Owner User Welding Procedures 2

[mjknair]

Hi All, Can asset maintenance department use welding procedures qualified by contractors during construction of the asset, Plant maintenance and weld repairs if any are directly performed by owner user and not contractor.

 

[metengr]

No, welding procedure specifications (WPS) should be qualified by the organization using them unless you purchase standard welding procedures from AWS. You still need to qualify welders using a qualified WPS.

 

[SJones]

What do the regulations in the Owner's part of the world stipulate? In a number of places, the Owner has the capability to do what is being proposed on the basis that they have the ultimate responsibility to demonstrate that it is safe to do so.

Steve Jones
Corrosion Management Consultant

http://www.linkedin.com/pub/8/83b/b04

All answers are personal opinions only and are in no way connected with any employer.

 

[metengr]

Agreed, if there are no regulations you can do as you please in some parts of this vast world of ours. Which is why most reputable codes and standards or large companies would tend to shy away from using another organization's procedures.

 

[SJones]

Why not use them if the owner paid for and approved them for use in the first place and is satisfied that there are no technical issues with them? To not use them would suggest that there was something wrong with them, calling into question the integrity of the equipment.

Steve Jones
Corrosion Management Consultant

http://www.linkedin.com/pub/8/83b/b04

All answers are personal opinions only and are in no way connected with any employer.

 

[metengr]

ASME Boiler and Pressure vessel code prohibits this practice. Your approach works for standard welding procedure specifications purchased from AWS. You can even place the company them on them.

 

[Duwe6]

NOTE: ASME B31.3 makes specific provisions to allow use of WPS's "qualified by others". So some of ASME B&PV Code allow it, but most Code sections disallow it.

In the "Grand Scheme of Things", it is not that expensive to run a PQR coupon and have the tensiles & bends performed. Consider that PQR as a capital expense - PQR's actually outlast the corporate headquarters building, making them pretty much the definition of a capital expense. Since you already have WPS's that you seem to like in-hand, run some PQR's to support those WPS's, copy the contractors' WPS's onto your company letterhead, list your PQR's; voila - fully qualified WPS's without having to hire a welding engineer.

 

[mjknair]

metengr, SJones and Duwe6 - thanks a lot for your advise. A challenge ahead for me to convince and get the required PQR's run.

 

[weldstan]

Assuming that regulations in your location would permit the use of another company's welding procedures, your company should obtain their approval in writing.

 

[SJones]

Just a quick comment: B31.3 is not a boiler and pressure vessel code. Moving on, it seems that we are perhaps missing the point slightly. The gist of the question appears to pertain to the equipment OWNER using welding procedure specifications that have been qualified by others. In my experience, OWNERS write contracts such that any documents developed in the course of building and installing the equipment become the intellectual property of the OWNER. I can't say that this would fly in the US, but it has no challenge in certain parts of the world, particularly the Middle East. So, the OWNER has a library of WPSs (and PQRs of course) that have been used to construct the facilities that are to be maintained by the OWNER's maintenance crew - here the maintenance crew are deemed to be direct employees of the OWNER and not those of a second party contractor. The OWNER's welding engineer, who reviewed and accepted the WPSs for construction, is satisfied that the efficacy of their application during construction was satisfactory, likewise their in service performance - why shouldn't he/she then pass them to the OWNER's maintenance crew (direct colleagues) as direction for maintenance welding on the very same items that were constructed with them in the first place on the basis that the maintenance crew have achieved satisfactory welder performance qualification (possibly qualifying with the actual WPSs rather than applying essential variable allowances to qualifications performed against other WPSs)?

Steve Jones
Corrosion Management Consultant

http://www.linkedin.com/pub/8/83b/b04

All answers are personal opinions only and are in no way connected with any employer.

 

[DekDee]

Steve,
Let's leave the technical side for the moment (and on that I agree with metengr) and look at the ethical side of things.
Hypothetically, I own a welding fabrication company and you hire my company to fabricate, weld and install a huge amount of super duplex piping in your new refinery.
I spend $30,000 on qualifying numerous SDSS welding procedures - this money may or may not be recouped in the contract price, dependant on what type of contract it was.
After completion of construction (which went very well) I will be looking forward to ongoing work from your company on shutdowns (I think you call them outages in the US),maintenance and possible modifications.
I will not be very impressed if I never get a call because you are using your own personnel and my welding procedures to do the work.
Take it one step further, if you have now taken "ownership" of my welding procedures what is to stop you from hiring a cheaper company (cheaper because they don't have any qualified WPS's) and giving the work to them using my welding procedures ?
Some food for thought ?
Cheers,
DD

 

[SJones]

Hypothetically, this thread is going along a similar route to this one: thread178-238986

Essentially: what is the OWNER allowed to do, versus what should the OWNER do.

