Here is the text of the article published in the Giornale PnD after the Trieste PnD Conference (2013). A very clear description of the critical issues of NDTs determined by the reduction of senior Level 3 personnel before they have time to transfer their experience.
Worrying that this cry of alarm was launched 5 years ago [# 1] obviously not only in Italy, given the wide geographical spectrum of action of Phil. His prediction is coming true and, if you do not rely on the few "old men" left, in another 5 years it will be too late.
Also very significant is the not revolutionary conception that the qualification [# 2] is the training activity done on the candidate before the certification for exams and not the only exams as sometimes misunderstood in the Italian aeronautic sector.
The text of the article is taken from the Giornale PnD 4-2013 published by AIPnD that made it available for ATLAI.it, agreeing with the problem here exposed common to all industrial sectors.
We thank AIPnD for the collaboration.
Level 3 Responsibilities
Peabody, Massachussetts - USA
The world of NDT, especially in the field of aerospace, is facing a major identity crisis. The industry as a whole is losing focus concerning the true responsibilities of a Level 3, confusing them with the activities for which a Level 3 is responsible. We have industry documents, EN4179, ISO 9712, EN473, NAS410, etc., that detail the activities that must be carried out by a Level 3, but these documents do little in explaining the true responsibilities that come along with these activities.
[#1] The Level 3 community, at least within the aerospace world, is an aging work force. Over the course of the next 5-10 years we are going to be losing the vast majority of Level 3’s to retirement. Today, many companies, major Primes as well as smaller suppliers, are depending upon “retirees” to support their Level 3 needs. This support is not going to be available forever. And, because a major business philosophy, today, is to “do more with less”, new Level 3 candidates do not have the opportunity to learn from their predecessors. Most companies wait until the current Level 3 is gone before they look to replace him/her. Because the supply of available Level 3’s is dwindling, rapidly, the practice most seen is for an employer to identify one of their better Level 2 persons and nominate him/her to be the new Level 3. The problem with this is that there is no opportunity for mentoring, and the new candidates can read about the activities for which they are responsible, but they don’t understand the true responsibilities that come with each. If they are told what to do, and how it is to be done, they can do it, and do it very well. They can do it repeatedly in a highly competent manner. But, when they are asked to be the person to determine what is to be done, how it is to be done, and to explain when something is going wrong, they are totally unprepared.
I cannot tell you how many times I have seen examples of an employer’s Written Practice where the Level 3 has simply cut and pasted the requirements from the Industry Standard and put the employers letterhead on the top. The document is filled with “the employer shall” without naming the employer.
“The employer shall have maintain a Written Practice…”. This document is the written practice. “The written practice shall contain…”. The document then goes on to parrot EN4179, listing all the things that are supposed to be in the document we are reading, but they are nowhere to be found in the document. The author doesn’t understand how to comply with the requirements. The new Level 3 can comply with activity requirement (approving the written practice), but do not understand the responsibility behind the activity. “I can fulfill the requirement of approving the written practice by signing my name to the bottom. But, ensuring that the written practice is complete, reflects the actual practices of the employer, meets my customer requirements, and fulfills the requirements of the upper tier industry standards? Not sure how that gets done.”
And this extends to writing method specific procedures, or work instructions where, again, the candidate knows he/she is responsible for approving the document, but not quite sure how to write the document. Or to make sure that it meets all of my customer requirements, or reflects the actual practices within the employer’s system, or can be understood by those who have to use the documents.
And, in the name of “doing more with less”, Level 3’s are being asked to become more and more involved with the day to day activities of “shipping product”. The proactive activities of the Level 3, like “assuming the technical responsibility for the NDT facility and staff” (required by EN4179), are being lost. The level 3 is becoming more of a Level 2 inspector to help move product. And when something goes awry within the system, many times it either goes undetected because the Level 3 doesn’t have the time to adequately monitor the system, or he/she doesn’t understand what do to investigate the root cause.
Internal audits, an integral means to aid the Level 3 in understanding what is happening within their own shop, are either being done by individuals not understanding the method being audited, relying upon customer or third party audits (like Nadcap), or not being done at all. The Level 3, because he/she is “too busy” to do an effective audit, goes through the motions of filling out a checklist, or using the Nadcap audit to identify issues within their shop, has lost touch with what is happening within the facility for which they are responsible.
The Level 3 today is being asked to “fight fires”, to look for opportunities to cut cost, save time and continue to keep product moving. The days of working to be proactive, to identify quality risks, to ensure that everyone understands the right way to do things, is being lost. Many level 3’s understand that they have to administer a written general and specific exam because that is defined in EN4179. But they do not understand that these exams are tools, that they should be used to determine the suitability of a candidate to perform the job for which they were hired. The understanding of how to write a good exam question, how to evaluate a given answer, is nowhere to be found. Many Level 3’s don’t even understand the requirement for the specific exam that says “open book questions shall demonstrate an understanding of the material, not simply the ability to look up the answer.” They don’t understand the difference between a “good” Level 2 question and a “good” Level 3 question.
