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QUALITY CONTROL AND QUALITY ASSURANCE: DEFINING THE ROLES AND RESPONSIBILITIES OF THE CONTRACTOR’S QC AND THE OWNER’S QA Alison B. Kaelin, Corporate Quality Assurance Manager KTA-Tator, Inc. Pittsburgh, Pennsylvania, USA Abstract: With the success of the SSPC painting contractor certification programs (PCCP) and increasing Owner requirements for both quality control (QC) by the contractor and quality assurance (QA) by third party inspectors, there is more confusion than ever over which types of inspections, and to what level of detail, should be performed by whom. This paper reviews and discusses the SSPC PCCP criterion applicable to QC and QA, specifications and other industry standards that address QC and QA, and provides an approach to the appropriate division of hold point inspections and documentation responsibilities of QC and QA to achieve the maximum benefit of the quality process. Introduction Every painting project begins with the expectation that the result will be a painted structure that will be protected for a minimum period of time. In order to achieve that goal, Owners rely on a variety of tools such as the specifications, contractor certification, quality control, and quality assurance inspection (either internal or third party) to verify that the work is performed as specified. While many projects require quality control and/or quality assurance inspections, few if any, differentiate between the roles of quality control versus quality assurance or provide guidance on the responsibilities of each.

This paper discusses the difference between the functions of quality control and quality assurance, reviews the SSPC certification program requirements, other recognized industry standards and transportation specifications that establish minimum standards of practice for quality control and quality assurance qualifications, inspections, and documentation. It concludes with recommendations to Owners and others on how to maximize the benefits of quality control and quality assurance inspections. Evolution of QC and QA in the Coatings Industry When the coatings inspection industry began to evolve in the 1970’s, there was little distinction between the roles of QC and QA. Most early coating inspection was performed as a response to the inspection parameters established in the nuclear power industry and ANSI/ASME N45.2.6, “Qualification of Inspection, Examination and Testing Personnel for Construction Phase of Nuclear Power Plants” and ANSI N101.4, “Quality Assurance for Protective Coatings Applied to Nuclear Facilities. These standards defined the qualifications of coatings inspectors and coating inspection tasks that were required during installation or maintenance to nuclear power-generation facilities. ANSI N45.2.6 specifically applied to third party inspectors retained by the Owner, performing hold point inspection of contractor activities. As coating inspection expanded beyond the nuclear

power arena and into other industry segments like transportation and water storage and supply, most Owners continued to rely on third party inspection to verify that contractor activities were performed according to the specification. That is, the Owner’s representative often performed all of the testing required at inspection hold points. In the 1990’s and 2000’s, with the increased recognition of the International Standards Organization (ISO), American Society of Quality (ASQ), and other certifications, more and more Owners, consultants and contractors started moving to the concept of a total quality system involving a clear division between QC and QA responsibilities. Owners began to recognize that while third party inspection was still necessary, it was not intended, nor desirable, for the Owner’s inspection to replace QC by the contractor. Unfortunately, this awareness was not always transferred to the specifications as specific QC requirements. The result is that QA personnel are continuing to provide the primary role of inspecting and accepting the work. When the roles of QC and QA personnel are not defined, the loss of a critical component of a total quality system results and often creates a confrontational position between QA personnel and the contractor. On the other hand, when the QC and QA personnel both perform their respective roles during coating system installation, the quality of the end product improves. Due to the improving understanding of quality systems, more and more organizations and end users are attempting to better define their expectations for both the QC and QA. Defining The Difference

Quality Control (QC) is performing the necessary observations, testing and documentation that verifies the work performed meets or exceeds the minimum standards established by the project specifications or contract. Quality control involves the routine and systematic inspections and tests that are conducted to verify that each phase of the work is in compliance with the specification. Quality control is the contractor’s responsibility. Quality Assurance (QA) is the process to verify that the quality of work performed is actually what was reported by quality control. Quality assurance is an audit function, used to verify that quality control is being performed and performed properly. It may include review of QC documentation or conducting actual testing on a spot or periodic basis. Quality assurance is typically performed by the Owner or a third party inspector on the Owner’s behalf. In simple terms, the contractor is fully responsible for every aspect of the project from the equipment and materials, and experience and training of personnel, to the quality of the final product. Quality control by the contractor is meant to provide in-process verification that the cleaning and painting is being performing as designed to provide a quality final product. Quality assurance by the Owner is meant to verify that the quality control implemented by the contractor meets the requirements of the specification, to further assure that a quality final product will result. QC is a full-time requirement and has responsibilities for every aspect of the surface preparation and painting process. QA can be full or part time or performed at specific stages (e.g., following surface preparation) of the painting process to verify

the adequacy of the contractor’s QC. When the Owner does not perform QA or provides limited QA inspection, half of the total quality management process is lost. Both QC and QA are necessary components to verifying specification compliance and quality workmanship, but the presence of the Owner (or third party inspector) performing QA on a project does not relieve the contractor of the responsibility of performing QC. While not the focus of this paper, it cannot be forgotten that QC is more than the performance and documentation of inspections. The quality control process includes procedures for verifying that specifications, product information, and revisions are communicated to the job site; verification that the equipment and standards employed to perform QC are functional, correct and traceable; and procedures for documenting and resolving deviations, non-conformance and corrective actions. Control of Work The difference between QC and QA relative to the control of work is also critical. Only the QC has the authority to direct the contractor’s employees or production operations. When a contractor is required to retain an 3rd party QC representative, the QC will not be a direct employee of the contractor and may not have the ability to direct or ensure implementation of corrective actions on the part of the contractor’s personnel. A similar situation may occur when the Owner requires the coating manufacturer to perform QC functions on the job site through the technical representative. It must be recognized that this approach does not have a contractual relationship, observations may not be free of bias, may result in conflicts

