Attachment 14 - QAP.docx

QUALITY ASSURANCE PLAN

(QAP)

ACRONYMS

COR - Contracting Officer’s Representative

FSC ET - Facilities Support Contracts Engineering Technician

QA - Quality Assurance

QA Rep – Quality Assurance Representative, a.k.a. Contracting Officer’s Representative

QC - Quality Control

TOPWOP - Task Order Plan/Work Order Plan

PART 1 APPLICATION

1.1 QA is the system by which the Government verifies that the Contractor’s system of QC is working effectively and construction complies with the contract requirements. The QA process starts well before construction. Proper Construction Quality Management involves a proactive approach beginning with the Acquisition Planning phase, through the Contract Formation and Contract Administration phases.

1.1.1 The plan provides a "road map" for field operations, pre-award activities, post-award activities, testing and documentation. To remain effective, the plan shall be updated at least annually for changes in workload, staffing, etc.

1.1.2 During the early stages, the QA (COR) should spend as much time as possible in attending three phases of control meetings. The following personnel should attend and participate in the preparatory and initial phase meetings:

· COR

· QC Manager/QC Specialists

· Superintendent

· Foreman responsible for the definable feature of work

· Safety personnel

1.1.3 During site visits, the COR should focus on the processes by which the Contractor’s Quality Control System is implemented. If site visits reveal deficiencies, efforts shall be made to correct the process. Careful review of the three-phase control documentation may help determine the cause of the problem. After the preliminary review the COR should attend as many three-phase meetings as necessary to assure the meetings are being properly conducted. If the Contractor’s QC procedures are deficient, corrective action should be taken immediately. The COR should place emphasis on correcting Contractor deficiencies from the onset. Problem avoidance starts before actual work starts. Once work is underway and deficiencies occur, rework is required to correct them. The COR should properly document all corrective action taken by the Contractor.

1.2 CONSTRUCTIBILITY REVIEWS

1.2.1 Pre-Award of a Task Order: The Constructibility Review process is of special concern, as it offers the opportunity to have the biggest impact on the quality of projects. The FSC ET will perform the initial review of the Task Order Plan/Work Order Plan (TOPWOP) during pre-award for accuracy and to ensure the TOPWOP is inherently understandable and enforceable within during construction operations. The constructibility review by the FSC ET seeks to identify errors, omissions, and ambiguities in the TOPWOP thus reducing the potential for modifications and lost time during construction. The FSC ET is responsible for approval of the TOPWOP and will make the recommendation of award of a task order to the Contracting Officer.

1.2.2 Post Award of a Task Order: The approved TOPWOP and applicable approved record shop drawings must be technically correct to achieve a quality product that meets the customer’s expectations. The Contractor with normal capability must be able to perform the tasks as defined in the approved TOPWOP in the time allowed. The approved TOPWOP, submittals and approved record shop drawings and all pertinent documents must be inherently understandable and enforceable within normal contract procedures. During the post award process the Contracting Officer’s Representative reviews the submitted record shop drawings to ensure they are properly coordinated with the approved TOPWOP.

1.2.3 The constructibility review process, properly executed, will have a major contribution to quality in the acquisition process.

1.3 CONSTRUCTION ADMINISTRATION (POST-AWARD) RESPONSIBILITIES

1.3.1 The QA procedures are not intended, nor should they be allowed to replace the Quality Control Provisions required of the Contractor. When the Contractor’s QC process is unsatisfactory, the COR must apply the necessary corrective measures, as outlined in Section 2.5 to obtain an acceptable system. The temptation to provide continuing full time inspection in lieu of enforcing the required Contractor efforts in QC process must be avoided. This practice is unfair both to the Government and to the unsuccessful contractors. Quality Control by the Contractor and Quality Assurance by the Government are both necessary and must be applied.

1.4 REVIEW AND ACCPTANCE OF THE CONTRACTOR’S QUALITY CONTROL PLAN

1.4.1 The Contractor is required to submit a contract specific QC Plan to the Contracting Officer and COR within 15-calendar days after award of the contact for review and approval. The COR and FSC Technical Writer is responsible for reviewing the Contractor’s QC Plan. The review of the QC Plan by the COR and FSC Technical Writer seeks to identify errors, omissions, and ambiguities within the QC Plan thus reducing the potential conflicts and disputes once the contract has been fully implemented. The QC Plan must establish the procedures the Contractor will use throughout the contract. This review should be accomplished as quickly as possible and, when found acceptable, forwarded to the Contracting Officer for final approval.

