Friday, December 16, 2011

Understanding Intent

Paul,
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

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

AWS-D1.1, 4.2.1.1 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-4.2.1.1 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. 

PWC

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