Construction Program Management and Inspection Guide
Appendix B (Part 2)
Contractor Quality Control Plans: Contractor Guidelines and Example
Federal Lands Highway Office
Engineering and Operations Division (HFL-20)
These guidelines are intended to assist Federal Lands Highway (FLH) contractors in the preparation of acceptable Quality Control Plans. They are based on the requirements contained in Section 153 of the Standard Specifications for Construction of Roads and Bridges on Federal Highway Projects (FP). The guidelines are not contractual requirements and do not supplement or supersede any contractual requirements.
A contractor quality control plan (CQCP) is the documentation of the contractor's process for delivering the level of construction quality required by the contract. This document is intended to provide guidance to Federal Lands contractors, subcontractors, and suppliers as to what is expected from CQCPs and what the criteria for accepting and using the requirements for these plans will be.
The CQCP is a framework for the contractor's process for delivering quality construction. The plans and specifications define the expected results or outcome. The CQCP outlines how those results will be achieved. While it is not possible to determine from the CQCP whether the level of construction quality will be acceptable, it is possible to verify that the contractor, as an organization, has addressed the basic elements of its quality process. These guidelines address not only what should be in the CQCP in order for it to be acceptable to the Government, but also what elements the Government's QA process needs to have in order to assure quality without usurping the contractor's responsibilities.
It is not possible to determine from the content of the CQCP whether quality construction will result. The plan is not approved, but accepted based only on whether the plan clearly addresses all the issues it is required by the contract to address.
FAR and FP Requirements
Federal Acquisition Regulation (FAR) Clause 52.246-12, Inspection of Construction, is the foundation and basis for all contract requirements dealing with quality control and quality assurance. In summary, the clause has these provisions:
- Requires the contractor to maintain an adequate inspection system and perform inspections that will ensure contract compliance.
- Requires the contractor to maintain inspection records and make them available to the Government.
- Allows [but does not require or obligate] the Government to do its own tests and inspections and requires the contractor to assist.
- Says that Government tests and inspections are for its benefit and do not take the place of the contractor's quality control obligations.
- Says that anytime the contractor tells the Government that work is ready for inspection and it is not (i.e., it is in not in compliance), the Government may charge the contractor for the costs of its inspections and tests.
- Says that the contractor is obligated to comply with the contract whether or not a Government inspector is present.
- Says that the Government may order previously completed work torn apart for inspection, and that if it is not in compliance, the contractor will pay for the inspection and the correction of the work. If it is in compliance the Government will pay for the inspection and disruption to the work.
Note that nothing in the FAR clause requires that the contractor's inspection system be described in writing or that it be submitted to the Government for approval in advance of the work. These requirements are contained in FP-96, Section 153. In addition, Section 153 contains a basic outline of what should be included in the CQCP. The outline should be repeated for each major category of construction.
Outline of Contractor Quality Control Plan Requirements, FP-96, Subsection 153.02
- Process control testing. List the material to be tested, tests to be conducted, the location of sampling, and the frequency of testing.
- Inspection/control procedures. Address each of the following subjects in each phase of construction:
- Preparatory phase.
- Review all contract requirements.
- Ensure compliance of component material to the contract requirements.
- Coordinate all submittals including certifications.
- Ensure capability of equipment and personnel to comply with the contract requirements.
- Ensure preliminary testing is accomplished.
- Coordinate surveying and staking of the work.
- Startup phase.
- Review the contract requirements with personnel who will perform the work.
- Inspect startup of work.
- Establish standards of workmanship.
- Provide training as necessary.
- Establish detailed testing schedule based on the production schedule.
- Production phase.
- Conduct intermittent or continuous inspection during construction to identify and correct deficiencies.
- Inspect completed phases before scheduled Government acceptance.
- Provide feedback and system changes to prevent repeated deficiencies.
- Description of records. List the records to be maintained.
- Personnel qualifications.
- Document the name, authority, relevant experience, and qualifications of person with overall responsibility for the inspection system.
- Document the names, authority, and relevant experience of all personnel directly responsible for inspection and testing.
