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What Do You Think… P
eriodically, the Condenser publishes articles that present an author’s point of view and commentary on a topical issue of interest to the industrial refrigeration industry. In this column, we will briefly examine a trend and ask for your feedback, your thoughts, and your observations. In this issue, we take a look at…
The Case for Qualification and Certification of Mechanical Integrity Inspectors By Keith A. Tyson It is time for your plant to have a third-party inspection. How do you decide who to use? Before an inspector is hired, the owner/manager of the equipment has a right – and a responsibility – to know answers to the following: • What assurance is there that the inspector has the knowledge and ability to perform the inspections or tests? • Does the inspector have enough experience and training to support the report’s conclusions? • What makes the report on equipment condition credible? • Can a report that recommends the repair or replacement of equipment to meet safety requirements be trusted? • Can I sleep at night believing a report that states no harm or damage is likely to result from continued use of the inspected equipment? • Is there a system that allows me to have confidence in an inspector’s methods, procedures, and reports? These questions are common to most industries. Dependable answers are provided by a standardized written program and procedure for the qualification, training, and certification of inspectors. Other industries have requirements for inspectors. Nearly all pressure vessels and exchangers have ASME certifications which denote, at some point in their assembly, the inspection or testing by a person holding specific credentials. The methods of training, qualification, and certification for these inspectors are codified and well known. This assures the owner that that equipment is suitable for the conditions in which it will operate. Ammonia refrigeration systems are required to be inspected and tested in order to comply with OSHA’s PSM mandates. These duties must be performed in accordance with “recognized and generally accepted good engineering practice”. This is commonly interpreted as conforming to ANSI/IIAR-2, Bulletin 109, and Bulletin 110 which provide 16
the basis for inspections and tests. The IIAR bulletins stipulate only that the inspector must be “competent”. Bulletin 109, paragraph 5.3, states that “A more thorough inspection…should be conducted by a competent ammonia refrigeration engineer … every five years.” Bulletin 110 adds, in paragraph 6.4.4.1,“…the annual inspection of the vessels and heat exchangers shall be carried out by a competent person independent of immediate commercial and production pressures for that installation…” No other requirements for the inspector are provided. There is a growing awareness by auditors that the industry standard does not adequately address inspector qualifications. In fact, recent OSHA audits of refrigeration systems have found persons previously thought “competent” to be inadequately equipped for inspection duties. If the question is “How do we know the inspector is competent?” The logical response is “An inspector should be qualified, trained, and certified to perform the inspection and tests.” The process begins with the development of written inspection and test procedures. Although details of these are beyond the scope of this article, the documents should state inspection goals as well as the minimum qualifications for inspectors —including a certification level. The procedures ought to specify whether the inspector may be a facility employee or must be an independent contractor. If the inspection requirements are clearly stated, then the final report will yield relevant information.
Qualification of the Inspector A written inspection program defines the amount of training required based on the combination of education and experience. This is known as qualification. The training required for an individual factors in educational level, previous training, and related work experience. A new hire with a high school education and no ammonia refrigeration experience requires a great deal more instruction than an operator who has had refrigeration training and work experience. A person with pertinent higher education, such as an engineering degree, will likely not need as much preparation. It is useful to observe the training programs required for individuals who perform inspections and tests in other industries, such as petroleum or chemical. The employers of such inspectors use The American Society for Nondestructive Testing, Inc Recommended Practice No. SNT-TC-1A. This guideline provides a standard methodology for the qualification, training, and certification of inspectors. Most
Condenser | November 2011 | A Publication of the International Institute of Ammonia Refrigeration