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ANSI/ASNT CP-189-2011

Interpretations

The following interpretations of CP-189 were issued by the SDC Interpretation Subcommittee and approved by the SDC. These responses clarify the intent of ANSI/ASNT CP-189-2011. Interpretations of earlier editions are available in Members Only (password required).

Inquiry 11-01

The State of California, Department of General Services, Division of the State Architect has jurisdiction over construction of schools and other state-owned buildings. They are now requiring a Licensed Civil Engineer to sign off on all of our firm’s nondestructive testing (NDT) certification documents. We feel this is an unnecessary level of bureaucracy, as per CP-189, and the ASNT NDT Level III is the certifying authority, and he administers the tests and signs the certifications. Is the State’s requirement in conformance with CP-189, and would it not require a formal revision to ANSI/ASNT CP-189?

Background

See Division of State Architect IR 17-2 and samples of our Certification Documents. Consolidated Engineering Labs is a fully accredited facility, meeting ASTM Standards E-543-04 and E-1212-04. Our Qualification and Certification Procedure has been CP-189 compliant since 2004; it is only since early 2011 that the Division of the State Architect has attempted to enforce the engineer signature provision. All other California state, county and municipal jurisdictions accept ASNT Recommended Practice No. SNT-TC-1A: Personnel Qualification and Certification in Nondestructive Testing.

Response

There is no need for a formal revision. Paragraph 9.2/9.2.1.5 does not prohibit the customer from adding requirements.

Inquiry 10-07

It is intents of paragraph 9.2 Contents of Documentation. The employer’s certification documentation shall include at least a training record, certification record, an experience record, a record of previous experience (if applicable), employee’s current examinations and a vision examination record. That all “training record, certification record, an experience record, a record of previous experience (if applicable), employee’s current examinations, and a vision examination record” should be kept in one file for each individual?

Response

No, a filing system is not specified in this standard.

Inquiry 10-06

Improperly formatted request.

Inquiry 10-05

CP-189 paragraph 6.2. requires NDT Level III examinations administered by the employer as follows:

Specific exam: written exam on NDT-related requirements of specs or standards used by the employer, e.g. ASME codes.

Practical exam which requires that the candidate should prepare an NDT procedure (If the documented experience demonstrates that the candidate has previously prepared acceptable procedures using specs and requirements of codes applicable to employer, a practical exam is not required).

Is it required from ACCP Professional Level III anyway to undergo the exams mentioned above?

Response

Yes.

Inquiry 10-04

Improperly formatted request.

Inquiry 10-03

Improperly formatted request.

Inquiry 10-02

Can the eye examination for near vision given in the middle or beginning of a month expire at the end of that same month 1 year later? Example: If an eye examination for near vision is conducted on Dec.15th of 2009, can the expiration date be Dec. 31st 2010.

Response

The term "date" used to establish intervals, such as "annual" in ASNT personnel qualification and certification documents is intended to be the last day of the applicable month.

Inquiry 10-01

4.1.3 states “All training shall be presented by an NDT instructor”. 4.4.1.1 states “possess a current ASNT Level III certificate in the NDT method to be taught.

Does it imply that if an employer has a NDT Level III in direct employment he does not require an NDT instructor to present training, since the employers Level III has met the requirement of 4.4.1.1?

Response

Yes, paragraph 4.4.1.1 provides that individuals that possess a current ASNT Level III certificate in the NDT method to be taught, meet the criteria as an NDT Instructor. References to an ASNT Level III certificate in ANSI/ASNT CP-189 applies to individuals holding either (or all) Level III certificates issued by ASNT, i.e. ASNT NDT Level III, ASNT PdM Level III or ACCP Professional Level III.

Inquiry 09-05

Appendix C: Sample certification Form has a section to document education, including High School or equivalent. However, the pertinent sections of the document reflect no requirement for education or documentation of such (except for instructors). Suggest reflecting the requirements as needed to accommodate this aspect of qualification.

Response

The individual candidates level of formal education is not a factor in the requirements for qualification and certification of NDT personnel in accordance with ANSI/ASNT CP-189 standards.

Inquiry 09-04

Can an ASNT Level III that is not certified in the applicable test method administer a multiple-choice Specific written examination to another Level III in that test method if he is designated by the employer as the certifying representative and that designation is documented in the company's Certification procedure?

Response

No, ANSI/ASNT CP-189-1995 paragraph 6.4.1 permits delegation of administration and grading of multiple-choice questions for NDT Level I and NDT Level II candidates, if so documented.

6.7 takes precedence which states, “The employer’s representative who administers the Level III examinations shall possess a current ASNT NDT Level III certificate in the method for which the examination is administered and shall be knowledgeable and familiar with the standards, specifications, and products used or made by the employer.”