Steve Jones
Corrosion Management Consultant

http://www.linkedin.com/pub/8/83b/b04

All answers are personal opinions only and are in no way connected with any employer.

 

[DekDee]

Steve,
Interesting you posted that link - I am one of your supposed "reactionaries" - (formerly Ballbearing).
ASME IX makes no mention of Owner - it lists manufacturer, contractor, assembler or installer.
Based on your previous posts it appears you do not think the Owner has to comply with the requirements of the code, only the manufacturer, contractor, assembler or installer.

QW-100.1 A Welding Procedure Specification (WPS)
is a written document that provides direction to the welder
or welding operator for making production welds in accordance
with Code requirements. Any WPSs used by a manufacturer
or contractor that will have responsible operational
control of production welding shall be a WPS that has
been qualified by that manufacturer or contractor in accordance
with Article II, or it shall be an AWS Standard
Welding Procedure Specification (SWPS) listed in Appendix
E and adopted by that manufacturer or contractor in
accordance with Article V.

QW-103.1 Welding. Each manufacturer or contractor
is responsible for the welding done by his organization
and shall conduct the tests required in this Section to qualify
the welding procedures he uses in the construction of the
weldments built under this Code, and the performance of
welders and welding operators who apply these procedures.

What happens if you substitute Owner for manufacturer or contractor in both of those clauses ?
Regards,
DD

 

[SJones]

What happens if you substitute Owner for manufacturer or contractor in both of those clauses ?

Very good question. the answer could depend upon a number of things: regulations, specific equipment, need to keep within certification requirements etc. The answers tend to fly in from North America and tend to pertain to pressure vessels. Not everyone is in North America, and what about piping? Similar to the linked thread - it is getting to be a "I've looked at the code and it says no" type of exchange.

For example, my current location has no readily apparent requirement legal, company or otherwise to ever have or to maintain a code stamp of a pressure vessel. I can't say that I'm overly keen on such an arrangement, but what if the OP was also located in the same place? Does the response have to be "I've looked at the code and it says no?" What the OP is asking is routine for this part of the world.

Steve Jones
Corrosion Management Consultant

http://www.linkedin.com/pub/8/83b/b04

All answers are personal opinions only and are in no way connected with any employer.

 

[DekDee]

Steve,
Not sure what code stamping of a pressure vessel has to do with the current discussion.
We are talking about the requirements of ASME IX.
I have worked in Australia, New Zealand, China, Thailand and currently in Malaysia but in all these countries if you are working to ASME codes and your PQR/WPS/Welder Qualification must be in accordance with ASME IX then you must comply with code requirements no matter whether you are a manufacturer, contractor, assembler,installer or Owner.
Regards,
DD

 

[SJones]

Code stamping is in respect of maintaining code stamping after having performed maintenance welding on the item which would be very difficult, or impossible, with the practices under discussion.

As to maintaining compliance with ASME codes in Australia, New Zealand, China and Thailand, that may be because it is stipulated by law, or other instrument. That is not the case everywhere - there is nothing requiring adherence to ASME codes in terms of administrative and operational control of welding procedure specifications when it comes to undertaking post-commissioning welding in this part of the world. The owner is free to do as seen fit. When the State is the Owner there is possibly some scope for conflict of interest.

Steve Jones
Corrosion Management Consultant

http://www.linkedin.com/pub/8/83b/b04

All answers are personal opinions only and are in no way connected with any employer.

 

[Duwe6]

DekDee, your citation of Sect IX stuff is 'trumped' by any ASME Code-of-Construction. That is why it is 'legal' to use some WPS's 'qualified by other' in ASME B31.3 work. Since Sect I & VIII, and B31.1 are silent on that item, then and only then are the governing rules found in Sect IX. It is a small point, but keeping track of what item supersedes what is really incumbent on the design engineer. But this usually falls on the Inspector. And when the Inspector sees the problem, it usually takes a lot of time and/or money to fix.

 

[DekDee]

Duwe6,
If you follow the link Steve Jones provided you will see it was me (with user name Ballbearing) that initially raised the topic of B31.3 "Qualification by others",
Regards,
DD