A common question from fabricators preparing for third-party audits: "Does a CWI have to be standing next to the welder when we run our PQR coupon?" The short answer is no — not under AWS D1.1:2025 alone. But the longer answer is where shops get caught.
What the standard actually requires
AWS D1.1:2025 Clause 6.3 establishes Procedure Qualification Record requirements. The standard requires the PQR to document the actual welding variables used during the test weld, that coupons be tested according to the specified mechanical test requirements, and that the fabricator's authorized representative certify the record.
Nowhere in D1.1:2025 does the standard state that a Certified Welding Inspector, third-party observer, or owner representative must physically be present while the test coupon is welded. The obligation falls on the fabricator: weld the coupon in strict accordance with the WPS being qualified, measure and record the actual parameters, submit coupons to a qualified testing laboratory, and certify the resulting record.
This is similar to ASME Section IX, which is also silent on mandatory witness. But many nuclear and petrochemical owner specifications impose hold points requiring authorized personnel to observe coupon welding. AWS D1.1 leaves the same gap for contracts to fill.
Where owner and EOR specifications take over
Most disputes about PQR witnesses originate not from the code but from contract documents. Common additions include:
Owner-supplied Inspector (OI) hold points. Many project specifications require the Owner's Inspector to be notified before PQR coupon welding begins. The welder cannot strike an arc until the OI signs off on preheat, base metal identification, and the WPS in use.
Third-party lab testing requirements. Some contracts require all mechanical test coupons to be machined and tested by an independent, accredited testing laboratory (ASTM E329 accreditation). This is separate from the witness question but often written in the same contract clause.
Fabricator QC witness signatures. Many EOR-supplied quality programs require internal QC witness signatures on the PQR form — not just the certifying signature at the bottom. This provides an internal chain of custody: the QC tech who observed the weld signs, the welding engineer who reviewed the test data signs, the authorized representative certifies.
If you are working under a contract that includes a Project Quality Plan or Inspection and Test Plan (ITP), check the PQR line item before you schedule qualification welding.
What happens when witness records are absent
In a third-party audit under AISC Certification, IAS AC172, or owner QA review, the auditor reviews PQR records for completeness. If the project specification required a CWI witness and the PQR has no witness log, the record is non-conforming under the contract — regardless of whether the actual welding was performed correctly.
The consequence is typically a corrective action request and, in severe cases, a demand for requalification. Requalification means another test coupon, more mechanical testing, and schedule impact. This is avoidable with front-end planning.
The safest approach: treat every PQR as if it will be audited. Establish a standard witness log as part of the PQR form itself, even when the current contract does not require one. A CWI co-signature at the time of welding costs nothing; retroactive PQR reconstruction is expensive and sometimes impossible.