Reinstatement of Revoked Certification for NDT per NAS 410 8.4

#1
Good morning. Evaluating a finding we rec'd regarding a revoked certification for termination of employment, where the person was later re-hired and re-certified.

Specifically in light of 8.4, which states "Certifications which have expired or been revoked may only be re-instated by specific and practical examination equivalent to initial certification. For the definitions of "General, Specific and Practical" I reference 7.1.2 through 7.1.4. This tells me that in this event the General examination described in 7.1.2 is not required to be repeated, as long as adequate records are available of the original General examination.

Finding specifically notes that "Inspector was employed by the supplier from x to y so the current certification is an initial certification but a General examination was not included. Only a Specific and Practical was given as if this was a re-certification."

I'm new to the industry, so not sure if I'm missing some key directive or rule of practice, as I'm not sure, by my reading, why this would even be a minor much less a major.

Thanks in advance for your feedback!
 
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#2
It’s difficult to comment without having the full facts and timelines, but on face value you may have a point and it might be worth ‘appealing’ the NCR. However, NAS 410 requires that you have your own Written Practice (WP)– what does your WP require for these circumstances? Do you have your own Company rules beyond the NAS 410 requirement? In addition, do your Customers have any specific requirements for Certification of personnel that this does not meet? Are all previous Certification records available for scrutiny?
 
#3
Thanks for the reply. It's re-assuring, as that's the chain of logic I used in discussing with my responsible UT Tech, specifically what our procedures called for and whether we had retained the records from the person's first tenure with the Company, which were in line but not exceeding the NAS 410 requirements to our understanding as detailed above.

The auditor did not raise any additional Customer-specific requirements, and our previous discussions indicated that we met the requirements of one specific Prime who engages us regularly, but that's where I plan to look next to verify what kind of ground we're standing on before escalating the issue.
 
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