13.2 CP-189 Mandatory Requirements
Key Takeaways
- CP-189 frames training, experience, examination, vision, and recertification as mandatory program elements; employers shall not reduce the standard’s minimums once CP-189 is invoked.
- Qualification examinations shall be administered or approved by a NDT Level III in the applicable method, with documented records of examinations and results.
- An outside agency Level III may be used only if the individual meets qualification requirements and the arrangement (including responsibilities) is documented in the written practice.
- Recertification intervals are limited (commonly not more than five years); under CP-189, re-examination is required at recertification—experience documentation alone is not enough.
- Lapsed certifications must be reinstated through the qualification process appropriate to the lapse; automatic reissue without that process fails the standard.
13.2 CP-189 Mandatory Requirements
Quick Answer: Under CP-189, once the standard is invoked, the employer’s program shall implement mandatory minimums for training, experience, examination, vision, and recertification. Examinations shall be administered or approved by a NDT Level III with documented records. Outside agency Level III support is allowed only when the person is qualified and the arrangement is written into the practice. Recertification is capped (commonly not more than five years) and, critically for the Basic exam, re-examination is required—experience alone is not sufficient. Do not invent exact hour tables from memory; own the shall-vs-should character and the Level III control rules.
Section 13.1 established that CP-189 is a standard. This section is about what that means operationally. Basic exam writers rarely need you to reproduce every cell of a training-hour appendix under exam stress. They need you to recognize which knobs an employer may not turn down, who owns exam integrity, and how recertification differs from soft “continuing satisfactory performance” stories that may appear under more flexible recommended practices.
The Controlling Document Still Exists—and Is Stricter in Spirit
CP-189 does not eliminate the employer’s written program document. Employers still must establish and maintain a written practice (or equivalent certification procedure) that controls:
- Methods and techniques covered
- Levels of qualification and any limited certifications
- Training and experience requirements (meeting or exceeding CP-189 minimums)
- Examination administration, grading, retest rules, and record retention
- Vision examination requirements and intervals
- Recertification intervals and methods
- Responsibilities of Level III personnel and any outside agency arrangements
- Suspension, revocation, and reinstatement after lapse
Exam trap: “Because CP-189 is a standard, no written practice is needed.” False. The standard is the external rulebook; the written practice is the local implementation. Auditors and customers read both.
Training Requirements: Mandatory Minimum Character
Think of training under CP-189 as required preparation against a defined body of knowledge for each method and level—not optional enrichment.
Exam-useful framing:
- Training shall meet or exceed the standard’s minimums for the method and level (exact hours live in the published edition’s tables—verify in the document, do not invent).
- Training content is expected to cover the knowledge needed for the examinations and the work; employers commonly align course outlines with CP-105 topical outlines (the training companion standard covered in Chapter 14).
- The employer’s written practice must describe how training is delivered, documented, and credited (classroom, structured remote/online, laboratory, etc., as the program allows).
- Customers or codes may demand more training than CP-189’s floor; the standard’s force is that you do not go below its floor when CP-189 governs.
Contrast trap with SNT-TC-1A: under a recommended practice, employers discuss recommended minimums and limited tailoring concepts in the Written Practice. Under CP-189, exam language focuses on mandatory minimums that cannot be reduced by employer preference once the standard applies.
Experience Requirements: Documented Performance, Non-Reducible Floor
Experience under CP-189 is still documented time performing NDT at the relevant method/level—not “years employed in the building.” Basic items target:
- Experience must be documented and consistent with the method and level claimed
- Education pathways may interact with experience requirements in the published tables (again: look up the edition; do not invent reduction formulas on the exam)
- Limited certification may reduce scope (and matching requirements) only as the standard and written practice allow for a restricted technique/application set
- Experience does not substitute for required examinations
Level III thinking: if production wants to “grandfather” a long-time helper into Level II without documented method experience and exams, a CP-189 program has fewer soft exits than a loosely tailored SNT-TC-1A story. Your job is to protect the floor.
Examinations: Level III Administration/Approval and Records
This is one of the highest-yield CP-189 themes on the Basic exam.
Core rule to memorize as a concept (not a hour cell):
Qualification examinations for NDT personnel shall be administered or approved by a NDT Level III in the applicable method, with documented records of the examinations and results.
What that implies in practice and on scenario items:
| Element | CP-189-oriented expectation |
|---|---|
| Who controls exams | Level III in the method administers or approves |
| What is recorded | Exam administration, scores/results, and related qualification records |
| General / specific / practical | Level I/II paths still use a multi-part exam structure appropriate to method and level (parallel to the SNT framework you already know) |
| Integrity | Controlled specimens, controlled question banks, no undocumented “oral pass” overrides |
| Who cannot casually replace Level III control | A Level II in the same method is not a free substitute for Level III exam authority under CP-189 |
Open-book-only on procedures, verbal-only undocumented testing, or “everyone uses the same three easy plates forever” all fail the spirit and documentation of a mandatory examination system—even when the candidate is skilled on the floor.