Also, the Level 3 has the responsibility to make sure certified personnel are truly qualified to perform the activities for which they are certified, not just making sure that they meet the minimum requirements outlined in the industry standards. For example, EN4179 says a candidate must obtain at least a 70% score on the specific examination. However, if a 30 question exam contains 8 questions concerning the interpretation of acceptance criteria, and the candidate fails all 8 of these questions but everything else is correct, the candidate receives a score of 73%. A passing score. However, the candidate has demonstrated a lack of ability in understanding how to interpret acceptance criteria. Many level 3’s understand the “activity” of ensuring that the candidate’s score meets the minimum required, but they do not understand the responsibility of making sure that the candidate is truly ready to undertake the job of inspecting hardware. How can a person be allowed to inspect aerospace product, to ensure flight worthiness, if he/she does not know how to determine the suitability of a product to meet engineering requirements?
The content of the exam, as well as the manner in which questions are asked, are very important. I see so many examples of questions where “all of the above” is a standard answer. And, in 95% of the cases, it is the correct answer. In these instances the candidate only needs to understand how the exam has been written, not the material contained therein. In the case of the practical examination, where a checklist is required, many Level 3’s don’t understand how to write an effective checklist, or to administer a proper practical examination. My favorite example was the Level 3 who wrote a checklist containing 10 checkpoints of which 5 were passed properly while the other 5 resulted in the following:
1. Does the paperwork match the part? The “part” was a welder qualification test plate. There was no paper work. The candidate was simply given the test plate and told to identify what he found. (The candidate received 10 points)
2. Is the part properly cleaned before application of penetrant? The Level 3 stated that he cleaned the test part prior to giving it to the candidate because he wanted to make sure all residual penetrant materials were removed. (The candidate received 10 points)
3. Was the proper penetrant applied? The facility only had one penetrant! (The candidate received 10 points)
4. Were all fluorescent indications properly evaluated? The candidate circled anything that fluoresced. He could not determine the difference between a relevant indication and a non-relevant indication. However, in calling out everything that fluoresced, this included the significant indications. The Level 3 said “he found the cracks”. The candidate received full credit.
5. Was the test piece properly cleaned after the test? The Level 3, again, said that he cleaned the test pieces after the exam because he wanted to make sure it was clean before he put it away until the next time it was used.
This Level 3 had “borrowed” a checklist from a facility at which he had previously worked. He did not know how to make his own checklist that would be appropriate for his shop. He did not know how to properly evaluate a potential Level 2 candidate. But he fulfilled the activity requirement of the industry standard by having a checklist, and a known defect test sample. The candidate met the minimum requirements, identifying all of the significant indications and receiving at least a 70% on the rest of the exam, but the Level 3 did not understand his responsibility for ensuring that the candidate was truly qualified before being certified [#2] : in fact, reviewing the inconsistency of the previous 5 checkpoints, the candidate was receiving 50% credit for doing nothing ! In order to receive the necessary 70% minimum, he only had to earn 20%!
The Level 3 must approve the training outline. Today, many employers outsource training to save resources. This is not only acceptable, in many cases it is the right business decision. However, it does NOT mean that the Level 3 is not responsible for the training, its content or the people who deliver the training. Whether the training is done in-house, by an outside agency or by a National Aerospace NDT Board (NANDTB), the Responsible Level 3 is still responsible for making certain that the training that is given meets his employer’s needs. And, that the training that was given was properly received and understood by the candidates. The employer must still have a training outline that defines his training needs, and the Responsible Level 3 must evaluate any training that is given, by whatever source, and make certain that the training is sufficient to meet his company’s needs. Any outside training should also be supplemented with internal specific training. This supplemental training, if it is not covered by the outside agency, must include the operation of the employer’s equipment, the employer’s quality requirements, the employer’s customer requirements and internal procedures. The Level 3 cannot simply say that “we use an outside agency for training” and feel absolved of any further responsibility.
Previous revisions of EN4179/NAS410 used to state that there is no additional training required to progress from Level 2 to Level 3. This was removed from the current version of the documents simply because it was not true. There is a tremendous amount that a Level 2 must learn before being ready to advance. But the industry standards don’t give any guidance as to what these needs are, and how the knowledge is to be obtained. These are the things that experienced, and proficient, Level 3’s must pass along to their successors. These are the things employers should make certain are being taught to their new Level 3 candidates, and these are the things that any new Level 3 candidate should understand that they need.
And, because employers are looking, more and more, to “do more with less”, and use outside agencies whenever possible, these outside agency level 3’s have to have the same understanding of Level 3 “responsibilities”, not just the activities they are required to perform. Not just ensuring that minimum requirements are met, but looking for the candidate to demonstrate understanding of these requirements and demonstrating an ability to comply.
This is a dilemma that the aerospace industry is facing today, and it will only grow as the aging Level 3 workforce moves on and the new generation of Level 3’s is empowered. It is up to the employer, the owner of the product and the responsibility for its quality, to make certain that their Level 3, whether an internal employee or an outside resource, understands his/her true responsibilities as well as minimum requirements, and that time and resources are properly allocated to ensure that “we are all doing the right thing, not just doing things right.” We need to make certain that we are not just meeting the letter of the law, but that we are meeting the true responsibilities that lay behind.