between the manufacturer and contractor, and does not provide either a QC or QA function. When the Owner performs his own QA (with direct staff), he has a contractual relationship with the contractor, and therefore can exert control through the contract (or by withholding payment or stopping work) when operations or conditions are non-conforming. When an Owner subcontracts third party QA, the third party QA does not have a contractual relationship with the contractor; therefore, the third party QA typically can only advise and document the non-conformance of the contractor’s operations and advise the contractor’s QC or the Owner. If the contractor fails to correct the non-conformance, the Owner must decide whether to stop work, withhold payment, accept the non-conformance or take other action. Both the Owner and the third party QA representatives must be careful not to direct or unduly interrupt contractor operations due to potential contract issues regarding control of the work and costs related to work stoppages. Sequence of QC And QA Inspections The specific duties of QC and the QA personnel will vary from project to project. The coating inspection process typically dictates that after certain activities (e.g., surface preparation), work should be inspected, rework performed as necessary, and the surfaces accepted by QC and QA before the contractor can move on to the next step of the maintenance painting process. These specific inspection items are typically referred to as “hold points.”

A rule of thumb is that the QC inspection of each hold point should occur first and any non-conforming items identified by QC should be corrected, reinspected and accepted by the QC. The QA inspection should only occur after the work (hold point) has been inspected and accepted by the QC inspector. The QA inspector should then verify that the work that the QC inspector accepted meets the requirements of the specification. If the QA inspector identifies non-conforming items, they should be repaired and re-inspected by the QC inspector before the QA inspector accepts the work and the contractor proceeds to the next step of the painting process. It is often helpful, if not necessary, to have the QC inspector and the foreman present during the QA observations, so that any deficiencies can be identified and confirmed by all parties. This also allows QC and the foreman to clearly identify areas requiring rework to the laborers and reduces delay of production activities. The QA process typically includes both a review of tests or documentation provided by QC and duplicate inspection or testing of certain hold points (e.g., dry film thickness measurements) as an audit function to verify that the results reported by the QC are accurately reflecting the quality of the work. When results of QC and QA inspection differ, the QA observations typically supersede those of the QC. The actual resolution of differing QC and QA observations should be defined in the project specification or discussed and agreed upon by all stakeholders in the pre-job meeting. SSPC’S Approach to QC And QA Responsibilities

SSPC Qualification Procedures for Quality Control (QC) SSPC: The Society for Protective Coatings (SSPC) has established four (4) qualification procedures for contractors that include minimum requirements for quality control (QC). Qualification Procedure No. 1, Standard Procedure for Evaluating Qualifications of Painting Contractors (Field Application to Complex Structures),” better known as QP-1, establishes specific requirements for the qualifications and duties of the contractor’s QC personnel on field coating application projects. QP-3, “Standard Procedure for Evaluating Qualifications of Shop Painting Applicators,” QP-8, “Standard Procedure for Evaluating the Qualifications of Contracting Firms that Install Polymer Coatings and Surfacings on Concrete and Other Cementitious Substrates”, and QP-6, “Standard Procedure for Evaluating the Qualifications of Contractors Who Apply Thermal Spray (Metallizing) for Corrosion Protection to Steel and Concrete Surfaces,” have similar QC requirements. QP-6 requires the contractor to be either QP-1 or QP-3 certified to supplement the procedure. Each of the contractor qualification standards identifies minimum requirements relative to quality control personnel, programs, inspections and documentation. The following provides a brief review by key topic. While the specific duties of the QC are not well defined in the SSPC QP-1, QP-3, QP-8, and QP-6 standards, the supporting documentation required by the respective standards (i.e., QC program application, audit criterion) provides additional insight on the requirements for the contractor’s QC. Minimum QC Qualifications Under QP-1 and QP-3, the QC Supervisor is responsible for oversight of

the QC inspectors. The QC Supervisor is required to have 3 to 5 years experience and formal training (the content and duration are not specified). The QC Inspector is to have a minimum of 2 years experience and formal training for QP-1; however QP-3 allows the QC Inspector to substitute in-house training for formal training. QP-8 requires the QC Manager and QC Inspectors to have 2 years experience, eight hours of general QC training and 16 hours of concrete training. QP-6 refers to the Thermal Spray Supervisor (TSS) and Thermal Spray Inspector (TSI) rather than QC. It requires the TSS to have minimum of two years experience (or one year experience and formal training in SSPC C-7) and qualification under internal programs defined by AWS and SSPC. The TSI must be internally qualified to perform thermal spray inspections. It should be noted that there is no established curriculum, duration, or evaluation of knowledge or practical testing required under the QP-1 and QP-3 standards. Refresher training is not required by QP-1, QP-3, QP-8, or QP-6. Written Procedures / Quality Manuals QP-1 requires the contractor to have written procedures to ensure that major operations (surface preparation, primer, intermediate and top coat applications) are inspected. It suggests that these procedures are components of a “QC Manual.” QP-3 simply requires the QC to have relevant inspection standards. QP-8 specifically details that standard operating procedures (SOPs) must be included in the contractor’s QC manual and delineates the specific procedures requiring SOPs (e.g., moisture testing in concrete). QP-6 requires the contractor to have formal written procedures for performing and documenting inspections.