Vision Requirements
CP-189 programs include vision examinations as a qualification element. For Basic recall, keep the same practical model you used under SNT-TC-1A without inventing new unpublished thresholds:
- Near-vision acuity is required (commonly discussed as Jaeger 2 or equivalent at not less than about 12 inches—confirm the current edition wording for exact criteria)
- Color vision / contrast differentiation is required when the method needs it (e.g., color-contrast penetrants, color-coded systems)
- Intervals and administration details live in the written practice consistent with the standard
- Failed vision checks block certification/recertification until corrected/retested per program rules
Vision is not a trivia afterthought: a Level III who ignores expired vision records has a program integrity failure under a shall-based standard.
Level III Requirements and Outside Agencies
Internal Level III role
Under CP-189, Level III personnel are the technical backbone of:
- Procedure development and approval
- Training program design/approval appropriate to the methods
- Examination development, administration, or approval
- Technical supervision of the qualification system
- Supporting audits and customer inquiries about personnel qualification
Outside agency Level III
Employers may use an outside agency Level III when:
- The individual meets the qualification requirements, and
- The arrangement—including responsibilities—is documented in the written practice.
Exam traps to reject:
- “Outside Level III is allowed with no written practice provisions”
- “Outside Level III is allowed only for radiography”
- “Outside Level III is allowed only when the employer has zero NDT staff”
- “Hiring an outside Level III means the outside agency becomes the certifying authority instead of the employer”
The employer remains responsible for the certification program; the outside Level III is a documented service relationship, not a silent handoff of legal/program ownership.
Recertification and Lapse
Maximum interval
CP-189 limits how long a certification may run before recertification. The Basic-aligned fact from current program teaching and practice items: recertification intervals shall not exceed five years (employers may set shorter intervals in the written practice; they may not invent a ten-year “experience only” extension that violates the standard’s cap).
Re-examination character (major SNT contrast)
A key difference candidates must own:
- Under more flexible recommended-practice language, recertification discussions often include evidence of continuing satisfactory performance and/or re-examination as the Written Practice allows.
- Under CP-189, personnel are recertified at intervals not exceeding the maximum through re-examination (and other written-practice provisions). Experience documentation alone does not satisfy CP-189 recertification.
That single contrast—“experience alone is enough” vs “re-examination required”—is classic Basic bait.
Lapsed certification
If certification lapses beyond the allowable interval, the employer shall not simply reprint a certificate. Reinstatement must follow the qualification process appropriate to the lapse, which typically means re-examination and may include refresher training as the program requires. Automatic reissue without that process fails CP-189.
Procedure and Document Control Concepts
Level IIIs sitting Basic should connect personnel certification to document control habits:
- The written practice is controlled (revision history, approval, distribution)
- Examination materials are controlled (access, revision, security)
- Certification records are controlled (who is current, method/level scope, expiration, vision status)
- Method procedures used on the job are controlled separately—but a specific exam that never updates after a major procedure rewrite is a qualification integrity red flag
- Customer contracts that invoke CP-189 should be mapped to program clauses so the shop is not “SNT in practice, CP-189 on paper”
High-Yield “Shall” Exam Traps (Without Inventing Tables)
Memorize the character, not fake numbers:
| Trap statement | Better Basic answer |
|---|---|
| “Employer may reduce CP-189 training hours if busy” | No—minimums are mandatory once invoked |
| “Any Level II can grade certification exams alone” | No—Level III administers or approves |
| “No records needed if everyone knows the tech is good” | No—documented examination records are required |
| “Outside Level III needs no written-practice mention” | No—document the arrangement and responsibilities |
| “Recertify forever by signature and experience log only” | No—re-examination path; max interval applies |
| “Lapsed cert auto-renews next Monday” | No—reinstatement via appropriate qualification process |
| “CP-189 removes vision testing” | No—vision remains a program element |
Closing This Section
Section 13.2 is the “operations manual” of CP-189 for Basic: mandatory floors, Level III–controlled exams with records, documented outside help, vision, and recertification by re-examination within a five-year maximum. Section 13.3 locks the contrast with SNT-TC-1A into a side-by-side you can deploy on almost any standards-block question.
CP-189 requires that examinations administered for qualification of NDT personnel be:
Per CP-189, an outside agency Level III may be used by the employer:
Per CP-189 (2024), the maximum recertification interval for NDT personnel is:
A key difference between CP-189 and SNT-TC-1A regarding recertification is that CP-189: