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.

The testing laboratory side of the record

The mechanical test portion — reduced-section tensile, transverse guided bend, macro sections — is typically the more scrutinized record. AWS D1.1:2025 specifies the test requirements and acceptance criteria. The fabricator can use in-house test fixtures that meet the standard's dimensional requirements, or send coupons to a commercial testing laboratory.

When an independent lab is used, the lab report substitutes for in-house witness on the testing side. The lab report, signed by a qualified testing technician or engineer, documents specimen dimensions, failure locations, and acceptance or rejection. Keep the original lab report as a permanent attachment to the PQR — not a summary or scanned copy cropped of margins.

For in-house testing, the person who performed the bend test or machined the tensile specimens should sign as the testing witness. No special certification is required by D1.1:2025 for this role, but internal competency documentation is expected under ISO 3834 or AISC-level QA programs.

Connecting the PQR to the WPS and WPQ

The PQR supports the WPS. Once the PQR is complete and certified, it authorizes the WPS to be used in production. The welder who ran the test coupon also earns a Welder Performance Qualification for the process and position used — a result many fabricators underutilize when planning their welder qualification matrix.

For a detailed walkthrough of what the mechanical test data means, see reading a PQR test report. For the cost comparison between PQR-supported and prequalified procedures, see PQR vs. prequalified cost comparison. For a broader explanation of how PQR, WPS, and WPQ relate to each other, see WPS vs. PQR vs. WPQ explained.

If your shop is still tracking PQR records in spreadsheets and cannot reliably answer "which PQRs support which WPSs," that traceability gap is exactly what gets flagged in audits. See how WPS software handles PQR traceability.

Pre-coupon checklist

Before you strike the first arc on a PQR coupon:

  • Review contract documents and the ITP for any witness hold points
  • Notify the Owner's Inspector or third-party QC as required
  • Verify base metal mill certification against the WPS base metal designation
  • Confirm and document preheat; record ambient temperature
  • Set up data collection for all essential variables (amperage, voltage, travel speed, wire feed speed)
  • Keep the WPS physically present at the welding station
  • Mark each coupon with weld direction, F-side indicator, and location reference before shipping to the lab

Rule library based on AWS D1.1:2025; verify against your governing edition.

The audit that catches a fabricator on PQR witnesses is almost never about the code minimum — it's about what the contract required and what the QC system documented. Read the ITP before you weld the coupon.