The 86th General Meeting Speaker Presentation
"Rules for Commissioned Inspectors"
The following presentation was delivered at the 86th General Meeting Monday General Session, May 8, 2017. It has been edited for content and phrasing.
INTRODUCTION: Vincent Scarcella possesses an AI commission with a B endorsement and is risk control director for CNA where he has worked for the past 15 years. He is a member of the National Board Committee on Qualifications for Inspection, and is responsible for CNA internal audits to ensure compliance with NB-369, Accreditation of Authorized Inspection Agencies. In his role at CNA, he is responsible for risk control in the northeast and mid-Atlantic zones, including budget responsibilities, a staff of 24, and he manages compliance for 14,000 jurisdictional inspections. Mr. Scarcella served in the United States Navy for seven years where he rose to become a first class petty officer and work center supervisor in boiler engineering. He received a Bachelor's of Science in Business at SUNY Empire State College.
Mr. Scarcella's slide presentation can be accessed here.
MR. SCARCELLA: I have to start by thanking the members of the Qualifications Committee not only for their input on the presentation, but also for their patience with me. This is the first time I’ve worked on a National Board committee. I would like to single out Mr. Allison. He really helped me become a more effective member of the committee and spent a lot of extra time with me at the beginning. And the Quals Committee, I think they are responsible for like a dozen different codes. There is a lot to do. It's a great group of people. I have a lot of respect for them.
How many people have read the new edition of RCI-1? If you don't have it, it's available for free online. And also there is a great online course that recently came out, I think within the last two months. They are both free, so everybody should have it. I'm just going to go section by section. And I'm not going to go over the whole thing; I'm just hitting the highlights and the portions of the code that the committee wanted everybody to review.
If you look at the foreword, it describes our whole process. We meet a couple times a year. We put together the changes that we want. There is a lot of input all around and a lot of support from the National Board staff members. From all that interaction, we produce a document for the Board of Trustees, and they vote up or down. So that's how we ended up with what we have for RCI-1 through 2017, which will become effective July 1.
How many people have had to fill out one of the applications? If you looked through Table 1, you'd notice that now a Bachelor's degree gets you three credits of the five you need. And the rest can come from experience and in-classroom training. You have Parts 1 and 2 – commissions, qualifications, examinations. Part 3 is the inservice responsibilities – for inspectors and supervisors. Part 4, you have the AI portion, new construction. And new for 2017 is the repair section which was pulled out of Part 3. Diary section. Code of ethics probably would be the most important part. Complaint and due process. And missing from the bottom is the glossary.
So we will go right into Parts 1 and 2. So like I said, there were some changes in Table 1. You have the changes for continuing education going from 24 months to 12 months. You have to do one class a year instead of two classes every two years, and I think that keeps you more in the know and keeps the training fresh. And then for any endorsement you have, you have to do the continuing education. So if you have three endorsements, you will be doing three classes. Applications for reinstatement, over twelve months – you are going to have to go into the continuing education. If you have been out for 24 months, retesting; right? Reapplication, go through the whole process over again. And now, of course, you are going to have the new R endorsement, the application process for the R endorsement in 1 and 2 – oh, 1.4. We had a lot of discussion about the eighty hours for the AI. And I have to be honest with you, I don't know who can learn this job in eighty hours. It takes a lot more than that. And eighty hours in a shop isn't going to get you there, but that's the bare minimum. And we have a responsibility to take it as far as it has to go.
Part 3 had the most changes. The two main changes were to the supervisor's responsibilities, and then pulling the R portion out of the inservice section. Some of these things we discussed here pretty thoroughly, and I think the committee just wanted to tighten up on some of the information on the inservice supervisor. This is more in line with the supervisor on the shop side, so there is more of a parallel now. It's just as important, so it should have similar requirements. It's stated now in the inservice supervisor's section that they have to be commissioned. And it's very clear about maintaining the competency of your staff, making sure that you are assigning work to your staff that is equal to their skills.
All of those things would seem to be common sense, but they are stated now. Maintaining work records, document nonconformance, all of these things we can all agree are pretty simple. Audit and documentation of performance, which you would think if you are an NB-369 world, you would know that. This extends it beyond that. It's consistent with 369. And ensure proper safety training. We went back and forth with that a lot, and I would say that I'm not going to send somebody out to do any work where it would jeopardize them or others. So we always teach training. We do lock-out tag-out, we do confined space entry.
My staff of 70 and I went the extra step a couple years ago. Every single one of our inspectors carries a single gas carbon monoxide meter, and we found them alarming in several situations. So we have had 28 instances where they've actually alarmed. It was to protect my staff, but they walk into a lot of boiler rooms, so a byproduct of that is the safety of the operators. Something to consider.
So all requirements for repairs and alterations have been removed and put into Part 5. That entire section will look familiar to you if you were familiar with the requirements in Part 3. You will notice that if you got your ticket today for inservice, it would have the R endorsement, and in the future you will have to maintain that. And as always, anything you are doing has to meet the requirements of the jurisdiction. That's also stated in the foreword. So Part 4 remains largely the same, consistent with QAI-1.
