May an N-type Certificate holder subcontract services, for example tensile testing of material and weld test coupons, to another N-Type Certificate holder without survey and audit of the subcontractor, provided the purchasing documents require the subcontractor to perform the services under his QA program, and that certification of the activities is reviewed and accepted by the subcontracting organisation?

ASME Code Section III permits an N-Type Certificate Holder to purchase Source Material from Organisations holding an ASME QSC or N-Type Certificate with Supply of Material in the scope. Survey and audit of the Material Organisation is not required in this case.

Testing of Material is included in the scope of activities certified by the Material Organisation.

Therefore it would be consistent when an N-type Certificate holder (A) subcontracts testing of material or weld test coupons to another N-type Certificate holder (B) without surveying and auditing the company B as “supplier of subcontracted services”.
NCA-3125 (b) permits subcontracting of services to Certificate Holders, but does not address surveys or audits.

Under NCA-3125 (c ) the N-type Certificate holder (A) shall describe in his QA Manual the controls for subcontracting to B and accepting Certification of the test results.

Does anybody have an opinion on this problem?
DK

In my opinion Yes. However, this issue was discussed at a Survey in january and the TL did not agree, but admitted it was based upon his common sense, not Code requirement.
mauro

Random thoughts:
1) The ASME should not have a problem with it when they do a Survey/Audit.
2) Auditors will have a a question on how the N-Type or MO/QSC service supplier was qualified.
3) I have yet to see an ASME Certificate with a scope indicating testing.