Evaluation of Painting Contractors With Limited Industrial Work Experience
Qualification Procedure No. 7 – Procedure for Evaluating Painting Contractors With Limited Industrial Work Experience
1.1 The procedure describes a method for evaluating the qualiﬁcations of ﬁeld painting contractors and contracting ﬁrms with less than 6 months industrial painting experience. The procedure deﬁnes minimum requirements for this qualiﬁcation.
1.2 The procedure determines if a painting contractor has the personnel, organization, qualiﬁcations, procedures, and knowledge to perform surface preparation and coating application of the required quality for complex steel structures under the conditions and restrictions speciﬁed by the owner.
1.3 The procedure encompasses assessment of resources to perform ﬁeld application of coatings in the industrial market. Specialty applications, such as lining materials, bituminous products, galvanizing, metallizing, etc., are not covered by the requirements of this standard procedure.
1.4 Meeting the requirements of this special qualiﬁcation program is not equivalent to SSPC certiﬁcation (e.g., QP 1 or QP 2). Firms meeting requirements of this procedure have not been observed by a qualiﬁed auditor performing coating operations in the ﬁeld on a complex steel structure project.
1.5 This procedure qualiﬁes contractors only for contracts that are speciﬁcally designated by owners or their representatives as being open to bids from contractors who meet the requirements described below.
2. Description and Use
Auditor: The person possessing the necessary technical competence to review contractors’ submittals, conduct on-site audits of contractors, and report results to the qualifying agency (henceforth SSPC) in compliance with the requirements of this procedure and the written requirements of the formal audit program.
Competent Person: One who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, the public, and the environment, and who has authorization to take prompt corrective measures to eliminate them. OSHA requires a competent person on-site during exposure-producing operations.
Painting Contractor: An individual or ﬁrm whose primary business is providing surface preparation and coating application services in the industrial, marine, or heavy commercial markets.
Qualifying Agency: The body responsible for development, maintenance, and operation of the program to ensure uniform compliance with the provisions of this procedure. In this procedure SSPC is the qualifying agency.
Qualiﬁcation: The procedure by which written assurance is given that a contractor conforms to the prescribed set of conditions or requirements of this procedure.
Procedure: The sequence of steps taken to carry out a particular course of action.
2.2 USAGE: The qualiﬁcation procedure may be used by a residential, commercial, or light industrial contractor desiring to enter the heavy industrial market and/or to become qualiﬁed to SSPC-QP 1 and QP 2.
2.3 FUNCTIONS TO BE EVALUATED: The procedure identiﬁes ﬁve function areas to be evaluated depending upon the qualiﬁcation category sought: Management Procedures; Technical Procedures; Quality Control Procedures; Personnel Qualiﬁcations; Safety, Health and Environmental Compliance Programs; including proper handling and disposal of hazardous waste. General requirements for each of these function areas are presented in Section 3.
2.4 EVALUATION PLANNING: SSPC must develop criteria or rating plans to evaluate each contractor against this standard. SSPC shall also determine which of the speciﬁc critical items within the ﬁve function areas are to be evaluated for subsequent follow-up or evaluation, ensuring the items evaluated are the same for all contractors. The sequence of steps for conducting an evaluation within this program is outlined in Section 5. The auditor will perform the evaluation, in each instance.
3. Referenced Standards
3.1 The latest issue, revision, or amendment of the standards shall govern, unless otherwise speciﬁed.
3.2 SSPC STANDARDS
SSPC Guide 7 Guide for the Disposal of Lead Contaminated Surface Preparation Debris
SSPC-QP 1 Standard Procedure for Painting Contractors (Field Application to Complex Industrial Structures)
SSPC-QP 2 Standard Procedure for Evaluating the Qualiﬁcations of Painting Contractors to Remove Hazardous Paint
4. General Qualiﬁcation Requirements
4.1 QUALIFICATION CATEGORIES: This procedure deﬁnes two qualiﬁcation categories: Category 1–Surface Preparation and Coating Application and Category 2– Hazardous Paint Removal in Conjunction with Coating Operations.