- Subcontractors. Include the work of all subcontractors. If a subcontractor is to perform work under this Section, detail how that subcontractor will interface with the contractor's and/or other subcontractor's organizations.
Unless the contractor already has a documented company QC plan, it may be helpful to discuss what is required and how detailed it will be. Generally, discussion of the basic who, what, where, when, and how should comprise three to six pages, with an additional two to four pages of detailed information for each major category of work. This is not including supplemental materials such as subcontractor/ supplier plans, certifications, test data, and personnel résumés. Also, if the QC plan contains a lot of repetitions of contract specifications, meaningless platitudes from quality textbooks, and other fluff, its necessary length will be longer.
Quality-and the processes that deliver quality-is a somewhat open ended concept. No matter how much detail is in the plan, it can always be argued that more could be, or should be, included.
One of the first issues a contractor or any organization must face when designing its QC/QA procedures, is how these systems will relate to and impact its organizational structure.
Separate Quality Staff. Testing is a very specialized function. A contractor may elect to hire a separate staff or subcontractor to perform testing and to generate the documentation required by the FAR Clause and the FP. But the testing and documentation are only part of the inspection system required by the contract. If the entire inspection system is performed by personnel separate from production personnel, that would mirror the traditional relationship between contractor and agency organizations. If a contractor has a separate quality staff, it is important to define the relationship between those personnel and the production organization. What will be the disposition of failing tests/inspections? Who will have authority to order production ceased? Under what circumstances? What will be the conditions of restarting production?
Combined Staff. Quality management experts generally discourage separating quality control personnel from production personnel. It pits one part of the organization against another. This built-in adversity is seen as both inefficient and requiring additional staff. Ideally, quality control should be achieved by developing an organizational culture which encourages quality-a culture which is embraced by everyone in the organization. However, for an organization transitioning from a traditional to a quality management system, superimposing a QC/QA staff on its existing organization may make sense while that organizational culture is being developed.
Process Control Testing
Testing provides a reflection of quality and the process. But only changes to the process can improve quality. Extensive testing needed to identify defects so that they can be corrected is an indication of a poor process. Ideally, frequencies of QC testing are dependent on characteristics of the overall process. In a transition environment, however, when contractors are not used to designing comprehensive QC systems, it may be necessary for the agency to provide guide frequencies to minimize the risk of serious deficiencies undetected until late in the process.
It is easy to become preoccupied with testing when describing the plan. Testing is easily defined and leaves a clear documentation trail. But the organizational resources that actually will control the quality of the construction are by far the most important part of the plan, even though describing these resources and procedures [the process] in writing is often difficult.
The contract may contain a listing of mandatory contractor testing including sampling points, frequencies, and time limits for delivering results. This testing is intended primarily for the agency's use in documenting quality assurance and accepting the work. Some contracts require additional testing identified as process control testing, which is intended to provide real-time information during the construction and production of materials to allow the contractor to adjust or control the process and ensure that quality assurance testing at the end of the process will indicate compliance. Whether or not the contract specifies process control testing, it is up to the contractor to address whether or not it is needed in the CQCP.
The standard acceptance plan in Section 106.05 of the contract is used for most pavement structure and structural concrete items. While much of the work is not accepted statistically, the criteria on which the statistically based plan is structured are consistent with the intended acceptance criteria of all work. In general these are the criteria:
- The plan is based on an acceptable quality level (AQL) of 5 percent defects. That is, if production is uniform and no more than 1 out of every 20 quality assurance tests fails, the process can be assumed to be in control and additional process control testing (and other actions) are not indicated.
- If defects rise to 10 percent (1 out of 10 QA tests fail), that suggests additional process control testing and other actions may be indicated.
- If defects rise to 15 percent or higher (more than 1 out of 6 QA tests fail), that is approximately equivalent (depending on sample size) to a pay factor of less than 0.90. This indicates serious process control problems, and the Government may require that process to be suspended while the contractor modifies the process control procedure (including testing) to address the problem.
