I will be fully upfront for those who wish to challenge me on this topic. YES, ASME B31.3 and 31.5 explicitly state that certain records that are required by the standard do NOT have to be “retained”. However, most people who challenge me on this topic fail to see that ittybitty two-letter word “if” in the code and in the world of Process Safety, these records most certainly have to be retained. We have to remember that ASME B31(s) were NOT written to “satisfy OSHA or EPA,” and I would guess that the majority of hazardous-material piping built in the USA is NOT associated with a PSM/RMP-covered process, yet ASME B31 still applies to said piping.
So let’s look at the language of B31.3 as it relates to “records retention,” and then I’ll explain why PSM/RMP require the very same records… (emphasis by me)
345.2.7 Test Records.
Records shall be made of each piping system during the testing, including:
(a) date of test
(b) identification of piping system tested
(c) test fluid
(d) test pressure
(e) certification of results by examiner
These records need not be retained after completion of the test IF a certification by the Inspector that the piping has satisfactorily passed pressure testing as required by this Code is retained.
First, we have to look at the ittybitty two-letter word “if”.
So there is a record retention requirement for “test records”; they just may NOT include items (a)-(e), as long as the facility can provide a “certification by the Inspector that the piping has satisfactorily passed pressure testing as required by this Code is retained.“
We have to remember the DIFFERENTATION between the “examiner” and the “inspector” in relation to the ASME B31 specifics…
The “inspector” serves as the FINAL AUTHORITY on Code compliance and represents the facility that will ultimately own and operate the piping.
- The inspector is employed by the Owner or an independent third-party engineering/inspection agency acting specifically on the Owner’s behalf. Crucially, the Inspector can NOT be an employee of the manufacturer, fabricator, or erector (unless the Owner is also the manufacturer and doing their own construction).
- The inspector verifies that ALL required examinations and testing have been completed by the Examiner. (See my other articles where I talk about this role. The Inspector reviews the NDE records, material test reports (MTRs), and welder qualifications, and typically witnesses the final hydrostatic or pneumatic leak tests. They do NOT typically perform the NDE themselves; rather, they audit the process to ensure Code compliance and hold the ultimate authority to accept or reject the work.
- ASME B31.3 Section 340.4 explicitly mandates minimum qualification requirements for the Inspector (e.g., specific years of experience in the design, fabrication, or inspection of industrial pressure piping). In contrast, Examiner qualifications are generally governed by the employer’s written quality program (often referencing ASNT SNT-TC-1A).
Summary Comparison
| Feature | Examiner | Owner’s Inspector |
| Primary Function | Quality Control (QC) | Quality Assurance (QA) |
| Employed By | Manufacturer, Fabricator, or Erector | The Owner (or Owner’s designated agent) |
| Code Section | Section 341 | Section 340 |
| Primary Action | Performs and documents the NDE and visual examinations. | Verifies records, audits compliance, and witnesses tests. |
| Authority | Determines if a specific weld/component passes or fails the technical acceptance criteria. | Has the ultimate authority to accept the entire piping installation on the Owner’s behalf. |
Remember, someone is signing off on the PSSR line item that says:
1910.119(i)(2)(i) Construction and equipment is in accordance with design specifications;
What records would you want to see in order to sign off on this line item? Would a single written certification from the “inspector” satisfy your curiosity about the integrity of the piping construction? How well do you know the “inspector,” and did they meet all the requirements of being an “inspector”?
I can tell you without hesitation that if/when a pipe fails and leads to an LOPC event, any investigator worth their salt will begin at that failure point and ask for all the records related to the design, installation, and verification that the pipe was built to the proper RAGAGEP. Getting a “certification” from an inspector, who no one knows or remembers, hampers our ability to assess the Quality Assurance program under which the piping was built. Having those items (a)-(e) above, sure does allow us to “peel that onion” layer by layer, so we can identify those latent organizational failures that allowed the event to initiate.