Authority of the QC / Management QP-1 requires that there is written authority for the QC Inspectors to report directly to management and have stop work authority for non-conforming work. QP-3 is similar but adds that there must be evidence that the QC Inspector reports directly to management, not any production-related Supervisor or Manager. QP-8 and QP-6 do not define the authority of the QC. QP-6 does require the TSS to be involved in material and equipment decisions and to be on-site during all surface preparation and thermal spray applications. QC Inspection Hold Points QP-1 does not define the specific hold points to be reviewed by QC. However, the SSPC QP-1 Annual Internal Audit Report / Checklist for SSPC Certified Contractors (Rev 02/04), indicates that hold point inspections are to be conducted during each major operation. It states that examples of hold points include: precleaning, surface preparation, primer, intermediate coat, top coat application, and cure. QP-3 defines hold points during: 1. 2. 3. 4. 5. 6. 7. 8. 9.

receipt of items to be coated inspection of repaired and coated items storage of repaired and coating items surface preparation storage of coating materials handling repair labeling handling and shipment

QP-8 requires hold point inspections based upon the detailed requirements of the QC plan. QP-6 requires hold point inspection for major operations defined as

surface preparation, acceptance, thermal spray (primer) application, seal and subsequent coating application.

QC on projects than is addressed in the QP standards. This standard must be specified in addition to the applicable QP standard.

Documentation / Reports QP-1 does not define the information that must be documented by the QC. The SSPC QP-1 Annual Internal Audit Report / Checklist, specifically requires that the QC prepare daily reports that include the following information (at a minimum):

Minimum QC Qualifications QS-1 requires the contractor to employ a QC Manager reporting directly to management that is an SSPC PCS, NACE Certified Coating Inspector or holds a BS degree in materials science or corrosion engineering. QC Inspectors must have successfully completed NACE CIP Level I and confirm visual acuity through testing every ten years.

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12.

compressed air cleanliness dry film thickness air temperature humidity dew point surface temperature abrasive cleanliness degree of cleanliness achieved surface profile batch numbers of paint used batch numbers of thinner used mixing according to specification

QP-3 provides a similar list; however, it adds wet film thickness and the type and amount of thinner used. QP-8 does not define the information to be recorded other than a reference to the QC program requirements. QP-6 requires documentation of the hold point inspections performed on major operations. SSPC QS-1, Standard Procedure for Evaluating a Quality Standard of Contractors That Apply Protective Coatings and Linings SSPC has prepared the above standard for inclusion in the 2005 SSPC Volume 2, Systems and Specifications. It provides a supplemental standard (QS-1) for use by Owners that require a higher level of

Written Procedures / Quality Manuals QS-1 requires implementation of a quality system rather than simply a QC manual. The written quality control manual must follow the guidelines of ANSI Q10013, “Guidelines for Developing Quality Manuals.” The QC Manual should include procedures for control and distribution, the general scope of inspections, equipment calibration up-todate reference and testing procedures. The quality system and manuals must include quality planning and development of specific work plans, procedures for project document review, document and data control, and internal review. Authority of QC / Management QS-1 requires written documentation of training of managerial staff and demonstrated management review of fieldwork and QC documentation. It requires that a designated replacement be provided should the QC Manager be absent. Inspection Hold Points QS-1 recommends that the contractor provide a project-specific work plan defining the inspections, reference standards, and documentation required by the specification. It requires that the work

plan be maintained on-site and be available for review. Documents/Reports QS-1 requires that results of all inspections and tests be recorded in a written report and adequately describe areas tested, testing performed, reference methods, results and signatures. Additional QS-1 Requirements QS-1 introduces several other requirements that are not included in the QP standards for contractors. The include: Program Review – QS-1 requires annual written review of the QC Manual by the QC Manager to the management. Review of Documentation – QS-1 requires periodic internal review of QC documentation by the QC Manager. Resolution of Client Complaints – QS-1 requires that the QC Manual include a policy to address the investigation, auditing, and resolution of client complaints. SSPC 03-14, Chapter 3, Quality Control for Protective Coatings Projects The SSPC Publication, “The Inspection of Coatings and Linings, A Handbook of Basic Practice for Inspectors, Owners, and Specifiers,” 2nd Edition (SSPC 03-14), Chapter 3, Quality Control for Protective Coatings Projects, provides recommended practice for individuals involved in quality control inspections and features a series of recommended coating inspection forms. Chapter 3 suggests the QC inspector should also maintain a daily work log that identifies the duties performed each day, non-conforming items, and supplemental information that cannot be recorded on standardized forms.

Chapter 3 provides two (2) specific forms to assist the QC in documenting the recommended hold point inspections. Form 4 is a daily coating inspection form and Form 5 is a dry film thickness measurement worksheet. Forms are appended with permission from SSPC. SSPC Qualification Procedures for Quality Assurance (QA) SSPC has one qualification procedure applicable to QA: Qualification Procedure No. 5 (QP-5), “Standard Procedure for Evaluating Qualifications of Coating and Lining Inspection Companies.” The SSPC QP-5 program establishes a certification for inspection companies whose focus is the industrial coating and lining industry. It evaluates an inspection company's ability to provide consistent quality inspection of coatings & linings for its clients (typically third party QA). Like the portions of the SSPC QP certifications related to QC, QP-5 provides minimum requirements relative to the qualification of quality assurance personnel, programs, inspections and documentation. The new QS-1 incorporates many QP-5 requirements. Minimum QA Qualifications QP-5 requires the company to employ a Total Quality Manager that reports directly to the president or management team. The TQM must have a minimum of 10 years experience and be a SSPC PCS, NACE Certified Coating Inspector or hold a BS degree in corrosion science or engineering. Inspectors employed by a QP5 certified company are divided into three levels of responsibility primarily based upon experience and education. Level I is the lowest and Level III the highest. Level I requires a high school diploma and 6 months experience in Level I

skills or an Associates degree or higher and 3 months experience in Level I skills. Level II requires a high school diploma, 1 year experience in Level I skills and qualification as a Level I or a high school diploma plus 3 years experience in the duties of a Level I or an Associates degree or better and 1 year experience in the duties of a Level I or a Bachelors of Arts or Science and 6 months experience in the duties of a Level I. Level III requires a high school diploma and 6 years of Level II qualification or a high school diploma and 10 years of Level II experience or an Associates degree and 7 years experience as a Level II, or a Bachelors of Arts or Science and 5 years experience as a Level II. At minimum, all QA Inspectors must successfully complete a written coating inspection training course. In additional to coating inspection training, QA Inspectors are required by QP5 to undergo annual physical testing for near distance acuity (vision) and color perception and annual coating inspection refresher training. Written Procedures / Quality Manuals QP-5 requires participants to develop a complete quality system that addresses: 1. 2. 3. 4.

Quality Policy and Management Commitments Organizational, Management Structure, and Reporting Relationships Procedures for performing coating inspections and tests References to inspection equipment, calibration, maintenance and measurement standards

5.

Internal audit procedures and schedule

The program must be reviewed annually and documented by a written report to management on its effectiveness and suggested changes. Management of QA QP-5 requires that the total quality manager audit the QA inspection staff and provide oversight of the implementation of the quality system. In addition, QP-5 requires participants to train auditors and perform auditing of the implementation of the quality system (i.e., Quality Assurance/Quality Control Procedures of Coating Inspection). Hold Points Requiring QA Inspection QP-5 does not define which hold points should be inspected by the QA; rather it states that the scope of QA inspections are dictated by contract. Documentation / Reports Similar to the above, QP-5 does not specify the documentation required to be maintained by the QA. However, Section 11.0, Certificates and Reports provides a format for written QA inspection reports. Additional QP-5 Requirements QP-5 places several additional requirements on QA that are not included in contractor QP programs. Internal Audits – Internal audits are required to be performed on a minimum number of QA projects. Internal auditors must complete a formal auditor training program and be qualified as Level II Inspector or higher.

Internal Review of QA Reports – QP-5 requires a process for reviewing QA inspection reports internally by a competent supervisor. Annual Refresher Training & Visual Testing – Inspection personnel are to be provided annual refresher training in inspection practices and standards and tested for visual acuity annually. Resolution of Client Complaints – QP-5 participants must have a policy to address the investigation, auditing, and resolution of client complaints. Table 1 (at the end of this paper), summarizes the differences between the QP1, QP-3, QP-8, QP-6, QS-1, and QP-5 standard requirements relative to QC and QA. Planned 2005 SSPC Actions Related to QC and QA SSPC has indicated that in early 2005 it will convene a meeting with all auditors to discuss and resolve auditing discrepancies within the certification programs. SSPC will also be introducing in early 2005, an on-line training program for QC Managers and Supervisors for contractor QP certifications. The training will focus on procedural requirements of the programs including equipment calibration and traceability, required documentation, and resolution of specification deviations and non-conformance. It is expected that this will become a requirement for the QP certifications. Other Organizations Defining QC And QA Responsibilities

NACE Coating Inspector Training and Certification Program Qualifications of Inspection Personnel The NACE International Coating Inspection Program (CIP) began certifying coatings inspectors over 20 years ago. The CIP establishes three levels of certification for individual coatings inspectors (regardless of whether they perform QC or QA). Level 1 – Requires successful completion of a one-week training session. Level 2 – Requires successful completion of a second one-week training session. Certified Coating Inspector – Requires successful completion of Level 1 and Level 2, a peer review, and 2 years of verifiable coatings-related work experience. The peer review consists of a 2-hour oral examination administered by a 3-member review board. Hold Points The NACE training provides a comprehensive review of the observations, tests and examinations that may be performed by a coating inspector during the coating process but does not define them relative to QC and QA. The NACE International Coating Inspector Training and Certification Program Session I – Student Manual (7/1/98), “The Coating Inspector’s Checklist” indicates inspection tasks ranging from pre-surface preparation to surface preparation and coating application. ANSI/ASME N45.2.6, Qualification of Inspection, Examination and Testing Personnel for Construction Phase of Nuclear Power Plants ANSI/ASME N45 2.6 establishes criteria for companies to internally certify individual coatings inspectors through experience, education and testing as Level I, II, or III coating inspectors. The SSPC QP-

5 standard adopted the levels used by ANSI/ASME N45.2.6. American Society for Testing and Materials (ASTM) ASTM has several standards that discuss coating inspectors and responsibilities; however, they do not differentiate between QC and QA. ASTM standards discussing inspector responsibilities or inspection and inspection activities related to applicator certification include: D4227-99, Standard Practice for Qualification of Coating Applicators for Application of Coatings to Concrete Surfaces D6237-98, Standard Guide for Painting Inspectors (Concrete and Masonry Substrates)

procedures for third party inspectors. It provides minimum training requirements equivalent to NACE Level I and a minimum of three years experience. It states that third party inspectors should pass annual visual acuity testing. It suggests that the inspector’s authority, testing procedures, instrumentation, hold points and documentations be reviewed at the pre-job conference. PDCA P4:94: Responsibilities for Inspection and Acceptance of Surfaces Prior to Painting and Decorating: Indicates that the contractor is required to inspect surfaces for compliance with the specification and that the Owner has the responsibility to determine if the preparation of the surface is complete.