4.1.1 Firms seeking qualiﬁcation under Category 1 shall meet all the requirements of Sections 4.2, 4.3, 4.4, 4.5.1, 4.5.4, 4.5.5, 4.6.1, 4.6.2, 4.6.4 and 4.6.6.
4.1.2 Firms seeking qualiﬁcation under Category 2 (Hazardous Paint Removal) shall meet all the requirements of Category 1 plus those of Sections 4.5.2, 4.5.3, 4.6.3, and 4.6.5.
4.2 MANAGEMENT PROCEDURES: The applicant must demonstrate adequate procedures for disseminating company policy and for personnel, administrative and ﬁnancial management as follows:
4.2.1 Contractor Policy: The contractor shall have:
Written policies on quality, safety and health, and environmental compliance.
Written procedures for disseminating company policies to personnel within the organization.
4.2.2 Organization and Personnel: The contractor shall have:
An organizational chart showing division of responsibility within the company.
A list of names, titles, duties, and job descriptions for key personnel (management, technical, quality control, safety, health and environmental compliance). Each job description shall state the experience, licenses, certiﬁcations and training, and refresher courses required for each position.
4.2.3 Administrative and Management Procedures:
The contractor shall provide:
- A brief, written description of the contractor’s method of ﬁnancial record keeping.
- Procedures used for contract estimating and scheduling, and for keeping track of job costs.
- Procedures used to review speciﬁcations and other bid documents.
- Formal procedures for learning about and meeting current federal, state, and local environmental, health, and safety regulations.
4.3 TECHNICAL KNOWLEDGE: The contractor shall have adequate technical resources, suitable job conversion procedures, and appropriate equipment and facilities to perform work. The contractor shall provide the following:
4.3.2 Technical Resources:
A list of technical societies, trade associations, other industry groups, or Internet resources utilized by the contractor to keep abreast of technology developments.
Veriﬁcation that the company maintains a library of current SSPC and other technical standards appropriate for types of work the contractor intends to compete for and obtain.
4.3.3 Procedures: Formal procedures, which are used to convert job speciﬁcations into ﬁeld work orders, job plans, etc., including procedures for:
- Logging receipt of speciﬁcations and revisions and recording who gets copies, as well as removing obsolete or superseded documents from active ﬁles.
- Documenting communication that notes exceptions to speciﬁcations or other clariﬁcations.
- Communicating speciﬁcation requirements to site-based personnel.
- Quality assurance programs (where used). Work procedures should speciﬁcally deﬁne quality control methods and criteria.
- Safety, health and environmental compliance programs.
4.3.4 Equipment and Facilities:
List of contractor-owned or leased equipment.
Formal description of maintenance and repair procedures utilized for equipment, including repair logs.
4.4. QUALITY CONTROL: The contractor must demonstrate that it has proper inspection and recording procedures for job quality control.
4.4.1 Inspection Procedures and Recording Systems:
The contractor must demonstrate the following:
- That standards and speciﬁcations for coating inspection work are available to QC personnel.
- That a system for maintaining and ﬁling in-process inspection reports exists.
- That inspection equipment and calibration standards and procedures are available.
- That procedures for on-site quality control personnel to stop non-conforming work exist.
- That procedures for verifying proper coating application have been established.
- That procedures exist for site personnel to ensure that each major operation (e.g., surface preparation, primer, intermediate and topcoat application) is inspected, if a site speciﬁ c inspection or quality plan is not speciﬁed by the facility owner.
4.5 PERSONNEL QUALIFICATIONS
4.5.1 Quality Control Supervisor: At a minimum, the designated Quality Control Supervisor must:
- Have successfully completed formal training programs in quality control and inspection procedures from a training provider approved by SSPC, and;
- Have a minimum of 3-5 years varied coatings industry experience.
4.5.2 Competent Persons: Evidence or documentation shall be furnished that the competent person shall have had at least 32 hours training (SSPC C-3 course or equivalent).
188.8.131.52 Evidence or documentation shall be furnished that the competent person shall have had:
- A minimum of two years industrial painting ﬁeld experience.
- Experience in safety practices relevant to industrial painting.
