Procedure for Evaluating the Qualifications of Industrial/Marine Painting Contractors

What is the Standard Procedure for Evaluating the Qualifications of Industrial/Marine Painting Contractors?

Field Application for Painting Contractors to Complex Industrial and Marine Steel Structures

1. Scope

1.1 This procedure describes a method for evaluating the primary qualifications of industrial/marine painting contractors and defines a minimum standard for qualification.

1.2 The purpose of this procedure is to determine whether a contractor: has the organizational set up; employs qualified management and craft personnel; has established and imple­mented a viable quality management system; has implemented a worker safety and health program; has implemented environ­mental protection procedures; and has knowledge of industry technical standards and good painting practice.

1.3 This procedure encompasses the field application of protective coatings for corrosion control in the industrial, marine, highway, municipal, military and other sectors where steel structures are protected. Specialty applications, such as thermal spray metallizing, coating and surfacing of concrete, bituminous products, galvanizing,and handling, managing and containing of hazardous materials and debris are not covered by the requirements of this standard procedure. SSPC has developed additional contractor qualification procedures to evaluate firms who perform thermal spray metallizing (QP 6), install polymer coatings and surfacings over concrete (QP 8 ) and who perform hazardous paint removal, such as deleading of industrial steel structures prior to protective coating applica­tion (QP 2).

1.4 This procedure encompasses surface preparation and coating application and related operations conducted in the field. SSPC-QP 3, “Standard Procedure for Evaluating the Qualifications of Shop Painting Contractors,” covers coating operations performed exclusively at a fixed shop facility. See Section 6 of this standard procedure.

2. Description

2.1 Definitions:

Contractor: A firm whose business is providing surface preparation and coating application and related services for corrosion control in the industrial and marine sectors.

Auditor: 1) The person or persons performing audits on behalf of the qualifying agency. 2) The person(s) possessing the necessary technical and quality system auditing skills to review contractor submittals, conduct on-site audits of applicants, and report findings to the qualifying agency’s program administrator in compliance with the requirements of this procedure and the written requirements of the formal audit program.

Qualifying Agency: The body responsible for develop­ment, maintenance, sponsorship and operation of a program to ensure uniform compliance with the provisions of this standard procedure.

Complex Structure: Industrial structures containing a variety of structural shapes and configurations such as metal producing and rolling mills, ships and other marine vessels and structures; bridges and towers; processing facilities, including chemical and petrochemical processing plants and distribution facilities; pulp and paper mills; power generation plants and substations, food and beverage plants and terminals, water processing and waste treatment facilities; storage tanks, and other industrial and marine steel structures. Complex structures also include any steel components affixed to the structure.

Qualification: The procedure by which written assurance is given that a contractor conforms to the prescribed set of conditions or requirements of this standard procedure.

Procedure: The written sequence of steps taken to carry out a particular course of action.

2.2 Types of Structures: Complex structures encompass a wide range of structural types and configurations.
Although the required evaluation functions are similar for all complex structures, the specific skills (e.g., rigging or pollution controls) are frequently quite different for painting a bridge or painting a process facility or an ocean-going vessel.

This procedure does not differentiate between contractors engaged in work in different industries and on different struc­tures. Owners wishing to select contractors with the specific skills and experience required for the particular job at hand have the option to evaluate the contractor’s ability to meet site-specific requirements in addition to the primary capabilities assessed through this procedure.

Some examples of industrial/marine subcategories for which specific skills are often associated are listed below:

• Marine/splash zone: These include structures proxi­mate to and remote from both coastal and inland shorelines SSPC-QP 1 February 1, 2008
• Proximate includes waterfront structures, locks, dams, ship hulls, flight decks, tanks and voids, bulkheads, piers, pilings, etc.
• Remote includes offshore platforms and structures, etc.
• Bridges and towers.
• Metal and manufacturing facilities.
• Chemical and processing facilities: These include chemical and petrochemical plants, pulp and paper mills, food and beverage plants, and water and waste treatment facilities and related storage and distribution facilities.
• Power generation and distribution facilities.

2.3 Functions to be Evaluated: The procedure identifies four functional areas to be evaluated: Management Procedures; Technical Capabilities; Job Quality Monitoring; and Safety, Health and General Environmental Compliance.

General requirements for each of these function areas are presented in Section 3.

