AAR 01

Correction:
1. Internal Audit has been planned only on the outsourced supplier – NDT process.
2. Internal Audit has been performed on the outsourced supplier – NDT process. UT, MPI and LPI
inspection has been witnessed by the auditor. The ASNT level 2 inspector performed the
inspection as per the ASNT level 3 reviewed/approved procedure, calibrated equipment. The
indication was evaluated against the acceptance criteria specified in the procedure. No issues
identified.
3. A review has been conducted and ensured that all the other outsourced process has been
already audited during the internal audit and documented as per the requirements.

Root cause Analysis:

During the root cause analysis, it was identified that as per the internal audit procedure all the
outsourced processes like NDT, PWHT and machining were included and audited as a part of the internal
audit. The details were documented under the section 5.7.1.5 of API Q1 9 th edition in the internal audit
checklist but for the NDT process alone the audit was mostly based on the document review and
interview of the personnel. This is mainly because that on the day of the internal audit, there was no
NDT jobs planned or available in the schedule. On further investigation, it was noted that the internal
audit procedure was defined in a generic manner and did not include the specific control to witness the
outsourced NDT process at least one method as a demonstration of capability during process audit even
though there was no job scheduled on the day of the audit. Hence resulting in the finding.

Corrective Action:
1. The Management of Change has been initiated for the change in Quality Management System
procedure, approved by the Top Management.
2. The Document Change Request has been initiated for the change in Quality Management
System procedure, approved by the Top Management.
3. The Internal auditor procedure has been revised and the updated version include the specific
control to witness the outsourced NDT process at least one method as a demonstration of
capability during process audit, even though there was no job scheduled on the day of the audit.
4. Training has been provided to all the internal auditors on the topic of the revised procedure and
API Q1 cl. 6.2.2.1
5. Training effectiveness has been evaluated and found to be ok.
 AAR 02
Correction:
1. Inspection and Maintenance manual has been received from the supplier which include all the
inspection requirements of the non-metallic components (frequency, method, equipment, and
acceptance/ rejection criteria). The manual also includes maximum interval of replacement due
to ageing, shelf life and other details like chemical attack and evaluation of ultraviolet radiations.
2. All the other non-metallic component COC has been reviewed and ensured that the inspection
and maintenance manual covering all the above stated requirements has been received from
our supplier.

Root cause Analysis:

During the root cause analysis, it was identified that the material specification provided to our supplier
clearly mention the details of the documentation requirements and inspection manual. But the supplier
failed to provide the inspection and maintenance manual along with the COC as per the API 7K
requirements. Also, this was not identified during the incoming inspection the uncoupled hoses received
from our supplier. The Supplier Luohe Letone Hydraulics Technology Co., Ltd. is also an API 7K certified
facility with facility ID: 15796, who manufactures hoses as per API 7K requirements and hence a COC
traceable to API 7K was only given to us. On further investigation it was noted that the purchase order
did not directly specify the documentation requirement from the supplier instead reference to material
specification was only given. Also, there incoming inspection report did not have a checkpoint to verify
the documentation/ inspection and maintenance manual requirement specified in the material
specification. Eventually the supplier only provided a COC traceable to API 7K and documentation
requirements was missed during our incoming inspection as well. Hence resulting in the finding.

Corrective Action:
1. The Management of Change has been initiated for the change in Quality Management System
procedure, approved by the Top Management.
2. The Document Change Request has been initiated for the change in Quality Management
System procedure, approved by the Top Management.
3. The incoming inspection report has been revised and the recent version include the checkpoint
to verify the documentation/ inspection and maintenance manual requirement specified in the
material specification.
4. The purchase order has been revised and the updated version include the checkpoint to include
any documentation related any purchase not only related to nonmetallic components.
5. The purchasing procedure has been revised and the updated version include the control to
include the documentation required from the supplier directly on the purchase order issued to
the supplier as per the API 7K requirements.
6. Training has been provided to all the QC personnel and purchasing personnel on the topic of the
revised procedure, forms and API Q1 cl. 5.6.3
7. Training effectiveness has been evaluated and found to be ok.
 AAR 03
Correction:
1. Deformation test under pressure has been performed again as per the API 7K requirement
during the API audit and the results found to be with the requirements and no issues identified
with the product.
2. All the other design verification test requirements have been verified and ensured that it is
meeting the requirement of the API 7k sixth edition. No issues identified.

Root cause Analysis:

During the root cause analysis, it was identified that the Deformation test under pressure was carried
out only to the working pressure and not to the test pressure. This is because the requirements from the
API 7K 6th edition was generically specified in our design verification test procedure and not integrated
properly. The design verification test procedure did specify that the Deformation test under pressure
shall be carried to test pressure as per the Table 10 of the API spec 7K 6 th edition but did not include the
Table 10 details in the procedure and only the reference to Table 10 was given in the procedure. Hence
the technician tested to wrong pressure. On further investigation, it was noted that the design
verification report in which the test results are recorded was not reviewed prior to the approval and the
design verification test procedure did not specify the review authority prior to the approval of the report
to ensure that the results meet and confirm to API 7K requirements. Hence resulting in the finding.