Inquiry 09-03

Is it the intent of CP-189 that the development of the qualification examinations described in Sections 6.2 & 6.3 be done by an ASNT Level III certified in the applicable test method?

If the answer to (1) above is No, must those examinations be approved by a Level III, and if so, must the Level III be certified in the applicable test method?

Response

Yes, ANSI/CP-189-1995 paragraph 6.4.1 states, in part, “…The employer shall be responsible for having an individual possessing a current ASNT NDT Level III certificate develop, administer, and grade Level III specific and practical examinations.

Inquiry 09-02

Is it the intent of Paragraph 6.3.3(b) that when a candidate is performing a Level II practical examination and the candidate's certification will be limited to a technique (e.g. limited to dry powder yoke magnetic particle) that only one sample needs to be used in administration of the practical examination.

Is it the intent of Paragraph 6.2.4 that when a candidate is certifying to CP-189 from previous uninterrupted service as a Level III per SNT-TC-1A that a Levell" is required to perform the demonstration examination per the Level II practical examination rules even if the Levell" has performed a Level II practical examination during SNT- TC-1A certification?

Response

No, paragraph 6.3.3.(b) states in part, “Level II. The candidate shall demonstrate proficiency…a minimum of two samples per method…”

No, paragraph 6.2.4 states in part. “…The practical examination shall include demonstrations of candidates ability to perform required activity (ies).” Documented evidence of the candidates ability to perform required activity(ies) satisfies this requirement.

Inquiry 09-01

CP-189 addresses the initial on-the-job training requirements. Are we to assume that the hours required for each method must be met during each certification cycle? Example: PT requires 140 h in the method and 270 h total in NDT for the Level II. Considering that these hours are required for Initial certification, must we meet the same requirements each time we recertify?

Response

No. The training hours shown in Appendix A are for initial certification. Recertification requirements are addressed in Section 8.0.

Inquiry 08-01

Is the requirement and/or intent of paragraph 4.3.2 that if an individual holds a current ASNT NDT Level III, the backup documentation including training and experience records need not be reviewed or retained by the employer to certify an individual in accordance with CP-189?

Response

Backup documentation including training and experience records is not required. CP-189 paragraph 9.2.1.3, Certification Record, states, “For Level III personnel, a copy of the candidate’s ASNT Level III certificate.” See also Inquiry 03-2.

Inquiry 07-05

Does this statement (paragraph 2.2.2) imply that the certificate holder (PdM) can perform the actions in 3.2 (General familiarity because of Basic Examination) and 5.3 for all methods not just IR and VA?

Response

No, only the methods for which the Level III is qualified as stated in paragraph 3.2.

Inquiry 07-04

If the employer does not have NDT personnel, but have PdM personnel, is it the intent of this document that there is still a need for a procedure for certification.

Response

Yes, if the employer must certify PdM personnel in accordance with CP-189.

Inquiry 07-03

The Predictive Maintenance (PdM) individual is identified in two paragraphs in this document Scope 1.1, and NDT Levels 2.2.1, with no clear understanding who this individual is. In 1.1 the scope of this standard is to establish the minimum requirements for the qualification and certification of the PdM. This does not exist in this standard. Is it the intent of this document to address PdM personnel qualification and certification requirements.

Response

Yes, for Level I and Level II personnel, see paragraph 4.1.1, Table 1 and Appendix A.

Inquiry 07-02

Is it the intent to allow Limited Certifications other than UT and RT film interpretation? This is not defined in the document. Both paragraphs 3.4 and 4.2.2 reference, Appendix B of this document, which is specific to RT and UT.

Response

No, however, for methods other than those in Appendix B, limited certification may be used as long as the employer’s written procedure meets the minimum qualification requirements of CP-189.

Inquiry 07-01

Can an ASNT Level III not certified in a particular method sign certification of personnel in that particular method, if he is designated by the employer as the certifying representative?

Response

Yes, provided the requirements for the certifying representative are covered in the procedure for qualifying personnel.

Copyright © 2012 by the American Society for Nondestructive Testing, Inc. ASNT is not responsible for the authenticity or accuracy of information herein. Published opinions and statements do not necessarily reflect the opinion of ASNT. Products or services that are advertised or mentioned do not carry the endorsement or recommendation of ASNT.
IRRSP, NDT Handbook, The NDT Technician and www.asnt.org are trademarks of the American Society for Nondestructive Testing, Inc. ACCP, ASNT, Level III Study Guide, Materials Evaluation, Nondestructive Testing Handbook, Research in Nondestructive Evaluation and RNDE are registered trademarks of the American Society for Nondestructive Testing, Inc. ASNT exists to create a safer world by promoting the profession and technologies of nondestructive testing.


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	ANSI/ASNT CP-189-2011 Interpretations The following interpretations of CP-189 were issued by the SDC Interpretation Subcommittee and approved by the SDC. These responses clarify the intent of ANSI/ASNT CP-189-2011. Interpretations of earlier editions are available in Members Only (password required). Inquiry 11-01 The State of California, Department of General Services, Division of the State Architect has jurisdiction over construction of schools and other state-owned buildings. They are now requiring a Licensed Civil Engineer to sign off on all of our firm’s nondestructive testing (NDT) certification documents. We feel this is an unnecessary level of bureaucracy, as per CP-189, and the ASNT NDT Level III is the certifying authority, and he administers the tests and signs the certifications. Is the State’s requirement in conformance with CP-189, and would it not require a formal revision to ANSI/ASNT CP-189? Background See Division of State Architect IR 17-2 and samples of our Certification Documents. Consolidated Engineering Labs is a fully accredited facility, meeting ASTM Standards E-543-04 and E-1212-04. Our Qualification and Certification Procedure has been CP-189 compliant since 2004; it is only since early 2011 that the Division of the State Architect has attempted to enforce the engineer signature provision. All other California state, county and municipal jurisdictions accept ASNT Recommended Practice No. SNT-TC-1A: Personnel Qualification and Certification in Nondestructive Testing. Response There is no need for a formal revision. Paragraph 9.2/9.2.1.5 does not prohibit the customer from adding requirements. Inquiry 10-07 It is intents of paragraph 9.2 Contents of Documentation. The employer’s certification documentation shall include at least a training record, certification record, an experience record, a record of previous experience (if applicable), employee’s current examinations and a vision examination record. That all “training record, certification record, an experience record, a record of previous experience (if applicable), employee’s current examinations, and a vision examination record” should be kept in one file for each individual? Response No, a filing system is not specified in this standard. Inquiry 10-06 Improperly formatted request. Inquiry 10-05 CP-189 paragraph 6.2. requires NDT Level III examinations administered by the employer as follows: Specific exam: written exam on NDT-related requirements of specs or standards used by the employer, e.g. ASME codes. Practical exam which requires that the candidate should prepare an NDT procedure (If the documented experience demonstrates that the candidate has previously prepared acceptable procedures using specs and requirements of codes applicable to employer, a practical exam is not required). Is it required from ACCP Professional Level III anyway to undergo the exams mentioned above? Response Yes. Inquiry 10-04 Improperly formatted request. Inquiry 10-03 Improperly formatted request. Inquiry 10-02 Can the eye examination for near vision given in the middle or beginning of a month expire at the end of that same month 1 year later? Example: If an eye examination for near vision is conducted on Dec.15th of 2009, can the expiration date be Dec. 31st 2010. Response The term "date" used to establish intervals, such as "annual" in ASNT personnel qualification and certification documents is intended to be the last day of the applicable month. Inquiry 10-01 4.1.3 states “All training shall be presented by an NDT instructor”. 4.4.1.1 states “possess a current ASNT Level III certificate in the NDT method to be taught. Does it imply that if an employer has a NDT Level III in direct employment he does not require an NDT instructor to present training, since the employers Level III has met the requirement of 4.4.1.1? Response Yes, paragraph 4.4.1.1 provides that individuals that possess a current ASNT Level III certificate in the NDT method to be taught, meet the criteria as an NDT Instructor. References to an ASNT Level III certificate in ANSI/ASNT CP-189 applies to individuals holding either (or all) Level III certificates issued by ASNT, i.e. ASNT NDT Level III, ASNT PdM Level III or ACCP Professional Level III. Inquiry 09-05 Appendix C: Sample certification Form has a section to document education, including High School or equivalent. However, the pertinent sections of the document reflect no requirement for education or documentation of such (except for instructors). Suggest reflecting the requirements as needed to accommodate this aspect of qualification. Response The individual candidates level of formal education is not a factor in the requirements for qualification and certification of NDT personnel in accordance with ANSI/ASNT CP-189 standards. Inquiry 09-04 Can an ASNT Level III that is not certified in the applicable test method administer a multiple-choice Specific written examination to another Level III in that test method if he is designated by the employer as the certifying representative and that designation is documented in the company's Certification procedure? Response No, ANSI/ASNT CP-189-1995 paragraph 6.4.1 permits delegation of administration and grading of multiple-choice questions for NDT Level I and NDT Level II candidates, if so documented. 