No, it’s not that kind of party…

In April I attended several standards development meetings dealing with product and personnel competency approvals. One of the key questions in the development of any code or standard is ‘who will have the final responsibility for compliance’? Codes and Standards are very carefully written to ensure that they can be used in a manner required by the regulations.

Codes and standard, when adopted by regulation, become legal requirements and identify the acceptable approval system(s). For this reason, committees must have a clear understanding of the 1st, 2nd and 3rd party requirements.”

I hadn’t really given this much thought until returning to Canada last week and meeting with a client. They were looking for information about the possibility of a 3rd party approval for a Z662 pipeline process needed for an upcoming project. Their thinking was that if a 3rd party approval could be obtained for their service provider, it would eliminate their responsibility for evaluating the process. This is a common misunderstanding and unfortunately it just doesn’t work that way.

Type of Party 1st 2nd 3rd
Certification (declaration) of conformance required by: The manufacturer of a product or the service provider of a skill. The owner of the thing constructed from the product or service. A technically knowledgeable entity independent of the 1st or 2nd party.
Product examples: Teddy Bears must comply with the “Toys Regulation”. Manufacturers are required to understand and be able to prove compliance with the regulation. The manufacturer declares compliance with a label affixed to the toy. Line Pipe must be verified by the pipeline company as complying with the standard. Typical assessments could include a verification or review of the manufacturers quality system including test instrument calibration program and examination of MTR data. Toasters are required to meet construction and safety requirements established by electrical standards and verified by an accredited certification body such as CSA-International. Products must bear a registered certification mark.
Skills examples: Residential lawnmowers do not require operator qualification. The machine is provided with written safety and operating instructions. A neighborhood kid can offer to cut your lawn simply declaring that he will do a good job. Under section 13.3 of the CSA Z662, companies are required to evaluate the training, experience, qualification and output of fusion technicians to confirm competence at the skill level they require for their pipeline system. The repair of motors certified for use in Hazardous Locations can only be performed by qualified individuals in a certified setting and authorized to maintain the specialized certification of the product they are working on.

Third party approvals are usually required where potentially complex or serious safety issues could exist and the owners (often the public) cannot be reasonably expected to have the necessary knowledge or safety management systems to evaluate the completed products or services for compliance.

Confusion can arise when a 3rd party approval is available in a 2nd party system. The design, construction and operation of Oil and Gas Pipelines are regulated under a 2nd party system but use products and services where 3rd party approvals may be available. This often leads companies into a serious false sense of security.

Under both CSA Z662 section 3 and API 1173, the company (owner) is the 2nd party. The company is required to have a program that establish requirements for, and evaluates the competence of, personnel performing assigned tasks. Pipelines are complex systems that include many factors including service fluid, operating pressure and operating environments. Because of this the design, construction and operation for each pipeline system must be considered project specific. The competency of personnel executing the design, construction an operation functions must be established and verified based on the project tasks.

Consider welding. A journeyman welder qualified for structural steel on a high-rise construction project will require different experience and skills when compared to another journeyman who welds Oil and Gas Pipelines, even though both may carry the same trade credentials.

Now let’s assume we have established and qualified a weld procedure identifying very detailed requirements to produce a compliant pipe weld for our project. We have identified the levels of training experience and qualifications (competence) that the welder must have to work on our project. A welder arrives and shows that he has very high levels of 3rd party welding certifications and qualifications (CWI, AWS, CWB level 1 etc.). He does not have the record of pipeline experience and qualifications we have identified. He insists that the 3rd party endorsements are all we need for proof of his experience and qualification, and that if there are any problems the responsibility will rest with the 3rd party certification organization.

Here is the tricky part. We can certainly assess and choose to accept his credentials if we believe they are equivalent, but under a 2nd party system we accept full responsibility, no differently than if we had evaluated his qualification under our in-house criteria.

There are numerous 3rd party qualifications available from reputable organizations including API, AWS, CGSB, CPAC, CWB and NACE, to name a few. The qualifications provided by these organizations can be very valuable tools in establishing, assessing and supporting various competency requirements. It is however critical to remember, that when using these tools, that we (2nd party) still retain full responsibility for the identification and acceptance of the competencies of our personnel (staff and contractors) for our project tasks. 3rd parties taking full responsibility for the product or skill only occur in 3rd party standards as we noted at the start: The CSA Z662 and API 1173 are 2nd party standards.