Joe Pang has been at every single one of our meetings so far that I have been to. So one of the things he felt strongly about adding to the presentation is that if a supervisor is going into a shop, make sure you sign in, and the inspector and the supervisor need to be at the joint reviews.
Part 5, like I said, it's pretty much the same, it's cut-and-pasted into this from Part 3, it's its own section. Same requirements for the supervisor and the inspector to be at the audits. If you have met the audit requirements for Part 4, it counts for Part 5. It doesn't mean you have to do another audit. So that continues. And then the diary section, next, remains mostly the same. I think there were some changes in regard to Part 5 coming on. This, I think you may see more scrutiny looking at – during audits and looking at diaries in the future, which is a good thing. We want to establish that habit of really doing a good job on the diaries. In my company we don't typically do shop work, but we will inspect a client's large equipment that has been purchased at the factory, and I encourage my staff to look at those diaries and talk to the AI. I think that's a critical component of the whole process. Diaries must be made available for reviews and investigations.
And probably the most important part -- to me, of RCI-1 is Part 7, and we did tighten up some of the language for the conflict of interest. There were some inquiries, and we responded to it. You are just trying to maintain that line, right? We don't want your inspector to be involved in the manufacturing process and remove that integrity from the process. And I have given this presentation to inspectors a couple of times already, and if you look at a good faith clause in a contract, it's pretty substantial. But you are acting in good faith if you are acting without malice. You are focused on what the job at hand is. And so that's all this is, act without malice, just do your job. I have to explain public perception, and that's easy now because you can assume you are being videotaped at about any time right now. So that's how I explain it to staff. Maintaining that independence, integrity. Without it our jobs really aren't much of a function.
Due process and the glossary remain mostly the same. Neglect and falsification is specifically mentioned. Most of the cases of neglect and falsification started with indifference, and that's the thing that we really have to combat with our staffs. We have to make sure they are staying focused and staying on the right track. Glossary changes reflect the changes in the endorsements, and they added in the description of the inservice inspector supervisor requirement for the commission.
So in closing, we already know these responsibilities. We are responsible to a lot; right? The community, the occupants of a building, you guys all know that, but how many times do we remind our staff? I think it's important that we do that with more regularity. And we know the results when we do our jobs right.
MR. TROUTT: I'm looking at RCI-1 and I see a couple of things that are kind of concerning. I noticed that there is no endorsement for an inservice supervisor. Basically the RCI-1 is just saying that the inservice supervisor shall have the same credentials as the inspector he supervises. What's the difference? For that matter, when he goes to do the R stamp for repairs for that inspector or the R endorsement, it's pretty much the same thing. So where is the difference between the inspector and the supervisor, and are we going to do anything with that?
MR. SCARCELLA: It's a very good question. The qualifications haven't been addressed yet. We talked a lot about it, and you may have heard me soliciting feedback from members. I think it's important that we do put something in there. You can't have somebody who is fresh out of college in the supervisor's position.
MR. TROUTT: Agreed.
MR. SCARCELLA: And you can't have somebody that's never inspected a utility supervising people that are in utilities. He's just not going to be able to properly support the staff. So, yeah, we should probably put some language in there, and I expect that in 2019 you are going to see that, and we probably are already working on something along those lines.
MR. TROUTT: So is it the supervisor's requirement that their credentials say they’re a supervisor? What do they have to do to get this done?
MR. SCARCELLA: It's determined by the AIA right now.
MR. TROUTT: So either the AIA or the jurisdiction?
MR. SCARCELLA: Well, the jurisdiction runs by its own rules. This document applies to the jurisdiction only if they want it to. They make their own rules.
MR. TROUTT: I don't know that I necessarily agree with that. And the reason I say that is because the jurisdictions, if we are saying we are following NBIC, in Texas I have actually changed up our rules to coincide with the authorized inspector commission and ASME, or the inservice commission. So I'm actually separating my commissions the same way that the National Board did. So I'm following this. But if we refer to this document as only for the AIAs, what about the jurisdiction?
MR. SCARCELLA: I applaud what you are doing, don't get me wrong. But not every jurisdiction is going to have the resources to do what you have done. And hopefully everybody gets the chance to evolve like that.
MR. POWERS: Why were the requirements for the R endorsement created?
MR. SCARCELLA: I can't speak for the whole committee, but you will find probably most of them are in agreement with this, and if they are not, Phil will talk up. So I don't like the fact that as an inservice inspector I can just go around two or three years, and then suddenly I'm going to be signing an R-1 form just doing nothing but external and internal inspections. It's just a different function. We have rules wrapped around how we handle it. Under our program, if I'm going to sign an R-1 form and I'm not the AI for that shop, it has to start with an audit. I have to go in and start looking at the QC manual, then I have to look at the material controls and see how your welders are certified. By the time you get through with that, it's going to cost three times more to have me sign the R-1 form. So we haven't signed an R-1 form in years. We are already aware RCI-1 to 2017 is now, so that's why I think that's probably consistent with what our thought process was.
Thank you very much.