Procedure for Evaluating Painting Contractors With Limited Industrial Work Experience

Evaluation of Painting Contractors With Limited Industrial Work Experience

Qualification Procedure No. 7 – Procedure for Evaluating Painting Contractors With Limited Industrial Work Experience

1. Scope

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

2.1 DEFINITIONS:

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).

4.5.2.1 Evidence or documentation shall be furnished that the competent person shall have had:

1. A minimum of two years industrial painting field ex­perience.
2. Experience in safety practices relevant to industrial painting.
3. Experience in waste handling procedures relevant to industrial painting
4. 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:

1. Maintain a list of available safety resource materi­als.
2. Operate a formal procedure for acquiring safety information and materials.
3. 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. Disclaimer

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.