API Spec Q1 9th Edition # Re-audit - Disputing with API AARs

#1
Hi All,

Recently we faced API re-audit and we got total of 6 AARs. One AAR is as follow,

# AAR Description #

(1) Documents are not approved as mentioned in the procedure
(2) Latest version of WPS is not used

# Objective Evidence #

(1) Quality manual section B-3 Rev.04 dated 30th December 2019 point # 5 states – Each procedure are reviewed and approved for suitability and adequacy prior to issue and use – this is not evident.
(2) Following product was under production (welding) and it was observed that WPS-029 Rev.03 dated 8th July 2013 was used as an applicable WPS. W.O. # SO2016002-COO4, 4-1/16” Choke body, API spec. 6A 21st edition sec 7.3.4.1 for PSL 1, PSL 2, PSL 3 and PSL 4 the following shall apply.
- Welding shall be performed in accordance with WPS, written and qualified in accordance with ASME BPVC, Section IX or ISO 15609. The WPS shall be qualified by use of welding procedure test as required in ASME BPVC, Section IX or ISO 15614-1. The WPS shall describe all the essential, nonessential and supplementary essential variables.
As per WPS-029 Rev.03 dated 8th July 2013 the facility qualified the WPS based on the following standards:
- ASME Sex. IX : 2010
- API Spec. 6A 20th Edition
- NACE MR-0175 2nd Edition
However the latest edition of the above standards are as follows and the facility did not ensure the existing WPS meets the latest codes / standards:
- ASME Sex. IX : 2010
- API Spec. 6A 21st Edition
- NACE MR-0175 3rd Edition
Upon further interview the facility bought WPS-029, Rev.04 dated 18th March 2019 which has the same “Applicable Standards”.
- ASME Sex. IX : 2010
- API Spec. 6A 20th Edition
- NACE MR-0175 2009:2010

# Our Submitted Reply #

(1) We have shown the proof to auditor that all procedures and documents are approved by concern authorities.
We also requested him to be specific and let us know which procedure is not approved prior to release.
(2) Explained and shown proof that we are doing welding as per customer approved WPS 029, rev. 03 dated 8th July 2013. This order is a 3 year rate contract with client. WPS-29, rev. 03 was prepared in line with API specification 6A, 20th edition. Subject order was in manufacturing prior to API 6A, 21st edition implementation. We produced gap analysis of WPS 29, rev. 03 with respect to API 6A-21st edition. Supporting evidences like customer approved WPS and gap analysis attached for this point.

# API response #

Element 1 - please provide evidence specific to this challenge. How does your procedure ensure that "documents required by the quality management system, including revisions, translations, and updates: a) are reviewed and approved for adequacy prior to issue and use"? What is this process? How do you maintain evidence of this review and approval?

Element 2 - Your response is unclear to me. It appears the auditor has raised this element against a failure to demonstrate a WPS that meets the latest requirements of API Spec 6A 21st Edition. Your response states that the welding was done per customer requirements and API Spec 6A, 20th Edition. Were your gap analysis documents provided to the auditor during the audit? Have you updated your WPS to 6A, 21st Edition requirements?

I am confused now, what should I reply?

My draft reply for Element 2 is, "It is the case of latest V/s relevant documents. As mentioned in our response that, “This order is a 3 year rate contract with client. WPS-029 with API 6A 20th Edition was approved by customer on 11th June 2017.” Welding was done as per customer requirement and API 6A 20th Edition. Gap analysis for WPS-029 Rev.03 with API-6A 21st Edition, ASME Sex-IX-2019 and NACE MR0175:2015 was presented to the auditor. WPS containing API-6A 21st Edition requirements was updated on 18th June 2019."
 

roneljdsilva

Involved In Discussions
#2
Greeting from one management rep to the next!

Here is my take on the AAR raised and comments on possible means of closing. Hope it helps :)

From API Auditor's comments, the NC can be broken down into two parts (which the auditor clubbed into one as it falls under the same clause of API Q1).

Firstly, it seems like there was no clear evidence of approval on the WPS, the most convenient way to demonstrate evidence of review and approval is through signatures on your documents (clearly traceable to the person signing, designation and date). This AAR is linked to API Q1 9th Edition Clause 4.4.3a

Additionally, the comment as to why the document was stating compliance to older editions of ASME/API standards is giving the auditor a chance to raise a finding against API Q1 9th Edition Clause 4.4.4

Now that we have assessed the clauses against which the two nonconformities have been raised, let's move on to your initial response.

In the first part of this response, you are clearly stating an error in the judgment of the API auditor in raising this finding. Even if this case is true, I suggest you write a response explaining how the review and approval process was actually done in this case and how the requirement had been fulfilled. This information is missing in the response, rather it is stated that it was explained to the auditor at the time and you needed further information which is insufficient. Hence further response is required.

In the second part of this response, you are stating that a three-year contract was in place against the product which was signed when API 6A 20th Edition was in effect. This response will not work in justifying the use of documents written in compliance to 20th Edition for products being manufactured in periods were subsequent editions are in effect (refer API Q1 9th Edition Annex A.6). This is the reason the effective period of implementation of API 6A 21st Edition was one year from the date of publishing (November 2018 - November 2019). I do not see an appropriate response in justifying how the requirement had been met.

Please understand that a gap assessment to show there has been no change in essential variables for welding between the ASME Sec IX 2010 Edition and ASME Sec IX 2019 Edition works great as a correction but it does not address the root cause.

API reviewer's comments are straight-forward! Give more explanation to both the nonconformities.

My suggestion for your next response

In the first response, as you have already challenged the auditor's statement, you need to clearly explain how the review and approval process works in your company and was this method of review and approval stated in your procedure for control of documents? I would attach my procedure and the WPS in question to show that it followed the procedure requirements. The explanation must be detailed (forget about what the happened during the audit or what the auditor said, it is time to convince the reviewer!)

For the second part of the nonconformity, I would want to explain to the reviewer oh what my process is when newer editions of standards come into effect and how I integrate them into my QMS. Is your procedure addressing this? Remember this needs to be a proactive approach and not reactive. When a new edition of any relevant standard/specification is out that is required to be adhered to, are you carrying out a review of the new edition to see what documents in your QMS are effected? Are records of this review are maintained? If you had records of the review and showed them to the auditor at the time of the audit to provide evidence that the WPS was complying to the latest edition I believe this nonconformity wouldn't be raised and if this process is not clearly specified in your procedure for control of documents, I suggest it's time to make a revision. This revised procedure of how you incorporate the latest editions of relevant standards into your QMS would-be your corrective action.

Hoping this helps! Happy to help with any more clarifications you may have.

Best Regards,

Ronel Dsilva
 
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