In addition to those tests specifically required by the contract, the contractor is required to tabulate in the CQCP all process control testing which will be necessary to assure that the work and material comply with the terms of the contract when they are ultimately subjected to quality assurance testing. Note that, although process control testing is listed first in Subsection 153.02, it may make more sense to not complete or finalize this section until after the inspection/control procedures are defined.
This is the narrative portion of the CQCP, and it is the hardest part of the plan to develop and describe. Most organizations are used to intuitive processes, or processes that have evolved over time to reflect the personalities and desires of supervisory personnel. Describing and documenting these processes concisely in writing is often difficult. There is almost no physical limit to the length and detail included in this section. Every requirement, every sentence in the contract, could precipitate a paragraph or more of detailed process control procedures to describe how that requirement will be fulfilled. From a practical point though, this is excessive. For most typical FLH construction projects, the narrative covering inspection/control procedures should adequately address the quality process basics in two to four pages for each phase of construction (see below). This does not include testing schedules, certifications, personnel résumés, and other attachments. In addition, if the narrative includes excessive redundancies, paraphrasing of the contract, and other extraneous materials, these will add to the required length. The fact that many of the detailed requirements of the contract are not specifically addressed in the CQCP does not mean they can be ignored. The contract itself is the foundation for the outcomes expected from the CQCP.
The failure of the contractor to inspect and control any aspect of the construction process, whether or not it is specifically addressed by the CQCP, is a basis for adverse action under the contract, which may include required enhancement to the CQCP itself.
Categories of Construction
A typical contract may be divided into three to five categories depending on the nature of the work and the organizations performing the work. These categories are referred to as phases in Subsection 153.02, but to avoid confusion with sequential phases described below, they are referred to as categories here. For example, stakeout, erosion control, clearing, excavation, embankment, drainage, and slope protection might be grouped together as a single category of Grading and Drainage.
Sometimes how categories are defined is influenced by which subcontractors or crews do the work, since each may have its own organizational relationships. It should be left up to the contractor to group items of work in logical categories to facilitate the development of the CQCP. Typical categories are as follows:
- Grading and Drainage
- Pavement Structure
- Permanent Traffic Control
- Safety Appurtenances
- Seeding and Landscaping
- Temporary Traffic Control
Preliminary, Startup, and Production Phases
The FP requires each of the three sequential phases to be addressed separately. So for five categories of construction, a five by three matrix is generated which constitutes the inspection/control part of the CQCP.
The preliminary phase includes evaluation of equipment, materials, and other resources prior to work being started. It also involves comparing contract requirements with training and other needs.
Startup includes the additional management, training, and inspection resources usually needed when a new operation is started.
Production addresses the routine QC resources necessary after the process is established.
Who, What, Where, When, and How?
For each category and phase of the operation, the QC plan should answer these questions as they relate to the category and phase:
Who will be responsible for QC during the operation? The Quality Control Technician may be assigned responsibility for testing and documentation and perhaps even training and monitoring of startup. As the operation moves toward production, however, foremen or other supervisory personnel will probably be assigned increasing responsibility. If the management official is too high in the organization-say the overall project superintendent-then it is less likely he/she will have the time to perform detailed QC functions. In that case, subordinate personnel should be specifically identified.
What will that person do to ensure contract compliance? What authority will the person have over operations? What portion of the time the operation is in progress will the identified person actually be present to perform QC responsibilities? Testers and inspectors cannot control quality if their responsibilities are limited to testing, measuring, and documentation. "What" should address not only personnel but materials and equipment used in the construction. These items often have stated or implied contract requirements, and the QC system must verify that those requirements are met.
Where will these activities be performed? Will optional process control testing be performed on-site or at a commercial laboratory? Will manufactured materials be inspected at the plant, at the contractor's facility, or at the site of work? Will the equipment be inspected at the yard, or will inspections be performed at the site?
When will these activities be performed? The earlier QC activities are performed, the more latitude the contractor has in dealing with problems. However, when activities are performed too early, there is a risk of unforeseen changes or glitches prior to actual construction. When will test results be available? This is a key component of the QC plan that determines largely how responsive it can be to deficiencies.