D3276-00, Standard Guide for Painting Inspectors (Metal Substrates)

PDCA P8-00: Owner’s Responsibility for Maintenance of Paints and/or Coatings: Defines the Owner’s responsibilities for an appropriate maintenance painting program. It suggests that the Owner is responsible for periodic inspection of painted surfaces and that inspections by the Owner (e.g., QA) should be performed jointly with the contractor (e.g., QC).

D5161-04, Standard Guide for Specifying Inspection Requirements for Coating and Lining Work (Metal Substrates)

None of the PDCA specifications address the specific division of QC and QA responsibilities.

D4537, Establishing Procedures to Qualify and Certify Personnel Performing Coating Work Inspection in Nuclear Facilities

Transportation Specifications Addressing QC And QA Requirements

D4228-99, Standard Practice for Qualification of Coating Applicators for Application of Coatings to Steel Surfaces

Painting and Decorating Contractors of America (PDCA) PDCA has three (3) specifications that address inspection requirements. P2-92: Third Party Inspection Qualification and Responsibilities: Defines the qualifications, responsibilities and

A review was conducted of the standard specifications for over 50 transportation authorities as listed in the Federal Highway Administration (FHWA) state transportation websites. Specifications were examined for either QC or QA requirements relative to: personnel training/experience, written procedure/quality control manuals,

management, inspection hold points and documentation requirements Where QP1 certification was required by the specification, it was assumed that the minimum QP1 requirements for the above topics (i.e., training/experience) were invoked. Table 2 (appended) delineates the standard specifications that include either QC or QA requirements. Twenty-four of the over 50 standard specifications reviewed (approximately 50%) contained QC requirements or required QP-1 certification. Fourteen of the 24 specifications relied solely on QP-1 certification. Three of the states required the contractor to complete Owner-developed QC forms to document QC inspection of specified hold points. Five of the standard specifications addressed QA requirements. One state required QA to complete an Owner developed form. It should be recognized that QA requirements are often handled on a per contract basis rather than through standard specifications. The following provides a brief overview of two states that have recently modified their existing standard specifications and contract documentation to clarify the roles and responsibilities of the contractor’s QC and the Owner’s QA. Ohio Department of Transportation In 2004, Ohio Department of Transportation (ODOT) implemented a new specification (Item 514 Painting of Structural Steel: Dated March 22, 2004). Item 514 of the Ohio DOT specification requires the QC to have specific training by NACE Certified Coating Inspector or an

SSPC Certified Protective Coatings Specialist in coating inspection techniques. It also requires the QC to attend an ODOT bridge painting pre-qualification course. The specification provides a specific definition of a hold point (called quality control points) as “points in time when one phase of the work is complete and approved by the QC and ready for inspection by the Engineer or inspector (QA) before commencing the next phase of work.” This definition clearly invokes both QC and QA inspections of certain hold points. It also states that the QC should not routinely be involved in production duties. Item 514 identifies ten hold points for QC inspection. The ODOT course also provides the QC with specific forms to be completed each day documenting successful completion of each quality control point. A second form is provided to record the number, range and average of dry film thickness measurements performed by QC. Illinois Department of Transportation The Illinois Department of Transportation (ILDOT) undertook a major revision of it’s maintenance painting program in 2002 – 2003 through the introduction of QP-1 and QP-2 certification requirements for some projects, development of a new coating specification and implementation of specific ILDOT forms for completion by the contractor’s QC and ILDOT or third party QA inspectors. The QC and QA forms define the required hold point inspections that must be performed by the QC and QA, respectively. Staffing of QC And QA Personnel Another factor that can have a tremendous impact on the effective implementation of QC and QA is the

contractor’s schedule, number of work crews or locations, the QC having other responsibilities, and adequate staffing of QC and QA personnel. Under the SSPC certification requirements, while the contractor is required to provide a QC representative, there is no guidance on the number of QC personnel or QC time necessary to achieve adequate quality control. For projects involving multiple structures or locations, or multiple crews, it is unlikely that a single QC inspector could perform the necessary observations, testing and documentation to verify that all the work was performed as required by the project specification or the QP-1 program requirements. If the QC inspector is performing additional duties (i.e., acting as the competent person or assisting in production operations), his or her ability to adequately perform QC is further compromised. None of the QP requirements prevent the QC from performing other functions. Where there is inadequate QC coverage of the key hold points, the QA inspector may be the only one performing observations and testing. This results in the loss of the primary component (quality control) of the total quality management system. It can also lead to confrontation between the contractor and the QA when non-conformances are observed, since the QC has not been involved in the initial inspection and correction of the work. Similar to the above, inadequate QA staffing can also result in inadequate quality auditing of the QC. The level of QA inspection and the number of assigned staff is typically established by the Owner based on an engineer’s estimate of the project schedule and contractor’s labor. However, once a contractor has been selected, the

