PED: Five questions to ask your sub-contractors.

As the manufacturer of a pressure vessel that falls under the European Union's Pressure Equipment Directive, it’s your responsibility to make sure that your sub-contractor is carrying out the work to your specification and your purchase order.

At the end of the day, remember: the PED now states that you, the manufacturer, take FULL RESPONSIBILITY for the equipment you’re CE marking. That means if the sub-contractor’s work is sub-standard and the equipment fails, you’re at fault.

Recently we recorded a webinar with LRQA's Peter Roberts about this topic. After working with the PED for many years, he’s dealt with a lot of manufacturers and sub-contractors. Here are five questions he says you should ask before giving them the work.

1. Have you done this work before?

It seems obvious, but this question leads to other questions about standards. For example, if you’re working with a sub-contracted design engineer – is that design engineer competent? If they’re working on piping designs, have they worked in ASME B31.3 or EN 13480, the harmonised standard? Do they have evidence they’ve worked against the standards supplied for the project?

The PED requires that you use up-to-date standards, so this question is important.

2. Can I see your org chart?

Who’s responsible for what in your sub-contractor’s organisation? Make sure that the people in relation to quality have a clear connection with the various areas that they cover and that they have access to the managing director or manager of the department.

3. When can I visit your shop?

You could perform an audit on the sub-contractor around the work you want them to do. If they’re doing heat treatment, for example, you could go in and look at their processes, procedures, and the calibration of the equipment they’re using. You can also ask for the calibration logs of the equipment. Make sure all these areas are covered within their procedures.

Of course, if the sub-contractor is in another country this is tougher, but we have some solutions  for that.

4. Do you use any sub-contractors?

This is a crucial question to ask, as that work would be two steps away from yourself as the manufacturer. The sub-contractor could be subcontracting welding, NDT, bending, forming, heat treatment, pressure testing. How are these controlled and monitored?

5. What approvals do you have?

Perhaps the second most obvious question on our list, but it leads to other critical questions.

While it’s unusual for a sub-contractor in the pressure vessel manufacturing sector NOT to have an approval of some kind such as ISO 9001, ISO 3834, ASME, you should still ask. When they tell you what they’ve got and you see the certificates, take the next step – which Peter explains in this clip from the webinar: