Special Notice To SSPC QP 1 And QP 3 Certified Contractors

SSPC auditors are continuing to place special emphasis on QP 1 and QP 3 audit evaluation items that deal with clarification of ambiguous, omitted or incorrect contract requirements as well as notation and documentation of non-conforming work/deviations from the specification.

If the contractor is authorized to perform work that deviates from the specification the contractor's quality control (QC) personnel and QC Manager must document that fact by obtaining written authorization or confirmation from the resident engineer or other authorized facility owner representative of any changes, revisions, modifications or clarification of ambiguities. This documentation must be available at the job site or quickly accessible to the job site (e.g. via email; fax, etc). Otherwise the auditor has the authority to issue a critical item deficiency which could place the contractor’s certification status at risk.

If the contractor was given a “verbal” OK but has not yet received written confirmation because the paper work hasn’t caught up or was told that there would not be any written authorization on the change, contractor QC personnel must document this by recording the who, what, when, where, why and how of the change. SSPC suggests you create and put in place a procedure for documenting “verbal” authorizations, if you haven’t done so already.

In addition, contractors must also document specification deviations in their daily QC/Work reports, regardless of whether the change has been documented or verbalized. These daily reports must also be available at the job site for the auditor to review.

Examples of specification deviations that auditors run into on job sites that are not always properly documented include but are not limited to:

• blast profiles outside of specified ranges
• coating thickness outside of specified ranges
• coating thickness not measured IAW PA 2 even though PA 2 is called out in the specification
• cleaning or coating outside of specified ambient condition ranges
• substitution of materials
• containment not designed or being operated according to approved plans
• omitting a process such as chloride testing or pressure washing before painting
• skipping a hold point inspection
• changing a process

Another area of concern is when the auditor observes obviously non-conforming work that is being accepted by the owner’s inspector or official representative. For example, if the specification calls for blast cleaning to SP-10 but the contractor is cleaning to SP-6, and there is no formal variance (written or “verbal”) on record allowing for the change, but the inspector is accepting the work, expect the auditor to ask for an explanation. The auditor may also report such a condition in the audit report as well as report the finding to the facility owner.