1.4.1.1 As a minimum the COR shall consider the following:

1. Acknowledgement of the full range of QC requirements as evidenced by a complete package with all required items identified. Items may be incomplete, or even not present, but the Contractor should clearly indicate that they understand that the requirement for an item exists and will provide the information or item in a revised QC Plan.

2. Basic organizational structure of the Contractor’s Project Team, including the appointment of the QC Manager, complete with requisite authorities.

3. Established procedures for the basic processes that must run from the beginning of the contract, including submittal processes, scheduling processes, acceptance of materials, work inspection processes, rework procedures processes, documentation forms and procedures.

4. Control procedures including testing and inspection for those construction activities that will be accomplished prior to submission and approval of the complete plan.

5. Work activities will not start until after the submitted QC Plan has been approved.

1.5 APPROVAL OF THE CONTRACTOR’S QUALITY CONTROL PLAN

1.5.1 After the QC Plan has been approved, the COR must monitor the QC Plan to assure that the Contractor's QC organization is functioning as specified in their approved QC Plan. This is the essence of the Quality Assurance System. The COR must take affirmative steps to ensure that the Contractor corrects all deficiencies in the implementation of the QC provisions of the contract. This can be accomplished by discussing these deficiencies with the Contractor during periodic QC Meetings.

1.5.1.1 The QC Plan is likely to require updating throughout the life of the project. Changes to the approved QC Plan, including personnel changes, are subject to the prior approval of the Contracting Officer.

2 CONTRACT QUALITY ASSURANCE PLAN

2.1 THE ROLE OF THE QUALITY ASSURANCE REPRESENTATIVE (COR)

2.1.1 The QA Plan defines the responsibilities of the COR. The purpose of the QA Plan is to help the COR plan quality assurance activities to monitor the most critical construction activities.

2.1.2 The QA Plan places responsibility on the COR to be cognizant of the Contractor's activities in order to monitor critical work elements. The COR is the primary point of contact at the jobsite level between the Contractor and the Government. Any communications affecting the execution of the work should always include the COR.

A close, professional working relationship between the COR and the QC Manager is important. The QC Manager should be given every opportunity to perform their required duties and correct any deficiencies.

The COR should make every effort to visit each work site each day. As a minimum, the COR must visit each work site once a week to maintain awareness of the project status. The QA Plan designed is to help the COR make the most effective use of limited field time. The duration and frequency of visits will depend on the number of contract task orders assigned as well as the problems being encountered on other contract task orders. As a general rule, the COR should spend more time on a contract task order at the beginning to ensure that the Contractor’s QC System is functioning properly. Within short time frame they should be able to determine whether or not the Contractor’s QC organization is functioning in a satisfactory manner.

The COR may then be able to devote less time to one or more contract task orders and use the time saved to provide a presence on contract task orders that are deemed more critical. Attendance at all meetings with the Contractor, such as the Preconstruction Conference and QC meetings, and safety meetings is required. The COR is required to attend the preparatory and initial phases conducted by the Contractor.

The COR must review and document all Contractor Daily Production Reports and Quality Control Reports and Contractor of any errors or omissions. Timely documentation review and appropriate follow up action is critical to a successful job.

Reports inconsistent with the COR’s personal knowledge must be reconciled immediately. The primary point of contact for the COR on items of quality, workmanship, or the construction in general is the QC Manager. However, this does not preclude the COR from dealing with the Superintendent on the same items as the QC Manager or items that are normally their responsibility such as site safety, utility outages, the overall construction schedule, and access to the site.

2.1.2.1 Specific Duties: Carrying out the responsibilities outlined above requires the COR to accomplish the following tasks on a routine basis:

· Observe enforcement of safety provisions during normal site visits.

· Become familiar with the contract documents, in their electronic or hardcopy form and request correction through proper channels of any conflicts, omissions, errors, etc., that are found.

· Update the contract to incorporate any modifications issued.

· Remain familiar with the Contractor’s approved QC Plan.

· Review and recommend approval of Construction Schedules.

· Review submittals and recommend approval.

· Act as Contractor's point of contact on behalf of the Contracting Officer.

· Coordinate construction operations with Activity personnel.

· Make or arrange for inspections to be performed by the Government. (Inspections must be made within the parameters/requirements of the contract specifications to avoid “overzealous inspection”.

· The COR is advised to review the Army Corps of Engineer’s EP 415-1-261 for tips on inspection of construction.

· Verify and obtain decision on changed conditions.

· Inspect critical items and monitor specific testing. (In conjunction with the QC Manager under the QC System).

2.1.2.2 Make sufficient site visits to determine adequacy of QC System performance, such as:

· Check certifications of materials and equipment delivered to the site.

· Spot-check workmanship.

· Observe testing procedures.

· Review submittal register, rework items list, testing plan and log, etc.

· Evaluate Contractor's Quality Control System.

· Attend the weekly or bi-weekly Quality Control Meetings.

2.1.2.3 Obtain and review the daily QC and Production reports in a timely manner and take necessary action.

· Prepare the QA Report (QAR) when required.

· Prepare Construction Contract Non-compliance Notices.

· Review and make recommendations on Contractor payment requests.

· Contribute to preparation of Project Manager contract modification recommendations.

· Witness final tests and make final inspections for acceptance. (In conjunction with the QC Manager).

· Check status of “as-builts” maintained by the Contractor.

· Perform Labor Standards Interview.

· Conduct pre-final and final inspections.

· Scheduling and coordination of required utility outages.

2.1.3 Quality Assurance Representative Actions Concerning Deficiencies: The QC organization should be given the opportunity to detect and initiate correcting deficiencies. The COR’s responsibility is to assure the deficiency is corrected. If a deficiency is not corrected within one normal working day, the QC Manager is required to track the deficiency on the Rework Items List. If the deficiency is not logged on the Rework Items List, the COR shall issue a Construction Contract Non-Compliance Notice. If the deficiency will significantly impact the construction schedule, the COR must immediately notify the Contracting Officer and the FSC Engineering technician Supervisor.

The COR should continually monitor the Rework Items List maintained by the QC Manager on each task order using the QC System. The log should record the following:

· Date identified;

· Description of each rework item;

· Action taken/resolution; and

· Date corrected.

2.2 REPORTING REQUIREMENTS

2.2.1 The basic reporting requirement is to provide an accurate record of the work in progress and the as-built condition. This will help minimize later misconceptions concerning methods and progress of construction. Both the Government and the Contractor contribute to this contract record.

2.2.2 Quality Assurance Reports: Reports prepared or initiated by the COR should include the following:

· Quality Assurance Report,

· Construction Contract Non-compliance Notice (NAVFAC 4330/36), and

· Labor Standards Interview Report SF 1445

2.2.2.1 Generally, COR initiated construction reporting will be on an exception basis; however, the COR may increase the reporting requirements at any time deemed necessary.

2.2.3 COR’s Remarks Section on Contractor’s Reports: The "Quality Assurance Representative’s Remarks" section on the Contractor Quality Control Report is for COR’s remarks on routine matters and exceptions to the Contractor’s reports. Remarks should be directed at the Contractor's various operations, job progress, adequacy of the QC System and potential problems. The COR shall note any disagreement or question regarding the accuracy and completeness of the report. A copy of any remarks must be returned to the Contractor for resolution and appropriate reporting in subsequent Contractor reports or by another acceptable method.

Use of the "Remarks Section" on the reports is also appropriate to record that the COR was unable to visit the project on the day represented by the report.

The Contractor Quality Control Report continuation sheet may be used when additional space is needed to supplement and continue the " Quality Assurance Representative’s Remarks" section on the Contractor’s reports, or when it is necessary to document facts or conditions in detail.

2.2.3.1 The Quality Assurance Report (QAR): The QA Report (QAR) is an optional form for use on contract task orders. The reporting frequency is on an as-needed basis. The following are considered general guidelines for use of the QAR and do not preclude the Contracting Officer from varying them as circumstances dictate. The COR should prepare a QAR whenever:

1) Specific work is inspected for contract compliance. This does not mean whenever the site is visited. “Normal” visits can be reported solely through use of the COR’s remarks on the QC report.

2) Situations are discovered which adversely affect contract compliance (either time or quality). These may also be reported using the COR’s remarks on the QC report.

3) A team inspection is performed.

4) Verbal instructions are given to the QC Manager or Project Superintendent. These may also be reported using the COR’s remarks on the QC report.

5) There is a lack of application by the Contractor of QC requirements or failure to take corrective action on known deficiencies.

6) Uncorrected hazardous safety conditions exist.

7) There is a lost time accident.

8) When the Contractor's own daily reports are not received and reviewed in a timely manner (i.e. the following day).

If a QAR contains disagreement, dispute or any issue requiring further resolution, a copy shall be forwarded to the Contractor’s home office or Project Manager.

