
• The… CWI …shall act to preserve the health and well being of the public by performing duties required of welding inspection in a conscientious and impartial manner to the full extent of the inspector(s) moral and civic responsibility and qualification. Accordingly, the… CWI …shall:
     o …Be completely objective, thorough, and factual in any written report, statement, or testimony of the work and include all relevant or pertinent testimony in such communiqu├ęs or testimonials.
     o …Sign only for work that the inspector has inspected, or for work over which the inspector has personal knowledge through direct supervision.
     o …Neither associate with nor knowingly participate in a fraudulent or dishonest venture or activity…
It sounds like you have come to a fork in the road and there are tough decisions to be made. I’ve always believed that the reason we inspectors are hired is to save our bosses from themselves. You can create the change that is needed, or, you can “drag up” and move on. I’d love to have a dime for every time went home and told my wife Dianne, “It’s over. They’re gonna fire me.” Strangely, I’m still around. But situations like yours are all too common for the CWI.
You can not place your stamp or signature on a document you know to be false. That said, I’m going to assume that you are moving forward with creating the change.
My advice to you:
• Be able to “Put your finger on it”. Know your code/standard/customer requirements and do not back down from them. When you make the call and refuse to “by-off” on something, know where it is in the documents and be able to reference it.
• Don’t wait until the entire weldment or piping system is complete before you stand your ground. Keep Welders, Foremen & Plant Managers in the loop from the beginning.
• Don’t over reach. Know what the acceptance criteria are and don’t require a smidge more.
• If you are treading in unfamiliar waters, get out of the pool. Those decisions are not yours to make. Stay within your field of expertise.
• Finally, (and toughest of all for a “hard head” like me) accept if you are proven wrong. Don’t build a wall of resistance. Learn where you went wrong and come out of it a better inspector.
This situation can teach you a lot about yourself. One way or another, this will be a career changer. Make it a good one.

Remember: Integrity doesn’t get a mulligan.