QASP Northport Hazardous Waste.pdf

Quality Assurance Surveillance Plan

1. PURPOSE

This Quality Assurance Surveillance Plan (QASP) provides a systematic method to evaluate performance for the stated contract. This QASP explains the following:

What will be monitored?

How monitoring will take place.

Who will conduct the monitoring?

How monitoring efforts and results will be documented.

2. GOVERNMENT ROLES AND RESPONSIBILITIES

The following personnel shall oversee and coordinate surveillance activities.

A. Contracting Officer (CO) - The CO shall ensure performance of all necessary actions for effective contracting, ensure compliance with the contract terms, and shall safeguard the interests of the United States in the contractual relationship. The CO shall also assure that the contractor receives impartial, fair, and equitable treatment under this contract. The CO is ultimately responsible for the final determination of the adequacy of the contractor’s performance.

Assigned CO:

Organization or Agency: Department of Veterans Affairs, RPO East, VISN 2

B. Contracting Officer’s Representative (COR) - The COR is responsible for technical administration of the contract and shall assure proper Government surveillance of the contractor’s performance. The COR shall keep a quality assurance file. The COR is not empowered to make any contractual commitments or to authorize any contractual changes on the Government’s behalf.

Assigned COR: Laverne Glover Organization or Agency: Northport VAMC – Department of Veterans Affairs VISN 2

C. Other Key Government Personnel:

Sarabjit Singh, Deputy Chief of Engineering

3. CONTRACTOR REPRESENTATIVES

The following employees of the contractor serve as the contractor’s program manager for this contract.

A. Program Manager: To Be Determined upon vendor selection

B. Dispatcher: To Be Determined

4. PERFORMANCE STANDARDS

Performance standards define desired services. The Government performs surveillance to determine if the contractor exceeds, meets, or does not meet these standards.

The Performance Requirements Summary Matrix, paragraph (N/A) in the Statement of work (SOW), includes performance standards. The Government shall use these standards to determine contractor performance and shall compare contractor performance to the Acceptable Quality Level (AQL).

Contractor agrees to maintain an on-going Quality Management/Assurance Program which include the following activities Quality Assurance: The contractor will be evaluated throughout the contract period regarding their compliance with all VA quality performance measures and monitors as it pertains to Ambulance Services; proper documentation, adherence to performance measures, timely access, excessive waits/delays, pickup and delivery of special mode.

Additionally patient safety and patient complaints will be researched and addressed as necessary.

Task ID Indicator Standard Acceptable

Quality Level Method of

Surveillance

Incentive/Penalty

Handling of Waste

A

26-Scheduled wastes pickups

Disposal of Hazardous wastes required within a 90-day period after generation.

Contractor’s adherence to regulatory maximum turn-around-times.

<89 days = Exceptional

Within 90 days = Satisfactory 91-95 days = Marginal

>96-days = Unsatisfactory:

Regulatory Non- Compliance

Within 90 days 88%

Direct Observation during pre-waste removal manifest signing and COR tracking of stored wastes during weekly inspections of CHMSA

Incentive = CPARS rating.

Penalty = more than 3 marginal ratings in a 6-month period will be grounds for cure notice, a second instance of 3 marginal ratings in consecutive 6 months period may be grounds for termination.

Quality Level

Manifests, Reports, Tracking Documents

B

Waste Manifests

Compliance in the proper characterization, classification, segregation, consolidation, and packing of hazardous waste offered for disposal.

1-20 days = Exceptional

21-30 days = Satisfactory

31-40 days = Marginal

>40-days = Unsatisfactory:

Regulatory Non- Compliance

21-30 days = 81%

COR shall perform direct observation periodic reviews of final & signed manifests for waste disposal.

Incentive = CPARS rating.

Penalty = more than 3 marginal ratings in a 6-month period will be grounds for cure notice, a second instance of 3 marginal ratings in consecutive 6 months period may be grounds for termination.

Quality Level

Emergency Response

C

Contractor/ Subcontractor Response to Hazardous Materials Spills

Completion of Emergency Response mobilization and spill abatement with abatement/ remediation completion.

Moderate spill remediation complexity anticipated – variance in complexity to be evaluated and factored into AQL based on overall response.

High Complexity 1-24 hours = Exceptional

25-72 hours = Satisfactory

3 – 15 days = Marginal

>15-days = Regulatory Non- Compliance - Unsatisfactory

Moderate Complexity

1-12 hours = Exceptional 13-24 hours = Satisfactory

2 – 5 days = Marginal

>5-days = Regulatory Non- Compliance - Unsatisfactory

Abatement completed within 24-hrs.

80%

Direct observation of emergency response operations by COR, OS&H Specialist, or GEMS Coordinator and monitoring/ documentation of emergency response progress.

Subject to negative review.

Quality Level

Hazardous Waste Spill or Release Reporting

D

Contractor / Subcontractor Response Documentation of hazardous waste/ materials spills clean-up

Documentation of mobilization for HAZWOPER trained/ certified crew/remediation equipment and completion of all remediation phases.