How will inspections be performed? Using a standard checklist? Using the specifications themselves (quality assurance criteria), etc.? The more generalized and vague the inspection procedures are, the more likely they will not be consistently effective. However, not having a checklist is not a cause for disapproving a QC plan unless a checklist is specifically required.
The CQCP should minimize any parroting or paraphrasing of requirements in the contract, and should avoid simply promising to comply with the contract. These kinds of statements and assurances are of essentially no added value. The CQCP must go beyond the contract requirements and address the contractor's organizational process for consistently delivering those requirements.
Subcontractors and Suppliers
When subcontractors and suppliers (other than suppliers of commercial items) provide part of the work, then the QCP needs to be clear whether their QC responsibilities will be independent or a part of the prime contractor's responsibilities. If they are independent, then the subcontractors or suppliers QCP must be developed and submitted for approval, through the prime. Otherwise, the prime must address how it will monitor and verify subcontractor/supplier quality as a part of its plan. In either case the prime is contractually responsible for all the work, but being contractually responsible is not the same as having an active role in the quality delivery process.
An important part of the CQCP is the process for verifying that manufactured materials comply with the requirements of the contract.
Commercial Items. These are materials manufactured and sold to the general public, as opposed to materials made to the unique specifications of the agency. For most commercial items, the contractor's responsibilities are limited to verification that the materials are as required or permitted in the contract, and that the delivered materials are in fact those approved materials. Some materials which are arguably commercial are considered of critical importance and have specific QC/QA requirements in the contract.
Noncommercial Items. These are materials manufactured offsite, but specifically to agency specifications for this project. QC plan coverage for noncommercial items should be a separate document from the manufacturer, or the manufacture of those items should be included in the QC plan of the contractor or a subcontractor. Like critical commercial items, critical noncommercial items may have specific QC/QA requirements in the contract.
Records and Documentation
While good documentation is often a reflection of good quality control, documentation is not the same thing as quality control. Documentation should be the minimum necessary to concisely document the adequate function of the process.
While some contracts may have specific required qualifications for contractor quality control and testing personnel, the initial judgment as to whether a given person is or is not qualified is generally left to the contractor. However, during contract administration, the agency may be more assertive in monitoring the qualifications of these personnel. When the contract has specific experience requirements, the contractor should describe how the person's previous training and experience addresses these requirements.
It is possible that subcontractors, suppliers, and overall responsibilities for some latter phases of the construction will have not been arranged at the time the prime is ready to begin on the initial phases. It is permissible for the contractor to submit, and the agency to accept, a partial plan. However, the work not covered by the plan may not begin until the plan is supplemented to cover that work.
The performance of all contractors is required to be evaluated in accordance with FAR 36.201. Although most contractors are evaluated as satisfactory or better, it is important to understand the agency's process for dealing with serious or chronic unsatisfactory performance. Evaluations are made of five individual elements, plus an overall evaluation:
- Quality of Work
- Timely Performance
- Effectiveness of Management
- Compliance With Labor Standards
- Compliance With Safety Standards
The first of these five elements, Quality of Work, essentially overlaps the contractor's inspection system requirements under FAR Clause 52.246-12, Inspection of Construction. That is, a contractor that fails to maintain an effective quality control (inspection system) will generally warrant an unsatisfactory rating in the Quality of Work category. Deficient contractors must be clearly notified of the deficiencies and provided an opportunity to correct them.
Evaluations may be shared with other contracting agencies and private entities. FLH Divisions may participate in the Corps of Engineers' Construction Contractor Appraisal Support System (CCASS), which makes evaluations available to other participating Federal agencies.
Evaluations may be used in part for determinations of responsibility prior to award of sealed bid contracts or in evaluating past performance as a part of source selection for a negotiated contract.
If the prime contractor's performance would be evaluated as satisfactory but for the performance of a major subcontractor, it is permissible to execute a separate evaluation of the subcontractor, following the same rules as if it were a prime.