May 2, 2014
Q: I work for a large U.S. corporation that is made up of 15 manufacturers, each with well-known brands within their respective markets. Since we all work for "X-Corp.," it seems as though we could share welding procedures specifications (WPS) and procedure qualification records (PQR) across the company and save on testing and qualification expenses. Could a case be made for each division to use centralized X-Corp. WPSs that are supported by the PQRs run by the 15 different manufacturers?
A: That's a good thought. Let’s take a look at a couple of code provisions. AWS D1.1, 188.8.131.52 states, "Each manufacturer or contractor shall conduct the tests required by this code to qualify the WPS.” That same provision goes on to discuss consolidation with parent companies.
For some, that may create a gray area. But CWIs, in addition to being able to reference code provisions, also have to understand code intent. The best way to do that is to reference the intent as found in the annexes and the commentary of the code.
You’ll remember those sections. They are the ones your CWI instructor suggested you steer clear of during your exam. The commentary, located in the back of your code book, shares the same clause and provision numbering preceded by a “C.”
In D1.1 Annex K, "Contractor" is defined as "any company, or individual representing a company, responsible for the fabrication, erection, manufacturing, or welding, in conformance with the provisions of this code." C184.108.40.206 of the commentary states, "All contractors shall be responsible for their final product." X-Corp. would have no interest in taking on that responsibility when it has little control over fabrication, erection, manufacturing, or welding. That is the reason each contractor, or division of X-Corp., hires guys like us.
We can share the information gathered from the testing, but we cannot share the PQR. The PQR applies only to the individual manufacturer (contractor), not to the group. Having the information is certainly helpful, but it would only be to aid you in the processing of your own testing.
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