6.7 takes precedence which states, “The employer’s representative who administers the Level III examinations shall possess a current ASNT NDT Level III certificate in the method for which the examination is administered and shall be knowledgeable and familiar with the standards, specifications, and products used or made by the employer.” Inquiry 09-03 Is it the intent of CP-189 that the development of the qualification examinations described in Sections 6.2 & 6.3 be done by an ASNT Level III certified in the applicable test method? If the answer to (1) above is No, must those examinations be approved by a Level III, and if so, must the Level III be certified in the applicable test method? Response Yes, ANSI/CP-189-1995 paragraph 6.4.1 states, in part, “…The employer shall be responsible for having an individual possessing a current ASNT NDT Level III certificate develop, administer, and grade Level III specific and practical examinations. Inquiry 09-02 Is it the intent of Paragraph 6.3.3(b) that when a candidate is performing a Level II practical examination and the candidate's certification will be limited to a technique (e.g. limited to dry powder yoke magnetic particle) that only one sample needs to be used in administration of the practical examination. Is it the intent of Paragraph 6.2.4 that when a candidate is certifying to CP-189 from previous uninterrupted service as a Level III per SNT-TC-1A that a Levell" is required to perform the demonstration examination per the Level II practical examination rules even if the Levell" has performed a Level II practical examination during SNT- TC-1A certification? Response No, paragraph 6.3.3.(b) states in part, “Level II. The candidate shall demonstrate proficiency…a minimum of two samples per method…” No, paragraph 6.2.4 states in part. “…The practical examination shall include demonstrations of candidates ability to perform required activity (ies).” Documented evidence of the candidates ability to perform required activity(ies) satisfies this requirement. Inquiry 09-01 CP-189 addresses the initial on-the-job training requirements. Are we to assume that the hours required for each method must be met during each certification cycle? Example: PT requires 140 h in the method and 270 h total in NDT for the Level II. Considering that these hours are required for Initial certification, must we meet the same requirements each time we recertify? Response No. The training hours shown in Appendix A are for initial certification. Recertification requirements are addressed in Section 8.0. Inquiry 08-01 Is the requirement and/or intent of paragraph 4.3.2 that if an individual holds a current ASNT NDT Level III, the backup documentation including training and experience records need not be reviewed or retained by the employer to certify an individual in accordance with CP-189? Response Backup documentation including training and experience records is not required. CP-189 paragraph 9.2.1.3, Certification Record, states, “For Level III personnel, a copy of the candidate’s ASNT Level III certificate.” See also Inquiry 03-2. Inquiry 07-05 Does this statement (paragraph 2.2.2) imply that the certificate holder (PdM) can perform the actions in 3.2 (General familiarity because of Basic Examination) and 5.3 for all methods not just IR and VA? Response No, only the methods for which the Level III is qualified as stated in paragraph 3.2. Inquiry 07-04 If the employer does not have NDT personnel, but have PdM personnel, is it the intent of this document that there is still a need for a procedure for certification. Response Yes, if the employer must certify PdM personnel in accordance with CP-189. Inquiry 07-03 The Predictive Maintenance (PdM) individual is identified in two paragraphs in this document Scope 1.1, and NDT Levels 2.2.1, with no clear understanding who this individual is. In 1.1 the scope of this standard is to establish the minimum requirements for the qualification and certification of the PdM. This does not exist in this standard. Is it the intent of this document to address PdM personnel qualification and certification requirements. Response Yes, for Level I and Level II personnel, see paragraph 4.1.1, Table 1 and Appendix A. Inquiry 07-02 Is it the intent to allow Limited Certifications other than UT and RT film interpretation? This is not defined in the document. Both paragraphs 3.4 and 4.2.2 reference, Appendix B of this document, which is specific to RT and UT. Response No, however, for methods other than those in Appendix B, limited certification may be used as long as the employer’s written procedure meets the minimum qualification requirements of CP-189. Inquiry 07-01 Can an ASNT Level III not certified in a particular method sign certification of personnel in that particular method, if he is designated by the employer as the certifying representative? Response Yes, provided the requirements for the certifying representative are covered in the procedure for qualifying personnel. Copyright © 2012 by the American Society for Nondestructive Testing, Inc. ASNT is not responsible for the authenticity or accuracy of information herein. Published opinions and statements do not necessarily reflect the opinion of ASNT. Products or services that are advertised or mentioned do not carry the endorsement or recommendation of ASNT. IRRSP, NDT Handbook, The NDT Technician and www.asnt.org are trademarks of the American Society for Nondestructive Testing, Inc. ACCP, ASNT, Level III Study Guide, Materials Evaluation, Nondestructive Testing Handbook, Research in Nondestructive Evaluation and RNDE are registered trademarks of the American Society for Nondestructive Testing, Inc. ASNT exists to create a safer world by promoting the profession and technologies of nondestructive testing.