NDT AC7114 Checklist Questions: “The Fine Print” by Linda Beene

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NDT AC7114 Checklist Questions: “The Fine Print” by Linda Beene

10 June 2016

By now everyone who works in nondestructive testing should be deeply involved in the implementation of AC7114 Rev I changes. Since the checklist revision, I’ve performed approximately fifteen Nadcap audits and instructed several eQuaLearn NDT Level 3 Responsibilities and NDT Checklist Review courses. Based on input from the individuals taking the eQuaLearn courses and the audits performed, there appears to be some slight changes to the AC7114 checklist which, to some, may still convey some ambiguity.

The AC7114 change that I’ve selected to discuss herein is Defining Internal/External Auditor Requirements. I will discuss Specific Examination Requirements in the next eQuaLearn newsletter. My selection on which checklist changes I will address for this article was mainly based on the length of the open discussions in the eQuaLearn classes. In writing about the changes I will be using the term “fine print” to present my view on the requirements. Not surprisingly, the “fine print” is defined as paying attention to the “Compliance Assessment.” I come from a family of legal career individuals; and as long as I can remember, which is not as long as I used to be able to remember, I was always reminded “to read the fine print.” You would probably be surprised at how many times that I find that the checklist question is being assessed without using the applicable “compliance assessment,” or reading “the fine print.”

Internal/External Auditor Requirements

AC7114 Rev I Paragraph 4.4.3 poses the question, “Is there evidence that the employer has defined the requirements for personnel performing technical audits, surveys, or assessments (internal and external) to have the training skills, and knowledge in applicable method(s)?”

This becomes significantly different than AC7114 Rev H, because Rev H asked “Are personnel performing internal NDT audits knowledgeable in the method(s) they are auditing and are they approved by the Responsible Level 3?”

AC7114 Paragraph 4.4.3 Compliance Assessment Guidance states, “This requirement shall be addressed in the company written practice either in detail or by reference to another procedure in the written practice.”

This is one of the rare times that the information does not have to be addressed in detail within the written practice, but can merely be referenced to a procedure containing the details. The other requirement that comes to my immediate memory is “Training Course Outlines.”

In some of the written practices reviewed, I still see only the following statement as the implied answer for auditor qualifications. “Personnel performing technical audits, surveys, or assessments shall have the training skills, and knowledge to understand the processes and procedures utilized in the application of NDT processes. The individual shall be familiar with the applicable codes, standards, and other contractual documents that control the applicable method(s).”

This statement directly from NAS410 Rev 4 does not define the auditor qualification requirements. It basically states the auditor job description.

AC7114 Paragraph 4.3.3 presented prolonged discussions in the eQuaLearn Checklist Review courses about what information should be required when defining auditor qualifications? Could the definition be met simply by stating that the audit shall be performed by a Level 3? This would at least meet training and knowledge requirements in the method; although, it may or may not mean that the individual is familiar with the applicable codes, standards, and other contractual documents that control the applicable method. Should it also include the quality (AS9100, ISO) requirements for an auditor? Does a training audit have to be performed if required per your quality system? Is there a minimum amount of classroom training hour requirements, if the individual is not a Level 3?

The “fine print” states that the written practice shall address in detail the requirement. So the answer should be “YES.” The written practice should define the skills for an auditor, the training and knowledge requirements for the method, and auditor assessment criteria that the company will use to ensure auditor requirements are met.

As an example, as defined by one Nadcap Subscriber:
“Internal NDT auditors shall be approved by the Responsible Level 3 and have completed, as a minimum, the required formal classroom training equivalent to a Level 2 in the applicable method, objective evidence of 8 hours of auditor training (AS9100, ISO, etc.) and two training audits in each method they are auditing (AC7114S (U1) Paragraph 4.3.3).”

The only additional requirement that may require defining is, how it will be determined that the individual is familiar with the applicable codes, standards, and other contractual documents that control the applicable method. Will your auditor be a Level 2 or Level 3 in the method, or how will this requirement be assessed?

Remember, that the AC7114 “fine print” does state that “This requirement shall be addressed in the company written practice either in detail or by reference to another procedure in the written practice.” So please don’t forget to define the auditor specific qualification requirements, and not just the job description.

In conclusion, I selected this change to AC7114 Rev I to emphasize: Defining Internal/External Auditor Requirements, but please don’t overlook the other changes such as: defining vision examination requirements, elimination of reduction of minimum experience hours, etc. And, surely don’t forget to do what? Read the “Compliance Assessment,” the fine print.

I will take this opportunity to thank the participants who I am fortunate enough to get to know through their candid participation in the eQuaLearn courses. Their humor, technical examples, and experiences are invaluable; and I too, always walk away learning something new.

Don’t forget to check out the next eQuaLearn newsletter where I address Specific Examination Requirements. For more information on eQuaLearn training please visit www.eQuaLearn.com or email equalearn@p-r-i.org.

Author: Linda Beene has been a NDT Nadcap auditor since 2006, and an eQuaLearn instructor since 2011.

Disclaimer: The views and opinions expressed in this article are those of the author and do not necessarily reflect the position or views of the Performance Review Institute or any of its employees or programs.