2.4 Evaluation Planning: The qualifying agency must develop criteria and/or rating plans to evaluate each contractor against this standard. The qualifying agency shall also deter­mine which of the specific items deemed critical within the four function areas are to be evaluated for subsequent follow-up evaluations, ensuring the items evaluated are the same for all contractors. The sequence of steps for conducting an evaluation within a certification program is outlined in Section 4. The initial evaluation, in each instance, will be performed by the auditor and must include observation of the contractor’s operational capability on an active industrial/marine painting project under contract.

3. General Qualification Requirements

3.1 Management Procedures: Procedures shall exist for disseminating company policy and for personnel, administrative and financial management as follows:

3.1.1 Contractor Policy: The contractor shall have:

a. Written policies on its commitment to quality work, worker safety and health and environmental compliance.
b. Written procedures for disseminating company policies to employees and those personnel working under its direction. The contractor shall show that procedures are followed.

3.1.2 Organization and Personnel: The contractor shall have:

• A company approved organization chart (updated annually signed,and dated by the COO, CEO, President or other top management official) showing division of responsibility within the contracting firm by name of person and title. Documentation and observation must show that responsibilities are carried out in accordance with the organization chart. Key management personnel (e.g., production manager, quality control supervisor, and safety and environmental manager) shall be full-time employees of the contracting firm.
• A list of names, titles, duties, and job descriptions for key personnel (management, technical, quality control, safety, health and environmental compliance).The job descriptions shall state the experience, licenses, certifications and training and refresher courses required for each position.

3.1.3 Administrative and Management Procedures:

The contractor shall provide:

1. A brief written description of the contractor’s method of financial record keeping.
2. Written confirmation by a CPA firm or equivalent in good standing that accounting systems installed and methods used follow established and accepted accounting practices and principles.
3. Documentation of review of contract specifications.
4. Procedures implemented by management to review and distribute specifications to all employees who manage and effect projects.
5. Written procedures that have been established and implemented for learning about and complying with federal, state and local administrative, environmental protection, worker health and safety regulations applicable to projects performed by the contractor.
6. A key person in the organization is assigned the task of keeping track of new, revised and withdrawn regulations and informing the CEO and/or other key personnel of their impact on the company’s operations.

Information that it is a legally viable entity in the locales that it operates. Examples include: filing of appropri­ate company ownership/incorporation papers; filing of tax returns in a timely manner; Federal Tax ID/EIN statement; holding current state and/or local business licenses and maintaining valid insurance coverage; and other evidence as required.

Documentation that subcontractors are selected on the basis of their ability to assist the contractor in meeting project requirements and any specific inspection requirements. The contractor has overall and ultimate responsibility to maintain all QP1 requirements when delivered directly by the subcontractors.

3.2 Technical Capabilities: The contractor must employ qualified personnel;have adequate technical resources; have suitable job conversion procedures;and have appropriate equipment, facilities, and experience to perform industrial/ marine painting. To demonstrate technical capability, the contractor shall provide the following:

3.2.1 Craft Worker Qualifications: The contractor shall have a written craft worker assessment and proficiency moni­toring program that defines procedures the company uses to initially qualify, train and routinely evaluate the proficiency of all craft workers (i.e., persons performing repairs, surface prepa­ration and coating and lining application) under its supervision.

The worker assessment program must meet the performance requirements of Annex A and evidence of its implementation must be documented.

3.2.2 Technical Resources

The contractor shall provide a list of technical societies, trade associations, or other industry groups (univer­sities, major manufacturers, consultants) with which it is associated. Current membership certificates or correspondence shall be available at the home office location(s) to verify these associations.

The contractor shall maintain a library of current tech­nical standards (e.g., ASTM1, SSPC, API2, AWWA3, NACE4), technical bulletins, publications, product data sheets, MSDSs and other technical references invoked by projects performed.

3.2.3 Procedures: The contractor shall have written procedures that it uses to convert awarded contracts into field work orders, job work plans, instructions to craft workers, etc.

These include procedures for:

• Logging receipt of specifications and revisions and recording who gets copies, as well as removing obsolete or superseded documents from the workplace.
• Documenting communication or meeting notes or pre-job conference discussions, which note exceptions to specifications, omissions, errors, conflicting requirements or other clarifications prior to beginning work.
• Communicating specification requirements to field crews and their supervisors.
• Quality control programs. Work procedures shall specifically define quality control methods and criteria (see Section 3.3.2 below).