Corrective Action:
1. The Management of Change has been initiated for the change in Quality Management System
procedure, approved by the Top Management.
2. The Document Change Request has been initiated for the change in Quality Management
System procedure, approved by the Top Management.
3. The design verification procedure has been revised and the Table 10 requirements has been
directly specified in the procedure rather than just the reference to the Table from the API
Specification.
4. The design verification report format has been revised and include the control to review
authority signature prior to the approval of the test results.
5. Training has been provided to all the MR and design personnel on the topic of the revised
procedure, forms, and API Q1 cl. 5.4.6.
6. Training effectiveness has been evaluated and found to be ok.
 AAR 05
Correction:
1. Demonstration UT process qualification records has been received from the supplier. The
records have been verified and ensured that it meets and qualifies the UT procedure. No issues
identified.
2. All the UT inspection carried out until now has been listed and the inspection reports has been
verified. It was ensured that the results meet the acceptance criteria specified in the procedure.
No issues identified.
3. All the other methods Demonstration process qualification records are already available, and
controls are in place.

Root cause Analysis:

During the root cause analysis, it was identified that, during procedure qualification the external
provider’s UT procedure; UT process has been verified as evidence to demonstrate the process
qualification. During this verification of the procedure and process the personnel who performed this
activity has verified the validation record from the external provider but missed out to retrieve it back as
evidence of conformity. On further analysis, it has been noted that the requirement for collecting the
NDE demonstration validation report from the external provider is missed out in the Validation of
special process procedure since it was defined in a generic manner and there was no checklist or form
available to record, monitor the validation documents from the supplier. Hence resulting in the finding.

Corrective Action:
1. The Management of Change has been initiated for the change in Quality Management System
procedure, approved by the Top Management.
2. The Document Change Request has been initiated for the change in Quality Management
System procedure, approved by the Top Management.
3. Special process validation procedure has been revised to include the requirement for collecting
the NDE demonstration validation report from the external provider.
4. A new checklist has been developed to verify specifically the list of documents/requirement to
be monitored, collected, verified, and maintained from the external NDE supplier.
5. Training has been provided to all the Quality personnel on the topic of the revised procedure,
forms, and API Q1 cl. 5.7.1.5.
6. Training effectiveness has been evaluated and found to be ok.
 AAR 06
Correction:
1. The PQR has been re-done and the revised PQR qualification results has been documented. The
test piece has been welded per the new PQR and sent again to the third-party laboratory for
mechanical testing as per the requirements and it was ensured that the impact test was carried
out at -20 Deg C. The report has been verified by the Qualified welding inspector and accepted.
2. All the other PQR and Lab test reports has been verified and ensured that the impact test has
been carried out at -20 Deg C. This was only the isolated case and results meet the requirement
and no issues identified.
3. There was no customer order and hence no product delivered to customer. The product
available was only the prototype. No monogram has been marked.

Root cause Analysis:

During the root cause analysis, it was identified that the laboratory has been contacted and confirmed
that the impact test was performed only at the room temperature. It was understood that when the
purchasing information was communicated to the laboratory the material specification, or any
acceptance criteria (PQR) was not referenced and attached with the purchase order. Hence the
laboratory performed the test at room temperature. The purchase order format did not have any
provision to reference attached documents/ acceptance criteria related to the purchase. The purchase
procedure was defined in a generic manner did not include the control to refer the attachments to
purchase order. On further investigation, it was also noted that PQR was based on ASME, as per ASME
Sec. VIII Div.1: UG-20(f) impact test was exempted and did not include the API 7K material impact testing
requirements on the PQR. The temperature range needed to be impact tested was not included in the
PQR. Hence during the incoming review of the mechanical testing results for the PQR, this was not
captured. Hence resulting in the finding.

Corrective Action:
1. The Management of Change has been initiated for the change in Quality Management System
procedure, approved by the Top Management.
2. The Document Change Request has been initiated for the change in Quality Management
System procedure, approved by the Top Management.
3. Purchasing procedure has been revised and the control to refer the attachments to purchase
order has been included.
4. Purchase order form has been revised and the checkpoint to refer any attachments to purchase
order has been given.
5. The PQR Rev. 01 include all the impact test requirements as per the base metal in the material
specification.
6. Training has been provided to all the Quality personnel on the topic of the revised procedure,
forms, welder and API Q1 cl. 5.7.1.5.
7. Training effectiveness has been evaluated and found to be ok.