Written summary report of spill event to COR within 5-business days.

1-3 days = Exceptional

4 - 6 days = Satisfactory

7 – 9 days = Marginal

>9-days = Unsatisfactory

85%

COR shall monitor documentation through direct observation associated with spill response and review deficiencies/ complaints/ recommendations.

Subject to negative review.

5. METHODS OF QA SURVEILLANCE

Various methods exist to monitor performance. The COR shall use the surveillance methods listed below in the administration of this QASP.

A. DIRECT OBSERVATION. (Can be performed periodically or through 100% surveillance) B. PERIODIC INSPECTION. (Evaluates outcomes on periodic basis. Inspections may be scheduled {Daily, Weekly, Bi-Weekly, Monthly, Quarterly or Annually} or unscheduled, as required).

C. Validated User/Customer Complaints. (Relies on the customer to identify deficiencies.

Complaints are then investigated and validated)

6. RATINGS

Metrics and methods are designed to determine if performance exceeds, meets, or does not meet a given standard and acceptable quality level. A rating scale shall be used to determine a positive, neutral, or negative outcome. The following ratings shall be used for measurement will be: Meets Standards/ Does Not Meet Standards

EXCEPTIONAL:

Performance meets contractual requirements (AQL) and exceeds many to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with few minor problems for which corrective actions taken by the contractor were highly effective.

Note: To justify an Exceptional rating, you should identify multiple significant events in each category and state how it was a benefit to the GOVERNMENT.

However, a singular event could be of such magnitude that it alone constitutes an Exceptional rating. Also, there should have been NO significant weaknesses identified.

VERY GOOD:

Performance meets contractual requirements (AQL) and exceeds some to the Government’s benefit. The contractual performance of the element or sub-element being assessed was accomplished with some minor problems for which corrective actions taken by the contractor were effective.

Note: To justify a Very Good rating, you should identify a significant event in each category and state how it was a benefit to the GOVERNMENT. Also, there should have been NO significant weaknesses identified.

SATISFACTORY:

(Acceptable Quality Level)

Performance meets contractual requirements. The contractual performance of the element or sub-element contains some minor problems for which corrective actions taken by the contractor appear or were satisfactory.

Note: To justify a Satisfactory rating, there should have been only minor problems, or major problems the contractor recovered from without impact to the contract. Also, there should have been NO significant weaknesses identified.

MARGINAL:

Performance does not meet some contractual requirements. The contractual performance of the element or sub-element being assessed reflects a serious problem for which the contractor has not yet identified corrective actions. The contractor’s proposed actions appear only marginally effective or were not fully implemented.

Note: To justify Marginal performance, you should identify a significant event in each category that the contractor had trouble overcoming and state how it impacted the GOVERNMENT. A Marginal rating should be supported by referencing the management tool that notified the contractor of the contractual deficiency (e.g. Management, Quality, Safety or Environmental Deficiency Report or letter).

UNSATISFACTORY:

Performance does not meet most contractual requirements and recovery is not likely in a timely manner. The contractual performance of the element or sub-element being assessed contains serious problem(s) for which the contractor’s corrective actions appear or were ineffective.

Note: To justify an Unsatisfactory rating, you should identify multiple significant events in each category that the contractor had trouble overcoming and state how it impacted the GOVERNMENT. However, a singular problem could be of such serious magnitude that it alone constitutes an unsatisfactory rating. An Unsatisfactory rating should be supported by referencing the management tools used to notify the contractor of the contractual deficiencies

(e.g.: Management, Quality, Safety or Environmental Deficiency Reports, or letters).

7. DOCUMENTING PERFORMANCE

A. Acceptable Performance

The Government shall document positive performance. Any report may become a part of the supporting documentation for any contractual action.

B. Unacceptable Performance

When unacceptable performance occurs, the COR shall inform the contractor. This will normally be in writing unless circumstances necessitate verbal communication. In any case the COR shall document the discussion and place it in the COR file.

When the COR determines formal written communication is required, the COR shall prepare a Contract Discrepancy Report (CDR) and present it to the contractor's program manager.

The contractor shall acknowledge receipt of the CDR in writing. The CDR will specify if the contractor is required to prepare a corrective action plan to document how the contractor shall correct the unacceptable performance and avoid a recurrence. The CDR will also state how long after receipt the contractor must present this corrective action plan to the COR. The Government shall review the contractor's corrective action plan to determine acceptability.

Any CDRs may become a part of the supporting documentation for any contractual action deemed necessary by the CO.

8. FREQUENCY OF MEASUREMENT

A. Frequency of Measurement – Periodic as per performance surveillance.

During contract performance, the COR will periodically analyze whether the negotiated frequency of surveillance is appropriate for the work being performed.

B. Frequency of Performance Assessment Meetings – Periodic during the duration of the contract.

The COR shall meet with the contractor monthly to assess performance, discuss concerns, and troubleshoot existing problems.

Name: Laverne Glover Title: Occupational Safety & Health Manager / COR Signature: