Seeking assistance regarding the subcontracting of non-destructive testing work among manufacturers?
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Can non-destructive testing work be subcontracted among manufacturers? Regarding this issue, in accordance with Article 5 of Annex 1 to GB/T 194, \"Requirements for Licensing the Manufacture of Boilers and Pressure Vessels\", the enterprise may carry out its own work related to non-destructive testing, heat treatment, and physical and chemical property testing, or it may enter into a subcontracting agreement with an enterprise that possesses the appropriate qualifications or capabilities; such subcontracting agreements must be filed with the licensing authority. ，，，”。 Currently, there is a manufacturer that has signed a subcontracting agreement with us (we are a pressure vessel manufacturing company) regarding non-destructive testing of products at the appropriate level; we are responsible for carrying out the non-destructive testing work for them. However, the technical supervision authorities have inspected that manufacturer and stated that the agreement we signed is illegal. They claim that the General Administration for Quality Supervision, Inspection and Quarantine has explicitly prohibited subcontracting between manufacturers, stating that non-destructive testing tasks must be assigned to qualified testing companies... I have checked all the guidelines issued by the administration regarding subcontracting for non-destructive testing, but I couldn’t find any provision stating such a rule. The administration only says that in similar situations, the non-destructive testing tasks can be subcontracted, provided that the capabilities of the subcontractor are evaluated, etc. I think the administration wouldn’t change its policies suddenly; initially it said that subcontracting agreements could be signed with enterprises that possess the appropriate qualifications or capabilities, but then it changed its stance to say that only testing companies can act as subcontractors. . . . . It’s just that the technical supervision department is persisting on this matter (which seems unreasonable). Everyone, please give me some advice on how to handle this situation. . . Thank you so much! !
Reply to 1# wgd100: 1. You can ask the other party to issue the relevant prohibitive provisions, or contact their superior authorities to resolve the issue. 2. Resolve it privately.
Original poster, we have encountered the same problem you’re facing; at that time we were conducting flaw detection tests for other manufacturers. The test results are not recognized by the local cooking equipment supervision authority. The result indicates that it comes down to qualification issues: your testing qualifications are appropriate within your quality system, but you do not have the qualifications to subcontract non-destructive testing tasks to others. You do not have the qualified expertise for professional flaw detection inspections.
There are requirements. . State Quality and Inspection Law [2009] No. 192: Institutions that provide non-destructive testing services for the production of special equipment within their own organizations do not need to apply separately for approval as non-destructive testing agencies; however, those that offer such services to the public must obtain approval
Thanks to the person above. . . . Found this so-called method,,,