8.3.1 LR will review the ITP for the support structure, including the
references to manufacturing procedures and the codes and standards referenced, and
the indication of the planned reviews and intervention points of the applicant and
their contactors. Based on the findings of this review LR will indicate the planned
surveillance on the plan(s), as certification body. LR’s surveillance will tend to
be less intensive for those parts of the support structure manufactured according to
a certified quality system.
8.3.2 The marked-up ITP becomes the surveillance plan referred to in Ch 2, 8.1 Module requirements. It should include details of
the sample size to be surveyed by the certification body, as applicable.
8.3.3 LR’s surveillance should be conducted and reported in accordance with the agreed
plan, although the plan can be updated in the course of the manufacture in response
to changes (e.g. to sub-suppliers or schedule) or to findings (e.g. areas of concern
identified during surveillance activities).
8.3.5 Attention will be paid to ensuring the manufacture follows the certified design (as
evaluated and reported in the conformity statement for the relevant module and its
supporting evaluation report). Any deviations from the certified design will need to
be assessed, and may require elements of the design evaluations to be repeated by
the certification body.
8.3.6 The surveillance will consider all primary and secondary structures, and include
foundation structures (e.g. piles), mooring systems for floating installations and
corrosion protection measures.
8.3.7 The surveillance will be conducted by a combination of audit (assessing
the assurance processes), sample review of manufacturing records, and sample of
inspections, in all cases focussing on areas of greatest risk. Items to be reviewed
and/or surveyed include:
- welding consumable certificates;
- welding procedure specifications (WPS);
- welding procedure qualification record (WPQR);
- welder performance qualifications (WPQ);
- non-destructive testing (NDT) procedures;
- NDT operator qualifications;
- special work procedures (e.g. shaping, hot forming);
- material traceability reports;
- weld traceability reports;
- heating records;
- NDT reports;
- weld repair register;
- dimension reports;
- technical queries (TQ);
- non-conformity reports (NCR).
8.3.8 An essential part of the surveillance is to verify material origin and quality, and
its traceability through the processing stages. This applies to metallic and
non-metallic materials, and will comprise a combination of document review and
inspection to confirm that:
- materials are certified according to BS EN 10204 Metallic products: Types
of inspection documents type 3.1 or 3.2 or equivalent (type 2.2 may
also be acceptable, subject to more intensive review and inspection by LR);
and
- the manufacturer is implementing a suitable identification system that
enables all finished materials to be traced to the original source.
8.3.9 The sample review of manufacturing records will include confirmation that all
personnel carrying out critical functions (e.g. welding, NDE) are qualified for the
tasks they are performing.