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Quality Assurance in Materials and Construction

Observations and Recommendations

Observation #1: Agency emphasis and dedication of resources in the QA area is not commensurate with the level of investment and risk.

As noted in the Purpose of Review section of this report, over the last 10 years an average of
75 percent of the Federal-aid program was affected by the QA program. With organizational restructuring and the changes brought about by the legislation in the 1990's, FHWA's traditionally very strong role in QA shifted and other priorities emerged. As the Agency moves towards risk-based decision processes, the level of investment and the related risk in the materials and construction area dictate a re-focusing of FHWA's efforts in QA.

Prior to the 1990's, the Division Offices had direct oversight and responsibility for the majority of Federal-aid construction projects occurring at any given time. Area Engineers checked materials test results, delivery tickets, Independent Assurance results, quality of inspection, etc. Regional Office, and occasionally Headquarters, engineers would periodically review the Division Office activities and would conduct, or assist with, process reviews covering QA-related topics. This amount of hands-on involvement was indicative of the emphasis and resources the Agency devoted to QA, with the clear goals being the construction of high-quality, long-lasting projects and assuring the appropriate use of taxpayer funds.

When the ISTEA legislation brought about the concept of "exempt" projects, FHWA became less involved at the project level, which was to be complemented by increased involvement at the program level. Formal Agency goals and performance expectations in the QA area have been limited which has resulted in a lack of clarity for managers when they are distributing their available resources and also a lack of clarity for staff-level engineers as they assess what level of time and effort they should be devoting to QA activities. The closing of the Regional Offices and the reduction of reviews by the Headquarters Office has exacerbated this lack of clarity. Four of the seven Division Offices noted the need for more explicitly defining the role of QA in the context of the FHWA culture.

In 2002, safety, congestion mitigation, and environmental streamlining coalesced into FHWA's Vital Few. These quickly became high priority areas with a great deal of Agency resources devoted to achieving identified goals in each area. Performance expectations and managerial emphasis on the Vital Few are readily apparent at all levels of the Agency. Three Division Offices explicitly stated that QA is interwoven with the Vital Few and that having solid QA programs at the State level, supported by appropriate levels of FHWA QA activities, significantly supports the accomplishment of the goals of the Vital Few. This theme was echoed throughout each of the reviews and is supported by the Team. Increasing the emphasis on QA by establishing performance expectations at all levels of the Agency will enhance Vital Few activities and will also support the accomplishment of several goals included in the FHWA Strategic Implementation Plan.

In recent years, the mantra of "Get In, Get Out, and Stay Out" has been promoted to demonstrate the public's desire for longer-lasting highway projects. As traffic volumes continue to increase, and the associated user costs of construction congestion continue to spiral upward, the need for longer-lasting facilities is paramount. Tremendous amounts of research funding has been dedicated to developing improved materials such as Superpave hot-mix asphalt, high performance concrete, and high performance steel. Without proper acceptance testing and inspection, the public will not fully realize the increased service life that these improved products are capable of providing.

A 2006 national appraisal and evaluation 1 performed by FHWA's Office of Infrastructure of 20 State pavement preservation programs found that in nearly all of the States reviewed, pavement design lives are not being achieved in practice. In fact, it is very common to find both flexible and rigid pavements that last only a fraction of their design lives. The Pavement Preservation Report did not identify the factors that may have accounted for the shortened longevity of new pavements, but it's reasonable to assume that one of the contributors is insufficient emphasis on proper quality assurance procedures during construction. This truly is an area where "back to the basics" offers ample benefits. A decrease in QA emphasis at the Federal level leads to a decrease at the State level which, inevitably, leads to lower quality projects and continued erosion of the transportation infrastructure.

One theme that emerged during our interviews was the topic of regulatory compliance. As contemplated in 23 CFR 637, the goal of a QA program should be to effectively provide assurance that the quality of the finished product is what it should be; compliance with the regulation is also a priority. It is currently possible to have a QA program that is effective but does not comply with the regulation. Conversely, it is also possible to have a QA program that is compliant with the regulation but is not effective. The Team believes that a clear managerial message about QA, including performance expectations, will lead to States and Division Offices being more apt to comply with the intent of the regulation in developing and implementing effective QA programs.

