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."
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."