- Experience in waste handling procedures relevant to industrial painting
- Experience in environmental monitoring relevant to industrial painting.
4.5.3 Safety Coordinator: At a minimum, the safety coordinator must have a minimum of 40 hours of training by an approved training provider in industrial hygiene and safety. This person may be on the contractor’s staff, or the contractor may utilize the services of an industrial hygiene or safety professional with knowledge of hazardous coating removal operations. The safety coordinator is to be available for consultation on compliance issues as they arise. Since the competent person is required to be on site to implement all compliance activities, it is not necessary for the safety coordinator to be on site at all times. However, the safety coordinator should be available for consultation as needed.
4.5.4 Quality Control Inspectors: Requirements for designated quality control inspectors are deﬁned. At a minimum,
inspectors employed by the contractor must have formal training in quality control and inspection procedures and at least two years experience in the industrial painting industry.
4.5.5 Craftspersons: The contractor shall provide evidence of:
- A program to ensure that persons hired to perform surface preparation and coating application are qualiﬁed. Training, if necessary, must be available to and utilized by qualiﬁed workers, including training required to meet regulatory requirements.
- A method for monitoring proﬁciency of workers performing surface preparation and coating application and relevant documentation exists.
4.6 SAFETY AND HEALTH PROGRAM: The contractor must possess a written safety and health program in conformance with US OSHA Safety & Health (29 CFR Part 1926) or equivalent Canadian or Mexican regulations applicable to industrial painting operations; have provisions to maintain safety records; and provide access to safety resource material as follows:
4.6.1 Safety Procedures and Record-Keeping Systems:
- Document all safety education meetings and related activities.
- Have a formal procedure for conducting pre-job safety or hazard analysis.
- Hold and document pre-job safety meetings.
- Report accidents in accordance with regulations.
- Have a formal procedure for determining the proﬁciency of the safety and loss control program.
- Have formal safety procedures and training for operating specialized equipment.
- Have adequate personal protective equipment and an established, formal system to check the effectiveness and maintenance of the equipment.
- Have a procedure to ensure that available employees trained in ﬁrst aid are on all sites where work is performed on complex structures.
- A procedure to keep records of non-compliance with federal, state, and local regulations, and documentation that corrective actions are taken to avoid repeat violations.
4.6.2 Resource Materials:
- Maintain a list of available safety resource materials.
- Operate a formal procedure for acquiring safety information and materials.
- Operate a formal procedure to ensure that safety information and materials referenced in submittals are available to on-site personnel.
4.6.3 Environmental Compliance Plan: The contractor shall have a written plan to protect the environment from hazardous coating debris generated at the job site. This plan, shall include, at a minimum:
An environmental protection plan detailing how the contractor will control discharges to air, soil, and water.
A hazardous waste materials management and disposal plan. (See SSPC-Guide 7 and 40 CFR, subchapter 1, Solid Wastes, Parts 260-263 and 268).
4.6.4 The contractor’s written safety, health, and environmental compliance programs must be reviewed and formally approved in writing by a recognized industrial hygiene (i.e. CIH) or safety professional (i.e. CSP), and by the ﬁ rm’s executive management.
4.6.5 Monitoring Plan: The contractor shall have a written procedure specifying criteria for monitoring emissions of hazardous substances and a resulting action plan for the competent person overseeing deleading or other hazardous paint removal operations. The plan shall require the competent person to be on site at all times (unless otherwise authorized) during operations resulting in exposure to hazardous substances. Instructions shall require this person, without regard for production pressures, to stop non-conforming operations (i.e., work that deviates from the safety, health, and environmental compliance programs). This procedure shall also provide for a qualiﬁed back up person in the event the oversight or competent person is absent from the job site during exposure producing operations.
4.6.6 The contractor shall have procedures and policies in place to ensure that the contractor’s worker safety, health, and environmental compliance plans are enforced.
5. Evaluation Sequence
5.1 SUBMITTAL OF WRITTEN APPLICATION PACKAGE: The initial step is to request an application form and instructions. The request, along with an application fee must be submitted to the qualifying agency.
