Can a PSM/RMP facility be “compliant” with its piping RAGAGEPs (B31 series) if the facility does not have a piping “inspector”? When many hear the phrase “piping inspector,” they immediately think of the Mechanical Integrity element; however, the ASME B31 series also uses the phrase, and it refers to the installation of piping per the B31 series. So let’s discuss the need and role for the “inspector”.
The “inspector” works on behalf of the piping owner. This person is different from the examiner. These two (2) titles (Inspector and Examiner) are defined in the standard.
The owner’s Inspector is responsible to the owner for ensuring that the Code’s requirements for inspection, examination, and testing are met.
The Inspector is the owner’s representative and oversees the examination and testing work performed by the contractor.
The Inspector, therefore, cannot be an employee of the contractor, but could be a third party retained by the owner.
The Inspector is a representative of the owner, not an independent third party, such as an authorized inspector. The required qualifications of the Inspector are provided in Chapter V of the ASME Code.
Note that the Inspector is not required to perform examinations or check the design.
Under the ASME B31 codes—most notably ASME B31.3 (Process Piping)—this role is officially designated as the Owner’s Inspector. They serve as the facility owner’s final quality assurance authority, responsible for verifying that a new, modified, or repaired piping system is safe, structurally sound, and fully compliant with both Code requirements and the engineering design before it enters service.
According to ASME B31.3 Chapter VI (Inspection, Examination, and Testing), the Owner’s Inspector does not perform the actual physical testing. Instead, their role is oversight and verification:
- Confirming that all required non-destructive examinations (NDE), heat treatments, and leak tests (hydrostatic or pneumatic) have been successfully completed. ASME Digital Collection
- Reviewing and approving suitable records of materials, examinations, and tests to ensure they match the design parameters.
- Inspecting the piping to the extent necessary to be satisfied that it conforms to all Code requirements prior to initial operation. ASME Digital Collection
ASME strictly separates quality control from quality assurance to ensure objective oversight:
- The Examiner performs the actual physical quality-control work (e.g., visual inspections, radiography, dye penetrant testing, and ultrasonic testing). The Examiner is employed by the piping Fabricator or Erector.
- The Owner’s Inspector performs the quality assurance work. They oversee the Examiner’s process and verify the results strictly on behalf of the Owner.
Given the liability and technical demands of the role, ASME B31.3 (Para. 340.4) requires the Owner’s Inspector to meet specific experience benchmarks:
- Standard Qualification: At least 10 years of experience in the design, fabrication, or examination of industrial pressure piping. (Each 20% of satisfactorily completed work toward an ABET-accredited engineering degree counts as 1 year of experience, up to a maximum of 5 years).
- API 570 Alternative: Alternatively, the individual can be an Authorized Piping Inspector as defined in API 570 (Piping Inspection Code), provided they have at least 5 years of experience in the design, fabrication, or examination of industrial pressure piping.
- The Owner’s Inspector must be a direct employee of the Owner, or an employee of an independent engineering, scientific, or inspection company acting explicitly as the Owner’s agent.
To prevent conflicts of interest, the Code dictates that the Inspector cannot represent or be an employee of the piping manufacturer, fabricator, erector, or EPC (Engineering, Procurement, and Construction) contractor. If an EPC contractor is building the piping system, their internal QA/QC personnel cannot legally act as the Owner’s Inspector; the facility owner must designate their own independent representative to accept the system.