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February 2 - February 6, 2016

Some specifications may have requirements that the inspector may know to be extraneous or may be more restrictive than necessary to obtain a quality coating application. What is the ethical responsibility of the inspector to reject non-conforming coatings that they know will perform as intended, particularly where attempted repairs may degrade the coating system?

Selected Answers

From Michael Halliwell of Thurber Engineering Ltd. on February 12, 2016:
From the consulting side, we're there to look out for our client's interests. If an issue arises, there is an obligation to bring it to the attention of the client, inform them of the situation and options, then let them make an informed decision as to what happens going forward. If I see something not up to spec, I'm going to talk with the client (and hopefully the other stakeholders), saying "things aren't meeting spec, but based on past experience what was done should perform sufficiently. Repairs may cause more harm than good. You need to make the decision because you'll live with the consequences, but my opinion is..."

From Charles Harvilicz of Huntington-Ingalls, Newport News Shipbuilding on February 12, 2016:
He has two obligations. One is contractual, and the other is ethical or moral. He should carry out the first, and inform the owners of what he knows about the performance of the coatings system with less stringent requirements to take care of the other.

From Warren Brand of Chicago Corrosion Group on February 11, 2016:
I've had these conversations before, and have always found myself in the minority. And, I'm very comfortable there. There is a simple, overarching principal that I follow. What is the right thing to do? I simply am not wired to sit back and "observe, document and report" while something is going wrong. I think this is particularly ironic since my first job was as a daily newspaper reporter where that was all that I did. When people talk of their "ethical" responsibilities as a coatings inspector, I believe they are misusing the word ethical. Ethics relate to moral values, which, in my mind, override pretty much everything else. What I think these folks mean is "obligation" or, perhaps, "authority." But it is certainly not ethical to watch a coating application go wrong and simply sit back and take notes. It may be their job; it may be their obligation; they may even have the authority; but no, it is certainly not ethical behavior. We, as coating inspectors and professionals, need to rethink our role. Yes, of course, our first job as an inspector on site is to observe and document. However, if we see that 100 tons of the wrong-sized blast grit has been delivered, it's our ethical responsibility to let people know, even if it is not necessarily our role. I was talking to an inspector working on a bridge project this past summer. He called me, exasperated, asking my advice about a situation where the specification called for a blast profile of between 2.0 and 3.0 mils (or something like that). The blast ended up being between 3.0 and 4.0 mils. The coating consulting firm adamantly refused the blast, saying it was out of spec. The inspector took it upon himself to contact the coating manufacturer, who submitted a letter saying the 1.0 mil difference was acceptable. But the consulting firm refused to budge. The profile was out of spec - and that was that. The job stopped. The blast rusted. Expenses piled up for no technical justification whatsoever. The firm may have been acting "responsibly," or perhaps within their "authority," but how can that type of blind adherence to a specification ever be considered ethical?

From Karen Fischer of Amstar of WNY on February 11, 2016:
Coating Inspector training (SSPC or NACE) indicates that the inspector neither writes the specifications, nor is allowed to change them, no matter how they are written. Their job is to enforce the specifications (observe and record compliance). It is up to the contractor to address any conflict or unnecessary requirements in a specification with the owner or designer of the specification. An inspector can voice an opinion on the matter or inform the owner (either verbally or in writing) that enforcing the specification may result in a failure, but it is not within the job description of most inspectors to change the specification or allow anything other than what is called for. As a NACE Certified Inspector, I would inform the owner in writing of a conflict I saw in a specification and that it may result in a coating performance failure, so that I have my backside covered.

From john kern of VCI on February 11, 2016:
In your original statement you indicate there was no specification for the contractor to work to, so my question is, who specified the coating system. As a result of no specification, did the contractor submit to the owner an application and or an ITP? Since neither is indicated, then the "hired" inspector's job is to report the initial conditions as found to the entity that hired him. He does have the right to interject to this entity his findings such as "the wrong application" for the product in his report and support this finding per the PDS. It is his responsibility only to observe and report to the entity that hired him and  then let the owner make a final decision on the use of the coating system. This should have been accomplished during the pre-job conference and documented by the coating contractor. We as inspectors often find this situation due to the failure of the owner or applicator not performing due diligence in job specifications. In these cases we can only document what we find during the inspection service and report to the appropriate entity. If it is a bad spec, report it to the person you were hired by to perform the service. By reporting it to the other party, you may become liable for the application process. Again, it is our responsibility to document and report the observations and let the contractor or owner make the final decision. If we are working for the contractor and we report to them, then it becomes his responsibility to report to the owner if he sees fit to do so. If it still becomes a bad spec, so be it, as in your stated case. Inspect, document and report; that is your responsibility!

From Warren Brand of Chicago Corrosion Group on February 5, 2016:
We ran into this exact situation yesterday. A large pump housing, around the size of a large refrigerator, needed to painted internally ASAP. Our client called and asked if we could get an inspector onsite ASAP. As we put things into motion, I asked for a copy of the product data sheet (there was no specification). The internal environment of this pump housing contained water (condensation) at between 100 and 150 F. The housing was alreadydeeply pitted on the inside due to the original paint peeling off. The housing was made by one of the largest manufacturers in the world (a household name), highly sophisticated, one would think. The product data sheet, in part, indicated that the material was surface-tolerant (didn't even need to abrasive blast!) and that it could be used on the exterior of a ship, but not below the water line! The last page of the document clearly indicated that for immersion service (which this clearly was), a completely different product was recommended. I was stunned. I raised this red flag to the owner (even though we were hired only to inspect) because it was the ethically correct and kind thing to do (note my recent blog - ( We ended up with an email chain of about a dozen individuals, including some of the top people from the OEM. Then, I heard the words that OEM's use to defend uneducated, improper coating selections, "We've been using this material with no problem for more than 20 years." At the end of the day, I felt my job was to provide my opinion, supported by objective, independent, verifiable data,  and then let the client make the decision, which is exactly what happened.

From Stephen Bothello of Jotun UAE Ltd on February 4, 2016:
The coating inspector should be aware and be absolutely clear about  his responsibility and authority. The pre-job conference, where client representative, contractor's representatives and applicator's representatives are present, is a right forum to seek clarification about this or reinforce the dos and don'ts of the inspector's job. The main project documents, that is, specification from client, method statement from contractor/applicator and Inspection Test Plan/Protocol (ITP) should be absolutely clear in this regard. If the specification, work procedures or acceptance criteria within the ITP are not complied with, the inspector's most ethical responsibility is to raise an observation report or, in the case of serious violations, a non-conformance report (NCR). If a non-conforming coating has been used, it is, of course,  non-compliant with the job specification; hence, an NCR needs to be issued. NCRs have  provisions for the applicator and supplier to respond within a reasonable time limit, explaining why a non-complying coating was applied and describing any corrective or preventive actions. Though for an inspector it may be good to know that the non-complying coating may perform as intended, it is only ethical to reject, report and document the non-conformance and leave it to the applicator/supplier to explain, and for the other competent authorities of the project to agree/ disagree on final acceptance or rejection of the applied non-conforming coating.

From Steve Stroud of Stroud Estimating, LLC on February 4, 2016:
I agree with Ivan Lasa.

From Ivan Lasa. of FL Dept Transportation on February 3, 2016:
It is the responsibility of the inspector to verify that the coating is applied as per contract. It would be unethical to make a decision to accept a non-conforming product. In such cases the ethical responsibility rests on the applicator to request acceptance from the owner. The opinion of the inspector may be included as part of the request.

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Tagged categories: Coating inspection; Inspection; North America; Quality Control; Specification

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