contractor typically dictates the schedule, number of work crews, work areas and working hours. The QA staffing plan should be carefully evaluated against the actual contractor’s schedule to determine if adequate QA staff is available to facilitate production while maintaining quality assurance. Another potential problem with QA staffing is that with shrinking painting budgets, often QA time on-site is limited by the project budget. For example, the QA may be limited to an eight-hour workday, while actual contractor operations occur for 12 to 14 hours per day during peak periods. As most of the coating work is performed at the end of the day, the QA inspector may not be on-site during the mixing and application of the coating. A reasonable rule of thumb is that the QC and QA should be present for the complete duration of the workday or week. When QA staffing is inadequate, the ability to observe all operations is compromised. In the absence of effective QC, valuable QA time is lost performing initial inspections. When QC and QA tasks are not clearly defined, significant duplication in inspection efforts can occur. Separating QC And QA Responsibilities Qualifications QC qualifications appear to be inconsistently defined in most of the documents researched. Since QC has the primary responsibility for the quality of the end product, QC personnel should have a minimum level of experience and formal training to perform and document the implementation of the QC process. Consideration should be given to requiring QC personnel to document proficiency in coating inspection through formal

certification or successful completion of a specific curriculum. When SSPC QP1 is specified, the experience and training of the proposed QC should be verified. Annual refresher training and visual acuity testing should be considered for SSPC QP personnel similar to that by QP-5. Most documents required third party QA to demonstrate a minimum level of certification and experience. The SSPC QP5 certification program has significant requirements for the qualifications of third party QA inspectors. Procedures Similar to the above, the contractor should be required to follow written QC procedures and maintain documentation for recording the QC observations. Most specifications reviewed did not specify submission of QA procedures. Documentation was required for most QA inspections. Hold Points A review of the requirements of the above criterion for QC and QA inspections suggests that the QC has full-time responsibility for all phases of the project. Further, given the contractor’s control of the equipment, personnel, material and processes, they must through QC, be responsible for testing of its operation and adequacy. QA is typically specified at specific critical hold points and for periodic verification that the QC is being implemented. A comparison of the criterion specified in the documents reviewed indicates that an appropriate division of hold points between QC and QA may be as delineated in Table 3 (at the end of this paper).

Appropriate division of hold point inspections of the QC and QA personnel should result in the ultimate responsibility for quality being that of the contractor and allow QA to fulfill is it role by definition, as an audit function, rather than as the sole entity responsible for the quality of a coatings project. Clear delineation of QC and QA responsibilities also allows both the QC and QA personnel to perform their respective functions effectively to achieve the total quality system and resulting in a quality final product. Recommendations Owners Evaluate and revise current standard specifications, special provisions and contracts (i.e., contractor and Owner or third party inspection) to clearly define the responsibilities of QC and QA personnel. Require adequate QC coverage based on projected schedules or minimum QC coverage by crew, structure, location, or working hours. Require QC personnel to meet minimum standards of training and experience, provide QC procedures and maintain documentation that will be used to verify the quality of the final product. When specifying SSPC or similar certifications, require the contractor to provide evidence of QC personnel qualifications and training, necessary QC equipment, QC procedures and the type of documentation to be completed by the QC inspector. Require QS-1 in addition to QP certifications. Develop Owner specific QC forms or require the QC to complete Forms 4 and 5

presented in SSPC 03-14, Chapter 3 as minimum documentation. Develop Owner specific QA forms for use by internal QA or third party QA. Evaluate QA coverage based upon the contractor’s proposed work plan, number of crews, locations or working hours. Contractors Recognize that the QC is the first step in the total quality process and the importance of adequate employee training and experience and adherence to QC procedures and documentation. Provide for adequate level of QC in the project estimate and bids. Third Party Inspection Agencies Clarify in advance with Owners and Contractors the sequence of QC and QA inspections, resolution of conflicts and how to communicate non-conforming conditions. Verify whether the scope of the inspection is quality control or quality assurance. Clarify QA inspection hold points versus QC responsibilities. Organizations Serving the Coatings Industry SSPC, NACE, PDCA, ASTM and other organizations defining coatings inspection criteria or certification guidelines should evaluate the appropriate

qualifications/experience, inspection and documentations specific to QC and QA in their standards. Consider annual retraining, minimum training curriculum or training hours or certifications for QC personnel. SSPC should evaluate their certification programs for consistency between the different QP standards. Consideration should be given to defining minimum training requirements for QC and management of the QC process similar to the approach used for QP-5 certified inspection companies. Some the actions planned for 2005 appear to indicate that SSPC is moving in this direction. FHWA/AASHTO should consider developing master guidelines and specifications relative to the QC and QA on transportation projects. Conclusions It is only through the establishment of clear qualifications, responsibilities and documentation requirements for both QC and QA on a given project, that the full benefit of the total quality management process can be realized. Benefits can include avoiding duplication of documentation and inspection, reduction of conflicts between the contractor and Owner and third party QA, real or perceived under or over inspection, and most importantly, long lasting protection of the structure or asset.

