Q: During an API audit, an auditor wrote an audit nonconformity stating that we had disposed of welder continuity records that were older than 5 years; do you think this is really a finding since API Spec. Q1, Section 4.5 states in part “…Records shall remain legible, identifiable, and retrievable. Records shall be retained for a minimum of 5 years or as required by customer, legal, and other applicable requirements, whichever is longer.”
A: To ensure you minimize any risk associated with this issue, I recommend maintaining the welder continuity records.
If the records have been disposed, in order to respond to the API AAR, there should be sufficient evidence within your quality management system to prove the welder has been welding in any given process through work order records, time cards, and the like.
From one perspective, 5 years is the retention period specified by Q1.
However, there are a couple of other points to consider in this equation.
- How do you prove that you had continual welder continuity if you do not maintain the welder continuity records? I suspect that ASME Section IX and/or AWS D1.1 (as examples) only specify that these records are required and most likely do not specify a retention period, hence the question I posed.
- The other important point to remember is the retention period required by the API product specification. Some specifications require records to be retained for “x” years upon a product becoming obsolete while others may just specify retention for “x” years.
I believe your position would be more sound if the product specification agrees with Q1’s 5 year period; however, the question posed in item #1 above still exists.
— Bud Weightman
President, Qualified Specialists, International
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Qualified Specialists, International (QSI) is a professional consulting, training, and management systems technology firm headquartered in Houston, TX. Founded by R.T. (Bud) Weightman in 1989, QSI has a global presence and has implemented and assessed management systems in over 28 countries world-wide – with certifications ranging from ISO 9001, ISO 14001, OHSAS 18001, API Spec. Q1 / Q2, and more.
Our specialty spans quality, health and safety, and environmental (QHSE), and our products and services have been applied in engineering, manufacturing, fabrication, distribution, service, projects, and operations.
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Bud Weightman, President of QSI, is an international management systems expert involved with management and technical systems for over 40 years. As President of QSI, Bud is involved with the industry committees responsible for emerging requirements, including: revision of API specifications, leading various API Task Groups, and lead auditor for the accreditation of SEMS Audit Providers through the Center for Offshore Safety. Bud’s experience includes working with ISO 9001, ISO 14000, and OHSAS 18000 management systems, as well as industry-specific certification schemes such as API Q1 and Q2, AS9100, ASME systems, and numerous other standards.
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