As FHWA and the States have sought out new ways to maximize efficiency in delivering the highway program, new areas of risk have arisen. In 1995, 23 CFR 637 was re-written to allow contractor test data to be used in the acceptance decision. While the regulation and Technical Advisory 6120.3 identify the need for controls to be in place, the overall concept increases the risk to public funds. Thirty-four States now use contractor test results in the acceptance decision. Many of these States are using these results not only for pass/fail acceptance but also when determining pay factor adjustments; essentially, contractor data are being used to determine incentive or disincentive payment. This is made even more significant by the fact that these pay adjustments are most often applied to hot mix asphalt, concrete, and earthwork items, often representing the highest percentage of cost on a project.

Using contractor test results in the acceptance decision can be particularly appealing to States facing a loss of expertise due to retirements and personnel reductions driven by budget issues at the State level. State DOT managers may feel they are able to reduce their workload by shifting the testing burden onto the contractors. However, States are increasing the risk to Federal-aid funds by not establishing sufficient controls, as envisioned in the regulations. In 2000, the Office of Infrastructure initiated a series of reviews of State DOT QA programs with 3-4 States reviewed each year. 2 Significantly, the Infrastructure reviews found that many State systems used to validate contractor test data need to be strengthened. The reviews noted many critical deficiencies for using contractor test data, such as the lack of independent sampling for verification tests, inadequate statistical comparisons of test results, and insufficient State control of test samples, sampling locations, and testing data. Of the 15 States reviewed that used contractor test data in the acceptance decision, only 5 were found to have "reasonably good" systems in place to validate the contractor test data. The inherent risk is obvious since the procedures and controls envisioned in the regulations are not in place.

With 75 percent of the Federal-aid dollars exposed, the potential for and the risk of fraud is substantial. The FHWA has seen an increase in suspension and debarments in the last few years related specifically to materials. 3 From 1996 through 2004, FHWA had processed a total of 3 materials related suspension and debarment actions. In 2005 alone, there were 2 of these types of actions processed and in 2006 this figure had risen to 6. In addition in 2006, 3 cases have been settled without suspension or debarments and negotiations are currently underway on one case settlement that would result with no debarment or suspension. These are clear indicators of risk exposure for FHWA and the associated funds.

The recent, highly publicized, issues on the Boston Central Artery/Tunnel project are indicative of the level of risk and the potential consequences of short-comings in QA systems. The consequences go beyond the exposure of funds noted above. The fatality that resulted as a result of the partial collapse of a tunnel ceiling has shaken the public's trust. The indictment of six individuals related to substandard quality concrete being provided throughout the project has further damaged the public's faith in Government's ability to effectively monitor construction projects and assure effective use of taxpayer funds.

Each of the issues discussed in this section demonstrates the need to increase FHWA's emphasis on QA. The FHWA management has been successful at establishing a focus on the Vital Few and FIRE through the messages they deliver to all employees and, every bit as importantly, by the establishment of performance objectives and accountability throughout the Agency. The QA is key to the accomplishment of FHWA goals and the Agency needs to take a similar approach to QA as it has to the Vital Few and FIRE.

Recommendation #1: The FHWA senior management and Division Office leadership should develop Agency and individual performance objectives to increase accountability for the QA program equal to the level of investment and risk.

1 Pavement Preservation Technical Assistance Appraisal and Evaluation of State Programs – Interim Report, Federal Highway Administration, Washington, DC, Draft December 2006.

2 Quality Assurance Stewardship Review - Summary Report for Fiscal Years 2003 Through 2005, Federal Highway Administration, Office of Pavement Technology, Washington, DC, https://www.fhwa.dot.gov/pavement/materials/stewardreview2006.cfm, 2006.

3 This information has been derived from a summary based on a review by the Federal Highway Administration, Office of Infrastructure of the administrative records and FHWA Notices N2000.485 to N2000.582, Federal Highway Administration, Washington, DC.

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Updated: 06/27/2017
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