U.S. Department of Transportation
Federal Highway Administration
|Subject:||Information: Guidance for Plans of Corrective Action||Date:||January 3, 2017|
|From:||/Original signed by/
Joseph L. Hartmann, Ph.D., P.E.
Director, Office of Bridges and Structures
Federal Lands Highway Division Director
The following guidance was developed in response to a recommendation from the Program Management Improvement Team as an outcome of its review of FHWA's oversight of the National Bridge Inspection Program (NBIP) in 2015. The guidance will improve national consistency in the NBIP review process for the development and oversight of a Plan of Corrective Action (PCA). The attachment discusses durations of new, modified, and extended PCAs, coordination between FHWA offices, and approval and oversight responsibilities for PCAs.
Although this guidance is directed towards the NBIP, the same concepts will apply to the National Tunnel Inspection Program once it is initiated.
Please share this memorandum with appropriate staff and with all State DOT, Federal agency, and tribal government officials. Questions on the guidance can be directed to John Thiel at (202) 366-8795 or e-mail at John.Thiel@dot.gov or to Shay Burrows at (202) 366-4675 or e-mail at Shay.Burrows@dot.gov.
Directors of Field Services
Guidance for Plans of Corrective Action
Under 23 U.S.C. 144(h), FHWA must establish and maintain national bridge and tunnel inspection standards, including plans for corrective action (PCAs).
The Division Offices should work collaboratively with the State DOTs, Federal agencies, and tribal governments on the development of a new PCA if one of the following scenarios exists:
- An issue of non-compliance is identified for a metric previously determined to be Satisfactory.
- An existing PCA is in place, and a new issue of noncompliance is identified, independent of and not impacting the task and/or duration of the existing PCA. This scenario will result in more than one active PCA for a single metric.
Additionally, the Division Offices should work with their partners to modify or extend an existing PCA if one of the following scenarios exists:
- An existing PCA should be modified when new tasks are identified that are needed to address the same issue of noncompliance and do not impact the PCA's target completion date.
- If it has not been extended previously, an existing PCA may be extended when new tasks are identified that do impact the PCA's target completion date because the new tasks affect the completion date(s) of the existing task(s).
- If it has not been extended previously, an existing PCA may be extended when it is not on schedule due to lack of progress, with no likely method to accelerate progress enough to achieve the scheduled completion date.
- The expected duration for a new PCA is 12 to 36 months and will depend on the risk, size, and complexity of tasks to address the compliance issue.
- Compliance issues that are more complex, affect a significant number of bridges, or require extensive resources may require a new PCA duration of greater than 36 months, but should not exceed 60 months. An example of a compliance issue that would result in a lengthy new PCA is if the load rating calculations or scour analyses for all bridges in the State cannot be located, which would require a complete reevaluation of the bridge inventory.
- The new PCA should not exceed 24 months if a PCA was completed within the previous 12 months, and the new compliance issue is similar to the compliance issue addressed in the completed PCA.
- The new PCA should not exceed 24 months if a new law, regulation, or guidance effects NBIS compliance issues, and FHWA policy provides an implementation period which has passed.
- A PCA can be extended one time for up to 24 months, but the extension should not be greater than 50 percent of the initial PCA duration.
- A PCA can be modified multiple times with new tasks that don't affect the target completion date.
- The Bridge Safety Engineer must review all new, modified, and extended PCAs prior to the Division Office notifying the State DOT, Federal agency, or tribal government of approval.
- The Bridge Safety Engineer should be engaged early and throughout the PCA development process when it is anticipated that a new PCA duration may be greater than 36 months or an extended PCA may be greater than 50 percent of the initial PCA duration.
- The Division Office has discretion to extend a PCA by less than 6 months without review by the Bridge Safety Engineer. However, the Division Office must notify the Bridge Safety Engineer in advance. The Division Office may extend a PCA once in this manner, after which no additional extensions will be approved.
- The Bridge Safety Engineer must be notified before the penalty provision in 23 U.S.C. 144(h)(5) is invoked.
- The Division Office is responsible for approving the PCA after concurrence from the Bridge Safety Engineer.
- In addition, the Division Administrator/Director and the HIBS-30 Team Leader must approve any new PCA that is proposed to exceed 36 months or any extended PCA proposed for more than 50 percent of the initial PCA duration.
- The Division Office must review quarterly reports from the State, Federal agency, or tribal government.
- The Division Office must advise the Program Manager when two consecutive quarterly reports show a lack of progress towards completing the initial PCA or its interim milestones. The Division Office should work with the Program Manager to reestablish the original task schedule, or terminate the initial PCA and develop an extended PCA.
- When two consecutive reports show lack of progress during an extended PCA, and there is no acceptable proposal to reestablish the original schedule, FHWA will initiate the penalty process specified in 23 U.S.C. 144(h)(5).