2.3 REVIEWING THE CONTRACTOR’S REPORTS

2.3.1 The COR has the prime responsibility to ascertain the completeness and accuracy of the Contractor's Production and Quality Control Reports. The reports play an important role in settling disputes, especially those involving extended overhead and impact costs. Success in requiring the Contractor to properly execute these reports can substantially reduce the volume of documentation prepared by the Government. The COR must review all reports immediately upon receipt to ensure their accuracy and completeness. The Contractor must correct any discrepancies. The COR should use the space provided on the form to comment on, or take exception to, information indicated in those reports. Incorrect or erroneous information must be commented upon and appropriate follow-up action taken. Failure to take exception to incorrect information contained in the report constitutes constructive acceptance of the Contractor’s version of events.

The COR should check the following when reviewing reports:

· Phases of construction (preparatory, initial, and follow-up) under way on the day of the report, and the specific location of the work performed.

· Results of quality control procedures and inspections, including the nature of deficiencies observed and the corrective action proposed by the Contractor. This should include dimensional checks and validation of work elements along with safety violations and the location of such inspections. Minor deficiencies that are corrected on the same day they occur need not be included in the report. However, any deficiency that is carried over to the following day must be shown.

· Test results, including failures and remedial action to be taken. When test results cannot be completed by the time the report is submitted, a notation should be made that the test was performed and the approximate date results will be available. Delayed test results should be submitted with the report on the date received. Make sure Testing Log is kept updated.

· Any offsite inspection activities and the inspection of materials and equipment at the job site. Specific impacts, or lack thereof, of adverse weather conditions on the job.

2.3.2 Construction Contract Non-compliance Notice: This is a standard form (NAVFAC 4330/36) initiated by the COR to inform the Contractor of a deficiency requiring corrective action. The effectiveness of the form will be lost if it is issued to the Contractor for every deficiency regardless of magnitude or importance. If the Contractor has acknowledged the deficiency and correction is forthcoming, this notice should not be used. Further details on the use of this form are included in Appendix P.

2.3.3 Labor Standards Interview: The Defense Federal Acquisition Regulation Supplement (DFARS) provides a form used to make regular checks of compliance with contract labor standards. These regular compliance checks should include the following:

a) Employee interviews to determine classifications and rate of pay, including fringe benefit payments. SF 1445, "Labor Standards Interview” shall be used for recording such interviews.

b) On-site checks of type and classification for work performed and number of workers.

The COR is tasked with most items on the form. The item "FOR USE BY PAYROLL CHECKER" is the responsibility of the Contracting Officer.

2.4 ENFORCEMENT OF QUALITY CONTROL

2.4.1 Contractors must accept QC responsibilities. When the Contractor fails to control their own construction processes and those of their subcontractors and suppliers, enforcement becomes a vital element. Past experience shows the Project Manager’s timely and firm action is a major factor in resolving QC issues. This includes elevating problems to appropriate levels within the Contractor’s organization, as well as use of the various enforcement mechanisms available in the contract.

2.4.1.1 Quality Management Problems: The difficulties associated with QC vary, but most fall into the following categories:

· Commencing work without an acceptable, approved QC Plan and Safety Plan.

· Inadequately developed QC provisions.

· Inadequately enforced QC provisions.

· Delay in submitting an acceptable QC Plan.

· Inadequate qualifications of personnel in the quality control organization.

· Untimely or incomplete daily reports.

· Inadequate preparatory, initial and follow-up controls on each Defined Feature of Work (DFOW).

· Failure to take corrective action when deficiencies exist.

· Late and incomplete reporting of tests and inspections.

· Lack of interest by Contractor's management personnel.

· Failure to verify punch-list item completion.

· Submittal Processes

2.5 CORRECTIVE MEASURES

2.5.1 The Contract provides the means to enforce contractor compliance. Reasonable, but firm application of these provisions can be as effective in enforcing QC as it is for any other contract requirement. Implementation of any enforcement action requires careful consideration, along with complete and timely documentation. Actions that should be considered are:

· "Removal and Replacement of Defective Materials or Workmanship." FAR 52.246-12 "Inspection of Construction," clause is the appropriate provision for directing the Contractor to replace unsatisfactory work. The COR must notify the Contractor in writing of nonconforming work and of his obligation to replace material or correct workmanship as necessary. The Contractor must not be allowed to build upon defective work.

· "Disallow Payment." The COR should make a recommendation to the Contracting Officer to disallow payment for nonconforming work or subsequent work that will be affected in correcting the nonconforming work.

· "Retention on Invoiced Amounts” In addition to recommending disallowing payment, the COR may request that the Contracting Officer withhold payment in the form of retention from the Contractor’s request for payment, FAR Clause 52.232-5 Payments under Fixed-Price Construction. The payment clause applies to each of the above items.

