Considering Repairs and Alterations? Remember to Notify an Inspector
This article was originally published in the fall 1997 National Board BULLETIN. Some code requirements may have changed because of advances in material technology and/or actual experience. The reader is cautioned to refer to the latest edition and addenda of the National Board Inspection Code for current requirements.
According to recent National Board inquiries, failure to notify an inspector before a repair organization contemplates repairs and alterations is on the rise. Reports indicate that the failure of notification occurs during all stages of repair: before repair begins, during the course of repair, and at the conclusion of the repair.
According to inquiries made by inspectors or the jurisdictions, this apparent failure of notification is the result of economics, emergencies, and availability of the inspector.
Failure of notification has intensified since the 1995 edition of the National Board Inspection Code (NBIC) was adopted and the scope of routine repairs was reduced. Some repair organizations neglected to fully upgrade their Quality Systems to ensure that all repairs or alterations received the same degree of monitoring by the inspector.
For the most part, this neglect was not intentional but instigated by failure to understand the current requirements of the NBIC and from the lack of coordination between the owner/user and the repair organization to select an inspector. As stated in the NBIC, the repair organization is required to notify the inspector prior to the start of work for all repairs and alterations; Part 3:1.3.1
The R Certificate Holder is responsible for satisfying all NBIC requirements; noncompliance may result in suspension or revocation of the R certificate.
Beyond a violation of the NBIC, there are additional concerns caused by the failure to notify an inspector. The ability to determine if the repair or alteration was properly performed is highly questionable if the inspector was not present. Without inspector involvement, the jurisdiction will make the final judgment.
In some cases, the repair organization may be required to redo all of the repair and alteration work accomplished to date. This way, the jurisdiction will be assured that the quality system was followed and that proper controls were in place. At this point confidence will be gained by the inspector to certify the repair and alteration.