Changing of the Guard

In July of this year, John Moody (former Senior Technical and Certification Engineer at BINDT) concluded that it would be an appropriate time for him to retire. As a direct result of John’s retirement, I am pleased to say that this has provided me with an opportunity to continue John’s work for the provision of information relevant to BINDT’s NDT News readership. So, in this first ‘Boulton’s Bulletin’, it gives me great pleasure to provide you with current information on a topic that was very close to John’s heart. However, unlike the Changing of the Guard at Buckingham Palace, there is, I’m afraid to say, no formal ceremony in which sentries providing ceremonial guard duties at important institutions are relieved by a new batch of sentries, only me!

BS EN ISO 9712:2022 and PCN 24 requirements for employer responsibility
I was recently contacted by an ex-colleague of mine who has concerns about the requirements in Section 5.5 of BS EN ISO 9712:2022 for responsibilities attributed to the employer and, in addition, for ensuring employers have been suitably informed of their ongoing commitment to demonstrate understanding and compliance with the requirements of BS EN ISO 9712:2022, requirements that shall be documented within a written procedure produced by the employer for all to see. Therefore, the certification body (BINDT) would like to ensure that those organisations that do not already possess a copy of the latest version of BS EN ISO 9712:2022 remain aware of their ongoing responsibilities, which will also be available to view within the revised PCN Scheme documentation suite, designated PCN 24, which is due for release for use by approved training organisations (ATOs) and authorised qualifying bodies (AQBs) in January 2024 and mandated for use by employers and candidates on 1 July 2024.

Therefore, as a reminder to the employer, it is worth noting the following, which should be considered for inclusion within the employer’s ‘written procedure’:
“Where required by regulatory requirements and codes, the authorisation to operate shall be given in writing by the employer in accordance with a quality procedure that specifies amongst other things any additional employer-required job-specific training and examinations designed to verify the certificate holder’s knowledge of relevant industry code(s), standard(s), NDT procedures, equipment, and acceptance criteria for those products tested.”

BS EN ISO 9712:2022 goes on to confirm that the employer shall remain responsible for documenting the employee’s personal information, which shall include a declaration of education, training, industrial experience and the visual acuity needed to determine the eligibility for certification. In respect of all certificated NDT personnel under the control of the employer, then the employer shall remain responsible for:

All that concerns the authorisation to operate, ie providing job-specific training (where deemed necessary).
The issuing of a written company-based authorisation to operate/carry out NDT on behalf of the employer or the employer’s customers.
The ongoing results of NDT activities.
Ensuring that the annual vision requirements for visual acuity and colour perception as detailed within the latest edition of PCN GEN are met.
Maintaining documentary evidence/records confirming the continuous application requirements for NDT within the method, in the relevant sector(s) and without significant interruption for certification held are maintained; this action shall be verified at least once in every previous 12-month period.
Ensuring that personnel hold valid certification relevant to their tasks within the organisation in which they are employed.
Maintaining appropriate records.

The responsibilities listed from (a) to (g) shall be described in a documented procedure; the documented procedure may, in addition, form part of a company’s written practice where it is a requirement for a written practice to be produced.

Therefore, and in order to assist those companies that are required to produce a detailed written practice, which may include details of the employer’s procedure for employer-based responsibilities, and for the purposes of standardisation, it would be worth noting that guidance for the production of a suitable written practice can be found within the following American Society for Nondestructive Testing (ASNT) publication:
‘ASNT Document 10173 – A Model Written Practice’
This is a guidance document for the preparation of ‘employer-based’ certification procedures for the qualification and certification of NDT personnel, but nevertheless a document that may also provide guidance to employers and auditors alike when assessing compliance and assurance as to the inclusion of minimum content required to ensure that any specialised knowledge of parameters such as equipment, NDT procedures, materials and products have been fully considered by the employer.

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