· “Non-Payment for Unapproved Materials.” Materials used or installed without an approved submittal should not be paid for until such time the submittal is approved and the materials verified as conforming to the submittal.

· "Removal of Incompetent/Careless/Objectionable Personnel." The Contracting Officer may direct the Contractor to remove any employee deemed incompetent, careless, or otherwise objectionable, FAR Clause 52.236-5 Materials and Workmanship. Prior to removal, the COR should convene a meeting with the Contractor and attempt to correct the situation. Once the QC Manager has been removed, work should not be allowed to proceed until the Contractor provides an acceptable replacement. Reluctance to replace an incompetent QC Manager will only lead to greater problems as the job progresses. Any removal must be supported with complete documentation showing carelessness, negligence, or other behavior detrimental to contract performance.

· "Stop The Work." The Contracting Officer can direct the Contractor to stop work on any unsatisfactory item or work element pending satisfactory correction of the deficiency. The Contractor should also be directed not to install materials that lack an approved submittal. This is particularly important if the materials or defective work will be enclosed, will support further construction, or will be inaccessible if further work proceeds. These directives should not be designated as "Stop Orders," but should cite the deficiency and state that no further work be accomplished that will interfere with correction of the deficiency, FAR Clause 52.236-5 Materials and Workmanship.

· "Contractor Performance Evaluation." The Construction Contractor Performance Evaluation Report includes appraisal of the Contractor’s Quality Control effort. Failure by the Contractor to provide an adequate QC System or marginal performance despite repeated written notification should result in an unsatisfactory rating. Interim unsatisfactory appraisals should be considered when performance has been unsatisfactory for a reasonable period of time. The significance of this action should be explained to the Contractor as well as the exact reasons for such action. Conversely, when the Contractor exercises good quality control and produces quality construction, it should be noted in the performance appraisal. Recognition of outstanding QC Systems and quality workmanship should be given when appropriate. Information on evaluating performance (CPARS) on construction contracts is given in P-68.

· "Default." The "Default (Fixed Price Construction)" clause is the authority for terminating the Contractor’s right to proceed with the work. This is the ultimate action that can be taken against the Contractor and must be in accordance with the requirements of the "Default (Fixed Price Construction)" clause and applicable NAVFAC regulations. Only in justifiable instances will default recommendations be sustained.

CONTRACT PRE-PERFORMANCE CONFERENCE MEETING

Contract Number:

Contracting Officer’s Representative:

Date:

Were all of the Government’s key personnel, e.g. Contracting Officer or Contracting Specialist, FSC Inspection Supervisor, Contracting Officer’s Representative, FSC Safety Officer, FSC Technical Section Supervisor, and FSC Technical Writer, in attendance at the Contract Pre-Performance Conference Meeting?

TASK ORDER PRECONSTRUCTION MEETING

Contract Number:

Task Order Number:

Contracting Officer’s Representative:

Date:

Have all submittals been approved prior to mobilization and start of work on a task order?

Did the Contractor submit outage and locating requests?

QUALITY ASSURANCE PROGRESS REVIEW

Contract Number:

Task Order Number:

Contracting Officer’s Representative:

Date:

SPECIFICATIONS AND RECORD SHOP DRAWINGS

QUALITY ASSURANCE MONTHLY EVALUATION

MONTH: YEAR:

Experience of Personnel

1. Did the team (i.e. FSC ET, Contractor’s PM, PS, QCM) identified in the actively participate in the project?

2. If Contractor personnel substitutions were needed, was the degree of technical competence maintained?

Working Relationships

1. Did the FSC Engineering Technician, PM, PS and QCM participate in the preconstruction meeting?

2. Are quality control and safety meetings being conducted?

Quality Control

1. Is work being performed in accordance with the approved Quality Control Plan?

2. Were re-submittals of design deliverables or construction rework required this month?

3. Were as built redlines updated this month?

Timely Performance

1. Is the Contractor on schedule?

2. Is the Contractor maintaining the schedule? (Can the Government confirm the project is on schedule?)

3. Is the Contractor following his schedule?

Effectiveness of Management

1. Did the Government need to intercede in resolving a subcontractor issue?

Compliance with Labor Standards

1. Did payrolls have to be resubmitted this month due to inaccuracies or errors?

Compliance with Safety Standards

1. Were there any lost time accidents this month?

GENERAL PERFORMANCE COMMENTS THIS MONTH:

Concurrence:

Contracting Officer’s Representative Date