Confusion between national standard and API related standard.

lanley liao

Involved In Discussions
#1
Hi, Everyone,
I have two NCRs questions that i don`t know to deal with them better, which is as follows:
1.For the calculation letter for JJ315/44.5-K mast, the facility adopted steel wire by the size and type (Φ72 6x84WSNS+FC-1770) according to GB/T 20067-2006 as indicated in the DWG#C0.270.02.28.06 for wire rope assembly. However, API Spec 4F Section 8.1.3 specified that “The size and type of wire shall be as specified in API 9A and by API 9B.”
2.For design Verification Test Report # CBBG-130414 is available for Traveling Blocks and/or Hook Blocks # YG110, PSL 1, SN. TB13006-13008, the facility collected the calibrating certificate #Li-20200548-0817 for loading apparatus of “tubular force-measuring instrument” (Type: LTZ-30). However, the calibration was carried out as per JJG455-2000, not ASTM E4 as per the requirement of API 8C Section 5.6, i.e. “Calibrate the loading apparatus used to simulate the working load on the test unit in accordance with ASTM E4 so as to ensure that the prescribed test load is obtained”.
Thank you so much!
 
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jmech

Trusted Information Resource
#2
For anything done to an API product spec, you need to the requirements specified in the API product spec (i.e. wire per API 9A and 9B).

The corrections could include one or both of the below:
1. Verify that whatever you did meets the product spec requirements (if it does meet it - i.e. compare the wire properties and the requirements from API 9A/9B and compare the calibration report with the requirements in ASTM E4)
2. Revise your design with something that meets the product spec requirements (i.e. revise the wire rope assembly to use wires size and type of wire as specified in API 9A/9B and calibrate the force-measuring instrument per ASTM E4 prior to performing the design verification test again.)

Why didn't you ensure that you met the requirements specified in the API product spec? You need to answer this question to figure out the root causes and corrective actions.
 

lanley liao

Involved In Discussions
#3
Hi, Jmech, Thank you so much! The customer`s contract specified the size and type of wire rope that shall be performed as our national standards agreed, and we also have told that the requirements of API 9A and API 9B to the customer. but the customer still asks us to perform it according to national standards.
 

jmech

Trusted Information Resource
#4
If you don't meet the API requirements, you are not allowed to API monogram it or claim it meets the API standard, regardless of what the customer wants. Did you monogram this product or claim that it met the API standard?
 

lanley liao

Involved In Discussions
#5
Hi, Jmech,We don`t have monogram this product or claim that it met the API standard and because we have been not received the order for two years.
 

jmech

Trusted Information Resource
#6
If you don't monogram the product and don't claim that it meets the API standard (and there is no legal/customer/other applicable requirement for it to meet the API standard), then there is no requirement for it to meet the API standard.

However, this can be confusing during audits. You need to be very clear with the auditor that you are not claiming that this meets API 4F and there is no requirement for it to meet API 4F (or other applicable API standard), so the API 4F requirements do not apply.

If you are maintaining an API 4F monogram license, the auditor will likely want to see a design package that fully meets API 4F (including steel wire per API 9A/9B). If you don't have a design package that fully meets API 4F, then it is difficult (but maybe possible) to prove that you have the demonstrated capability to meet API 4F, which is what API requires for you to maintain the monogram license.
 

lanley liao

Involved In Discussions
#7
Hi,Jmech,Thanks! The auditor has checked our design package and found it meet the API 4F requirement.
This non-conformity is the customer's request to design and produce according to national standards, which is the case for this one product, while other types of products are designed and produced according to API 4F requirements. This product is a previously produced product. Our current API 4F certificate has been suspended this year, and we do not use the API monogram and claim to comply with the API 4F certificate.
 

jmech

Trusted Information Resource
#8
This non-conformity is the customer's request to design and produce according to national standards, which is the case for this one product, while other types of products are designed and produced according to API 4F requirements.
There is no requirement for non-API 4F products to meet API 4F, so I recommend appealing this finding.
 
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