The application process involves gathering required information about the contractor or shop as described in the application form. This information and documentation will be submitted to the qualifying agency at the same time as the formal application for qualiﬁcation.
5.2 REVIEW OF APPLICATION PACKAGE: The contractor’s application package is reviewed by the qualifying agency using guidelines for evaluation that have been established by that agency. The evaluation items are based on Sections 4 and 5 of this document.
5.3 ON-SITE AUDIT OF CONTRACTOR: Subject to satisfactory evaluation of the application package referred to Sections 4 and 5 and on a date mutually agreed upon by the contractor and the qualifying agency (unless the audit is unannouced), the qualifying agency’s auditor will visit the contractor’s premises and complex structure job site where surface preparation and coating application is being performed to investigate and rate the following areas directly and indirectly affecting quality of work provided: Management Procedures; Technical Capabilities; Quality Control; and Safety and Health. The auditor will perform the following:
- Conﬁrm data submitted with the application for qualiﬁcation.
- Conduct interviews with key supervisory personnel and some subordinate employees.
- Observe and rate the organization and operation, including management procedures, technical capabilities, quality control, and safety and health programs and procedures.
- Examine and rate equipment and facilities. The on-site audit will usually require from one to three days to complete.
5.4 EXIT INTERVIEW: Following the site audit, and before the auditor leaves the site, an exit interview will be held. At the exit interview, the auditor will review observations and the evaluation with the contractor, including discussions of deﬁciencies and omissions, if any. A written list of deﬁciencies and omissions will be provided to the site supervisor, who will be asked to conﬁrm receipt of the list. Every attempt will be made by the auditor during the exit interview to fully explain how the evaluation was conducted.
5.5 EVALUATION OF APPLICATION AND DETERMINATION OF STATUS:At the conclusion of the evaluation process, the auditor will report the ﬁndings to the qualifying agency, which will make the ﬁnal decision regarding applicant status based on the following options:
5.5.1 Qualify: The auditor has determined that the contractor has met or exceeded the requirements of Sections 4 and 5 above. The qualifying agency will make ﬁnal determination of the contractor’s qualiﬁcation status based on the audit results and disciplinary or other evaluation criteria deﬁned in the application materials. Upon review of all information, the qualifying agency will issue a certiﬁcate identifying the contractor by name and by location of the contractor’s home ofﬁce. Subsequent annual reconﬁrmation is subject to the qualifying agency’s requirements.
5.5.2 Withhold Qualiﬁ cation: Based on audit results and other factors, the qualifying agency has determined that the contractor or shop has not met the requirements of Sections 4 and 5 above. If qualiﬁcation is withheld, the qualifying agency shall submit to the contractor or shop an itemization of deﬁciencies that resulted in the decision to withhold qualiﬁcation. The contractor or shop will be allowed 90 days after notiﬁcation to submit corrective actions, and request an audit to verify that corrective actions have been implemented as stated by the contractor or shop.
5.6 METHOD OF APPEAL: If a contractor disputes the qualifying agency’s decision, the contractor may appeal, utilizing the following steps of recourse:
- The contractor shall notify the qualifying agency within 10 working days after notiﬁcation of audit results, identifying the speciﬁc reasons for the appeal.
- The contractor may arrange with the qualifying agency to have a second independent auditor acceptable to both parties brought in at the contractor’s expense to inspect and re-evaluate the contractor for compliance with the standard’s requirements.
In the event the foregoing step fails to resolve the dispute, a mutually agreed-upon arbitration panel consisting of three persons (one person chosen by the contractor, one by SSPC, and one agreed upon by both parties) with expertise in protective coating operations will convene to hear evidence and make a ﬁnal decision. If the arbitration panel ﬁnds for the contractor, the cost of all fees and expenses of the arbitration will be shared by the contractor and the qualifying agency. If the arbitration panel does not ﬁnd for the contractor, the contractor will be responsible for payment of all fees and expenses. Any other costs incurred by any party to the dispute will be borne by that party.
5.7 RECONFIRMATION OF QUALIFICATION:
5.7.1 Internal Audit: The contractor shall at his own expense perform an annual internal audit, based on the requirements of Sections 4 and 5 above, following initial qualiﬁcation. The results of this internal audit will be forwarded to the qualifying agency, with a copy retained on ﬁle by the contractor or shop, and will be made available to the auditor upon request during any announced or unannounced audits.
5.7.2 Reconﬁrmation of Qualiﬁcation – Owner Comments: Owners for whom the painting contractor performs work will be given an opportunity to comment on the qualiﬁed contractor’s performance by completing an owner comment form provided by the qualifying agency. Comments will be in the form of replies to speciﬁc questions asked of owners regarding performance on speciﬁc jobs. All owner replies will be treated as conﬁdential.
5.8 REVOCATION: Failure to satisfactorily complete the annual internal audit or pass unannounced audit(s) or failure to meet disciplinary or other evaluation criteria established by the qualifying agency will be cause for suspension or revocation of certiﬁcation.
5.9. QUALIFICATION PERIOD: The qualifying agency shall determine the time period for which qualiﬁcation shall be valid, and the re-qualiﬁcation schedule during the qualiﬁcation period.
5.10 QUALIFYING AGENCY FILES:The qualifying agency will maintain a list of certiﬁed contractors, as well as pertinent information submitted by owners and users who have utilized the contractor’s services. This information will assist in the validation process during the certiﬁcation term.
All information gathered will be used only for purposes intended. Information determined to be proprietary in nature will be treated as conﬁdential.
5.11 QUALIFICATION PERIOD: This qualiﬁcation is limited to a one-time 18 consecutive calendar month period following initial qualiﬁcation or ﬁrst eligible job site audit opportunity, whichever comes ﬁrst. Extensions beyond the 18 months may be granted by SSPC for exceptional circumstances. No extensions will be granted for more than 12 months after the 18-month eligibility period expires.
5.12 OBTAINING A PAINTING CONTRACT: Firms qualiﬁed to this procedure who have bid and are awarded a painting contract must notify SSPC within 10 working days of receiving the contract award. SSPC will subsequently attempt to conduct a mandatory audit of that job site, at the ﬁ rm’s expense, to conﬁrm implementation of the contractor’s quality program in the ﬁeld and thus the contractor’s possible eligibility for SSPC certiﬁcation. Failure to notify SSPC in a timely manner, or coordinate with SSPC to arrange a visit to the job site in a timely manner (i.e. while coating operations are in progress) or pass the audit, will result in revocation of qualiﬁcation to this procedure.
5.13 SSPC FILES: SSPC will maintain a list of contractors qualiﬁed to this procedure, as well as pertinent information submitted by owners and users who have utilized the contractor’s services. This information will assist in the validation process if the contractor applies for SSPC certiﬁcation.
5.14 ELIGIBILITY STATUS: Painting contractors who achieve SSPC certiﬁcation status while qualiﬁed to this procedure lose their qualiﬁcation to this procedure. New companies afﬁliated with formerly certiﬁed companies whose certiﬁcations have been suspended or revoked as a result of disciplinary actions deﬁned in the PCCP Disciplinary Action Criteria (DAC) are ineligible for qualiﬁcation to this procedure. Contractors having an owner, ofﬁcer, partner, or key employee above the ﬁeld superintendent level who has held any of these positions within another company that has applied to SSPC for any contractor certiﬁcation category within the previous 2 years are not eligible for qualiﬁcation to this procedure determined to be proprietary in nature will be treated as conﬁdential.
5.15 CONFIDENTIALITY: All information gathered by SSPC will be used only for purposes intended. Information
6.1 While every precaution is taken to ensure that all information furnished in SSPC guides, standards, and procedures is as accurate, complete, and useful as possible, SSPC cannot assume any responsibility, nor incur any obligation, resulting from the use of any materials or methods speciﬁed therein, or of the procedure itself.
6.2 This procedure does not attempt to address all problems concerning safety and health associated with its use. The user of this procedure, as well as the user of all products or practices described herein (esp. painting contractors), is responsible for instituting appropriate health and safety practices and for ensuring compliance with all governmental regulations.