Pressure welder program and fee consultation: Feedback from meetings

Renewal requirements

• The requirement to do a specific pressure welding test for renewal is redundant.
  • Pressure welders are already tested more than any other trade.
  • Testing is already governed by ASME IX requirements; it is a burden maintain something that is already done regularly.
  • If a pressure welder has their BCP-100, a boiler safety officer has already supervised a test.
  • This seems like proving our ability to pressure weld, when many pressure welders already have a red seal welder qualification.
  • The requirement to test those who haven’t been tested makes sense, but what about people who are constantly working and do different performance qualification tests and are already under a level of scrutiny?
• Notwithstanding fees, sending a pressure welder for renewal test disrupts their schedule and is a cost to contractors.
• If a pressure welder fails their renewal test, when can they retest? What are the fees? How many attempts are allowed?

In response to questions and comments, Technical Safety BC clarified the following:

• The Class A renewal test is not in accordance with a particular pressure welding procedure, it will be in accordance with your certificate of qualification.
• You can take the renewal test in advance of your expiry – your certificate will expire every three years in your birth month. Everyone would be entitled to retest if you fail your exam, but consider a scenario where someone fails multiple times.
• It is industry standard to renew qualifications and have continuing education.
• If you pass an X-ray test for production welding following one of the ASME B31 piping construction codes, it may not meet ASME IX requirements, which are even more stringent. The renewal test is a standardized test so to work everyone to the same standard with the bend test.

Proposed fees

• Because the program is redundant, it feels like a cash grab.
• The cost to welder to enter the pressure welding field is already around $650, plus the cost to travel to the testing facility.

In response to questions and comments, Technical Safety BC clarified the following:

• Although it seems like a new requirement, there has always been the ability to create a pressure welder certificate of qualification program, and Technical Safety BC is only invoking this now. BC is the only province that does not have a pressure welder certificate of qualification. Moving forward, the certificate of qualification will be your eligibility for doing pressure welding jobs.

Logbooks

• If recognized test administrators are going to be to signing the segment on quality control, this adds cost to the pressure welder and contractor.
• Agree with Quality Control professional being the one to sign logbook for employment.

Registered welding procedures

• Will procedures held by Technical Safety BC still available as pressure welding procedures?

In response to questions and comments, Technical Safety BC clarified the following:

• Yes, pressure welding procedures that are held by Technical Safety BC can still be used in production.

Transition requirements

• The shop we operate does not weld pipe in field, and therefore do not have the pressure welding procedure requested for the transition.
• If I’ve completed the BCP-100 but haven’t maintained continuity with that procedure, is that acceptable for transition?
• Will Technical Safety BC offices be open and ready for the number of applicants looking to transition into the new program?

In response to questions and comments, Technical Safety BC clarified the following:

• Yes, the BCP-100 is an acceptable welder trade qualification for transition. You can use a different procedure for the continuity requirement for transition.
• The application for pressure welders will be online, and photocopies of logbooks and records are acceptable. There is no need to physically go to a Technical Safety BC office.

Certificate portability

• Will the Class A be recognized interprovincially?
• Would be more inclined to be more positive toward the program if the certificate will be recognized interprovincially.
• Completed BCP-100 (currently the standard across Canada) and then transferred to another province.

In response to questions and comments, Technical Safety BC clarified the following:

• Yes, Technical Safety BC will be working with the other Canadian jurisdictions and the intent is to have the Class A certificate of qualification be recognized interprovincially.
• The Class A certificate of qualifications will replace BCP-100 testing, and the syllabus looks the same. This creates a fixed fee for the practical exam. It is understood that it is currently hard to schedule a boiler safety officer for exam invigilation.

Recognized test administrators

• How can my company become certified as a recognized test administrator?

In response to questions and comments, Technical Safety BC clarified the following:

• The process to become a recognized test administrator is available on the Technical Safety BC website.
• Envision that more contractors will want to become a recognized test administrator able so that they can do their own testing.

Class IT

• Great that the new program will allow apprentice pressure welders to get practical experience on pressure welding procedures.

Recognized Test Administrators

• Who is the correct person to become a qualified tester? Is it the same standard as before?
• Hoping to be able to meet the needs of my area and would like to get my facility up to the standard to be a recognized test administrator.
• It will likely will be weeks to find a recognized test administrator available. Understand reasoning behind requiring a recognized test administrator, but why not let quality control managers do the testing?

In response to questions, Technical Safety BC clarified:

• Yes, the standard set in 2017 for having qualified testers at recognized test administrators still remains the same.
• Contractors and shops can apply to become a recognized test administrator if they would like to test their own pressure welders.

Becoming a pressure welder

• The new program makes more difficult for pressure welders to get qualified because contractors now need to find a recognized test administrator when you hire someone new. The pressure weld test is overseen by a quality control manager and is the weld is sent out for X-ray, why isn’t this sufficient?
• The changes don’t streamline anything, it actually makes it more onerous and more expensive to hire pressure welders. It is cheaper to have non-code pressure vessels contracted from the US than it would be to have them built in-house. Welders are certified to do both code and non-code work. This makes it more expensive and puts BC at a disadvantage.
• Will pressure welders still get tested to welding procedures?

In response to questions, Technical Safety BC clarified:

• Testing by a recognized test administrator is already a requirement for pressure welders.
• BC is behind in issuing certificates of qualification for pressure welders; many other jurisdictions already have certificates of qualification programs for pressure welders and require renewals.
• Yes, pressure welders will still get tested to welding procedures.

Class R

• When hiring a rig welder, first do a production weld test. Is this still the same process?
• If hiring an Alberta-certified welder whose PWP7 has expired, will they need to do a production weld to requalify?
• Concern that if there is an immediate need, the certification process cannot be done quickly.

In response to questions, Technical Safety BC clarified:

• Yes. If hiring from out of province, the pressure welder will need to get a certificate of qualification and their certificate of qualification test can be a pressure welding procedure test held by the contractor, which can be used in production.

Renewals

• Will pressure welders need to retest every three years on all the tests that they have in their logbook?

In response to questions, Technical Safety BC clarified:

• No. Boiler contractors likely already test frequently, but no, pressure welders do not need to test to each procedure every three years. There is a standard practical test that needs to be completed for renewals.

Proposed fees

• The Technical Safety BC fees are more than reasonable. In comparison, another company hired a third party to write their welding procedures, which can be costly. 

Transition

• The transition deadline is December 2, 2020. Has Technical Safety BC allotted enough time to allow every pressure welder to be retested for the new program?

In response to questions, Technical Safety BC clarified:

• Pressure welders do not necessarily need to be retested in order to transition into the new program.

Logbooks

• Will new logbooks be issued? How will the contractor know that a pressure welder is qualified?

In response to questions, Technical Safety BC clarified:

• ITABC/Technical Safety BC is not reissuing logbooks. Technical Safety BC will issue a wallet card for certification to each pressure welder.

Issues with current program

• How will this program affect ASME shops? ASME shops and MA contractors can hire anyone currently.
• MA contractors need to be treated the same as an A contractor. Currently the Safety Standards Act and syllabus for MA contractors says to follow ASME.

In response to questions, Technical Safety BC clarified:

• These are legacy issues that we are addressing. Ministerial Order M317 requires that all pressure welding work be done by a holder of a certificate of qualification.

Harmonization

• Is there still the need for BCP-100?

In response to questions, Technical Safety BC clarified:

• No. Technical Safety BC is working to harmonize the Class A certificate of qualification for portability across Canada.

Licence requirements

• When subcontracting pressure welders, will the subcontractor need to hold a class PW contractor licence?
• How does this apply to rig welders?

In response to questions, Technical Safety BC clarified:

• No, the subcontractor would need any class of boiler contractor licence that will allow pressure welding work according to their quality control manual.
• The ASME Code allows rig welders, who generally operate as a company, to work under the scope of the main contractor’s licence.  These rig welders would not require a Class PW licence.

Logbooks

• Who signs the logbooks after tests instead of boiler safety officers?
• Will the continuity log still be applicable?

In response to questions, Technical Safety BC clarified:

• An RTA supervisor will be responsible for signing the logbooks after successful completion of a welding performance qualification test.
• Yes, the continuity log is still applicable.

New class A requirements

• Can anyone other than boiler safety officers administer Class A initial exams?

In response to questions, Technical Safety BC clarified:

• No, the boiler safety officers will be the only ones to administer initial Class A exams.

Transitioning pressure welders

Will currently active pressure welders be required to retest in order to transition?

• If a pressure welder is currently registered and do not have F3/F4 or F6/F4, would they  be able to transition? 
• If you get a new certificate of qualification and no need to renew for three years but do not perform pressure welding in two out of those three years, would you be denied a certificate of qualification?
• Will any F3/F4 or F6/F4 tests be accepted for transition?
• No issues with renewal test in three years, but some people feel it is unfair they are currently qualified why are those no good to transition.

In response to questions, Technical Safety BC clarified:

• Anyone who is currently working as a pressure welder and meets the requirements for transitioning do not need to retest.
• If they have not completed the specific practical tests required for transitioning, even if they are currently working as a pressure welder, they would not be able to transition. Technical Safety BC is proposing a standardized test(s) for the initial Class A certificate.
• Any F3/F4 or F6/F4 tests would be acceptable for transitioning.

Class IT and Class R

• Class IT sounds like a good thing for young welders to gain experience.
• Class R makes sense. Understand that this is currently a gap in the regulations.

Applicability to ASME shops

• Will ASME shops need to hire pressure welders that hold certificates of qualification?
• Technical Safety BC should clarify this requirement to ASME shops as they may think they are exempt.

In response to questions, Technical Safety BC clarified:

• Yes, ASME work is regulated work and their pressure welders will require a pressure welder certificate of qualification.