March 2006 - Contractor Quality Control Plans
posted by Larry J SmithSubmitted by: Larry J. Smith, P.E.
Introduction
The December 2004 Article of the Month "Construction Quality Management for Contractors" reviewed the requirements that all contractors performing construction to comply with the “Contractor Quality Control” (CQC) requirements, specifically UFGS Specification 01451. To better understand these requirements a training course entitled Construction Quality Management for Contractors was developed for the purpose of improving Quality Control. The course details the requirements of the contractor personnel and government personnel assigned to the project and the reasons for the requirements.
Continually contractors are missing the key ingredients of the Quality Control Plan –
Qualified Personnel
“The Contractor shall furnish for review by the Government, not later than 15 days after receipt of notice to proceed, the Contractor Quality Control (CQC) Plan proposed to implement the requirements of the Contract Clause titled "Inspection of Construction." The plan shall identify personnel, procedures, control, instructions, tests, records, and forms to be used. The Government will consider an interim plan for the first 30 days of operation. Construction will be permitted to begin only after acceptance of the CQC Plan or acceptance of an interim plan applicable to the particular feature of work to be started. Work outside of the features of work included in an accepted interim plan will not be permitted to begin until acceptance of a CQC Plan or another interim plan containing the additional features of work to be started.”
Content of the CQC Plan
The CQC Plan shall include, as a minimum, the following to cover all construction operations, both onsite and offsite, including work by subcontractors, fabricators, suppliers, and purchasing agents:
a. A description of the quality control organization, including a chart showing lines of authority and acknowledgment that the CQC staff shall implement the three phase control system for all aspects of the work specified. The staff shall include a CQC System Manager who shall report to the overall project superintendent.
b. The name, qualifications (in resume format), duties, responsibilities, and authorities of each person assigned a CQC function.
c. A copy of the letter to the CQC System Manager signed by an authorized official of the firm which describes the responsibilities and delegates sufficient authorities to adequately perform the functions of the CQC System Manager, including authority to stop work which is not in compliance with the contract. The CQC System Manager shall issue letters of direction to all other various quality control representatives outlining duties, authorities, and responsibilities. Copies of these letters shall also be furnished to the Government.
d. Procedures for scheduling, reviewing, certifying, and managing submittals, including those of subcontractors, offsite fabricators, suppliers, and purchasing agents. These procedures shall be in accordance with Section 01330 SUBMITTAL PROCEDURES.
e. A complete list of all specified control, verification, and acceptance testing procedures for each specific test to include the test name, specification paragraph requiring test, feature of work to be tested, test frequency, and person responsible for each test. (Laboratory facilities will be approved by the Contracting Officer.) Contractor must utilize the QCS – RMS module as specified in Specification Section 01312.
Personnel Requirements
The requirements for the CQC organization are a full time CQC System Manager and sufficient number of additional qualified personnel to ensure contract compliance. The Contractor shall provide a CQC organization which shall be at the site at all times during progress of the work and with complete authority to take any action necessary to ensure compliance with the contract. All CQC staff members shall be subject to acceptance by the Contracting Officer.
CQC System Manager
The Contractor shall identify as Overall CQC System Manager an individual employed by the prime contractor on the work site who shall be responsible for overall management of CQC and have the authority to act in all CQC matters for the Contractor. The Overall CQC System Manager shall be a construction person with a minimum of 5 years in related work. This CQC System Manager shall be on the site at all times during construction. The CQC System Manager shall be assigned no other duties. Two alternates for the CQC System Managers will be identified in the plan to serve in the event of any System Manager's absence. The requirements for these alternates will be the same as for the designated CQC System Managers.
CQC Personnel
In addition to CQC personnel specified elsewhere in the contract, the Contractor shall provide as part of the CQC organization specialized personnel to assist the CQC System Managers for the following areas: electrical, mechanical, Civil, structural, environmental, fire protection. These individuals shall be employees of the prime Contractor, and may not be employed by a supplier or sub-contractor on this project; be responsible to the CQC System Manager; be physically present at the construction site during work on their areas of responsibility; have the necessary education and/or experience in accordance with the experience matrix listed herein. These individuals shall have no other duties other than quality control.
A recent ASBCA decision "M.A. Mortenson Co., ASBCA No. 53349, 05-2 BCA ¶ 33,014." found that the “specialized CQC personnel specified in Corps of Engineers contracts have some expensive consequences for contractors failing to understand the CQC requirements.
A key decision by the Board is the Prime Contractor is required to "police" the work of the subcontractors and to see that it complies with the contract documents. The prime contractor does this by specifically establishing and maintaining an effective quality control staff.
With more Corps of Engineers Districts adopting Metrics for “on time” project delivery the importance of establishing and maintaining and effective quality control staff should not be underemphasized by Administrative Contracting Officers. Delays are frequently related to problems within the Red Zone and with Mechanical and Electrical System debugging, testing, and commissioning. By reviewing "lessons learned" in project closeout we continue to see the importance of closeout action plans and competent CQC personnel who understand schedule and technical requirements for project closeout.
I encourage all Construction Managers and Administrative Contracting Officers to review this article and the Mortenson case. Mr. Kelleher is correct; this case will be cited throughout the Corps for all us to better understand CQC staff requirements.
Contractors and COE personnel should continue their skills by remaining current with the Construction Quality Management for Contractors Course.
The 2006 CQM "Course Matrix" has been published to allow viewers and opportunity to select a course time and location matching your needs.
Your comments on this Article of the Month are encouraged below or on the Forum.