TABLE 1 COMPARISON OF SSPC PCCP REQUIREMENTS1 Training and Experience QP-1 QC Supervisor: 3 – 5 years experience and formal training QC Inspector: minimum 2 years experience and formal training

QP-3 QC Supervisor: 3 – 5 years experience and formal training or 10 years experience QC Inspector: minimum 2 years experience and formal or in-house training

QP-8 QC Manager and QC Inspector: 2 years experience and 8-hours general QC training and 16 hours concrete/polymer coating training

QP-6 Thermal Spray Supervisor: Demonstrate knowledge of SSPC CS 23, QP-1 and QP-3 (for concrete QP-8 and AWS C.2.20) and two years experience or one year experience and successful completion of SSPC C-7 training. Participate in SSPC Thermal Spray Training Course or equivalent (minimum 16 hours) or 2 years documented experience through the equipment manufacturer and formal training program (minimum 8 hours). TSS must be qualified under the contractor’s program as a Thermal Spray Operator and meet testing requirements of AWS C2.16, SSPC CS 23 as appropriate. Thermal Spray Operator: Internal program for training per AWS C.2.16 or equivalent Thermal Spray Inspector: Internal program for training, qualifying and certifying inspector.

QS-12 QC Manager: SSPC PCS, NACE Certified Coating Inspector or BS in material science or corrosion engineering. QC Inspector: Successful completion of NACE CIP Level I or equivalent. Physical Qualifications verify every 10 years: *Near distance visual acuity (Jaeger) *Color perception (Ishihara or Farnsworth)

QP-5 Total Quality Manager: 10 years experience and SSPC PCS, NACE Certified Coating Inspector, or BS in corrosion science or engineering. Inspectors (All): Successful completion of written coating inspection training program and written/practical exam Annual refresher training Physical Qualifications: *Near distance visual acuity (Jaeger) *Color perception (Ishihara or Farnsworth) Level I Inspector: HS diploma and 6 months experience OR Associates degree and 3 months experience Level II Inspector: HS diploma and 1 year experience as a Level I OR Associates degree and 1 year experience as a Level I OR BA or BS and 6 months experience as a Level I Level III Inspector: HS diploma and 6 years experience as a Level II OR Associates degree and 7 years experience as a Level II OR BA or BS and 5 years experience as a Level II

TABLE 1 COMPARISON OF SSPC PCCP REQUIREMENTS1 Written Procedures / Quality Manuals QP-1 Written procedures to insure major operations (surface preparation, primer, intermediate and top coat) is inspected i.e. QC Manual

QP-3 By specification Requires QC have relevant inspection standards

QP-8 QC Manual including SOPs on: Repair of deficient substrate Pre-treatment of substrate Contaminant testing Surface Profile Moisture in concrete Moisture/vapor emission Storage, mixing and thinning of coatings Installation methods Testing coating for cure, holidays, adhesion, and thickness Curing

QP-6 Formal written procedures for documentation and performing inspections

QS-1 Quality Control Manual following format of ANSI Q10013 – Guidelines for Developing Quality Manuals Include procedures for: Control and distribution Job descriptions Traceability of measurements General scope of inspections Up-to-date procedures for performing test References for equipment and measurement standards Procedures for handling nonconformance Quality Manuals to define and document how quality requirements will be met and include project-specific work plan outlining inspection and test plan

QP-5 Written Quality Manual Management structure Inspection Company’s general scope of inspections and tests Reference to inspection, verification, and test procedures to be utilized Reference to any inspection equipment, calibration, equipment maintenance and measurement standards used Audits schedule and procedure

TABLE 1 COMPARISON OF SSPC PCCP REQUIREMENTS1 QP-1 There is written authority for the QC Inspectors to report directly to management, and to stop nonconforming work and inform the production supervisor of required corrective rework.

Management (Authority of QC Inspectors, Supervisors, Managers and Total Quality Manager) QP-8 QP-6 QS-1 QP-5

QP-3 There is a QC Manager/Supervisor who supervises QC Inspectors. There is evidence that the QC Inspectors report directly to management, not any production-related Supervisor or Manager. QC Personnel have written authority to stop non-conforming work when necessary and order corrective rework.

Not defined

Thermal Spray Supervisor is required to involved in material and equipment decisions and be onside during all quality hold points, surface preparation acceptance, and all thermal spray application.

Written documentation of training and experience of managerial staff Demonstrate management review of field work and QC documentation Appoint designated replacement for QC Manager in case of absence

Total Quality Manager most report to or be executive management Auditors required

TABLE 1 COMPARISON OF SSPC PCCP REQUIREMENTS1 Inspection Hold points 1. 2. 3. 4. 5. 6.

QP-1 pre-cleaning surface preparation primer intermediate topcoat cure

1. 2. 3. 4. 5. 6. 7. 8. 9.

QP-3 receipt of items to be coated inspection of repaired and coated items storage of repaired and coated items surface preparation storage of coating materials handling repair of damages labeling handling and shipping

QP-8 At minimum, per contractors QC manual

QP-6 Procedures for verifying proper thermal spray application and sealing Procedures for inspection and documentation for each major operation (e.g., surface preparation, , primer application, seal and subsequent coating application)

QS-1 Specific hold points to be defined on a job specific basis in the project-specific work plan as part of the Quality Control Manual Work plan to be on site at all times

QP-5 Not specified

TABLE 1 COMPARISON OF SSPC PCCP REQUIREMENTS1 Documentation / Report Content QP-1 QP-3 1. compressed air 1. compressed air cleanliness cleanliness 2. dry film 2. wet film thickness thickness 3. dry film thickness 3. air temperature 4. air temperature 4. humidity 5. humidity 5. dew point 6. dew point 6. surface 7. surface temperature temperature 8. abrasive cleanliness 7. abrasive 9. degree of cleanliness cleanliness achieved 8. degree of 10. surface profile cleanliness 11. batch numbers of achieved paint used 9. surface profile 12. thinner used and 10. batch numbers amount of paint used 11. batch numbers of thinner used 12. mixing according to specification

QP-8 At minimum, per contractors QC manual

1.

QP-6 As discussed in hold points

QS-1 Results of all inspections and tests to be recorded in written report as discussed in test method Includes: Identification of instruments Description of test area and results Date of inspection Identification of instruments or test methods used Reference to sampling method Name, signature and title

QP-5 Includes: Identification of instruments Description of test area and results Date of inspection Identification of instruments or test methods used Reference to sampling method

Name, signature and title

TABLE 1 COMPARISON OF SSPC PCCP REQUIREMENTS1 Internal Audits and Program Review QP-1 Audits – None Program Review None

QP-3 Audits – None Program Review - None

QP-8 Audits – None Program Review – None

QP-6 Audits – None Program Review – None

QS-1 Audits – None Program Review - Annual written report to management on QC program

QP-5 Audits required on a minimum 50 % of projects Annual written program review to management required Internal Auditors: Meet SSPC Level II and complete formal auditor training

Other Requirements QP-1

Review of Documentation - None Refresher Training None Resolution of complaints - None

QP-3 Review of Documentation - None

QP-8 Review of Documentation None

QP-6 Review of Documentation -

QS-1 Review of Documentation Require periodic internal review of quality documentation by QC Manager

QP-5 Review of Documentation - Independent review of inspection reports / results / tests by competent supervisor

Refresher Training - None

Refresher Training None Resolution of complaints - None

Refresher Training - None

Refresher Training - None

Annual

Resolution of complaints None

Resolution of complaints - None

QC Manual must include QC Manual must include complaint policy and complaint policy and trigger trigger audit or investigation audit or investigation Record of complaint investigation and Record of complaint investigation resolution required and resolution required 1: Requirements based upon the applicable qualification procedure, application form and instruction and annual internal audit report form and checklist. Note: application package and internal audit report form and checklist not yet developed for QP-8 and QP-6. 2: Note QS-1 was approved September 1, 2004 but has not been released pending publication of SSPC 2005, Volume II, Systems and Specifications.

TABLE 2 SPECIFIED QC REQUIREMENTS FOR HIGHWAY AGENCIES Owner / Specifying Agency

Training / Experience YES

Written Procedures / Quality Manuals YES

Authority &/or Management of QC YES

Inspection Hold points YES

Illinois DOT

QP1 YES

QP1 YES

NO YES

YES YES

Ohio DOT

YES

NO

NO

YES

Nebraska Department of Roads Maine DOT Rhode Island DOT Connecticut DOT Massachusetts DOT New Jersey Highway Authority NJ/NY Port Authority New York City DOT New York City Transit Authority New York State DOT New York State Thruway New York TBTA Ohio Turnpike Commission Oklahoma DOT

YES QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1

NO YES QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1

NO NO NO NO NO NO NO NO NO NO NO NO NO NO

YES NO NO NO NO NO NO NO NO NO NO NO NO NO

Documentation / Report YES (Owner Form) YES YES (Owner Form) YES (Owner Form) YES YES QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1 QP1

Texas DOT Utah DOT Alabama DOT

QP1 QP1 NO NO QP1 QP1

QP1 QP1 NO NO YES YES

NO NO YES NO NO YES

NO NO NO YES YES YES

QP1 QP1 YES YES YES NO

Ministry of Transportation and Highways (Canada)

Delaware River Port Authority

Alaska DOT Maryland SHA Indiana DOT Note: If QP1 specified, training and QC manual assumed.

SPECIFIED QA REQUIREMENTS FOR HIGHWAY AGENCIES Owner / Specifying Agency

Delaware River Port Authority Illinois DOT Maine DOT Oregon DOT

Alaska DOT

Training / Experience NO NO NO NO YES

Written Procedures / Quality Manuals NO NO NO NO NO

Management NO NO NO NO NO

Inspection Hold points YES YES YES YES YES

Documentation / Report Content NO YES NO NO NO

TABLE 3 – Division of QC and QA Hold Point Inspections Hold Point Inspection

Quality Control DT OV V DV/PT PT DT OT OV DT OV DV/PT DT OT OV OT OV OV

Ambient Conditions (pre-preparation) Pre-surface preparation conditions (welds, rust, edges, etc.) Pre-surface preparation conditions (grease, dust, etc.) and/or SP-1 Surface preparation equipment operation and abrasive size/type Abrasive Cleanliness Compressed Air Cleanliness Soluble Salt Contamination Soluble Salt Remediation Ambient Conditions (pre-mixing and application) Mixing and materials (batch nos., pot life, thinner, etc.) Application equipment operation (pressures, agitation, type, etc.) Compressed Air Cleanliness (spray application) Wet Film Thickness Stripe coat, caulking, intercoat cleanliness, etc. Dry Film Thickness Visual Appearance (runs, drips, sags, etc.) Repairs Legend Type of Verification Frequency of Verification V = Visual D = Daily T = Testing O = Occurrence-based R = Review of QC report or testing P = Periodic

Quality Assurance DT OV V DR/RV/PT PR/PT DR/PT OR/PT OV DT OR/PT DR/DV/PT DR/PT OR/PT OR/OV OT OV OV