Production Control Procedures or Work Plans (see Section 3.3.2 below).

3.2.4 Experience, Facilities, and Equipment:

a. The contractor shall provide a list of current (site based) jobs and jobs recently completed on complex industrial/marine steel structures within the previous 18 months that support the contractor’s suitability for certification. The list shall include the following:

1  ASTM International, 100 Barr Harbor Drive, West Conshohocken,PA 19428-2959.
2 American Petroleum Institute (API), 1220 L St. NW, Washington, DC 20005-4070
3 American Water Works Association (AWWA), 6666 W Quincy Avenue, Denver, CO 80235.
4 NACE International, 1440 South Creek, Houston, TX 77084-4906.

• Name, address, and principal contact(s) of facility owners, general contractors, or other clients, including specific contact information (e.g., cell phone, landline phone, email address, mailing address).
• Scope of work performed.
• Product names of materials used (e.g., abrasive and applied coatings and linings.
• Equipment used for surface preparation and coating and lining operations.
• Types and number of personnel used to supervise and perform the work.
• Special requirements or special provisions (e.g., extraordinary safety or environmental compliance requirements; traffic control).

The contractor shall provide evidence of success­ful completion of the company’s three most recent industrial painting projects. Examples of evidence include: copies of current contractor facility owner evaluations; letters of commendation; statements confirming final payment and acceptance of work or equivalent documentation.

The contractor shall notify the qualifying agency of any contracts that it failed to complete due to default, or cause and explain the cause.

The contractor shall notify the qualifying agency of any project that has entered litigation or arbitration and explain the cause.

The contractor shall notify the qualifying agency of any disbarments, disqualifications due to defective work, unsatisfactory performance, regulatory non­compliance, fraud, illegal activities, or termination
for cause, and explain the cause.

The contractor shall provide written description of preventive maintenance (PM) and repair procedures used for equipment, including PM and repair logs.

3.3. Job Quality Monitoring: The contractor must demonstrate that it uses qualified personnel and proper inspection and recording procedures for job quality control.

Documentation shall be provided that shows objective evidence of conformity to contract requirements and the related good painting practices invoked by contract.

3.3.1 Personnel Qualifications: The contractor shall demonstrate that personnel performing quality control and related functions are trained and qualified and have written authority from executive management to perform their jobs.

At a minimum, the contractor must employ a Quality Control Supervisor (QCS) to oversee the company’s quality monitoring processes. The QCS must have at least three years of protec­tive coatings industry experience and must have successfully completed the SSPC Quality Control Supervisor Course (QCS) or equivalent and SSPC Coating Inspection Training or equivalent acceptable to the Qualifying Agency. Persons designated to perform quality control inspections in the field must have at least two years field experience in protective coatings and be formally trained in the fundamentals of coating inspection including calibration verification and coating inspec­tion documentation.

3.3.2 Inspection Procedures and Recording Systems:

The contractor must demonstrate that:

• Applicable standards and specifications for coating inspection work are available and used by field personnel.
• An implemented system for maintaining and filing complete and accurate daily in-process inspection reports is in place.
• Job specific inspection equipment and calibration verification standards and procedures are available on each job site and properly utilized by on-site Q.C.
• Non-conforming work is documented.
• Logs are maintained to ensure nonconforming work is identified and repaired (identification and repairs must both be documented on a daily basis) or otherwise addressed as determined by the owner.
• Company or contract specific procedures for verifying that coating and related operations are performed in accordance with contract requirements and industry best practices and are available and used by on-site personnel.

Procedures or inspection plans to ensure that each major operation (e.g., surface preparation, primer, intermediate and topcoat application) is properly performed and documented on a daily basis or in accordance with contract requirements are available to on-site personnel, and used to perform in-process inspections of work at key hold points.

Requests for deviations from contract requirements are documented and processed through appropriate channels for consideration. The contractor must maintain copies of notices or correspondence showing that deviation requests have been accepted by the facility owner or designated representative. In-process and final inspection records are retained for a minimum of three years after project completion, unless a longer term is required by contract documents.

3.3.3 Corrective Action Procedures: The contractor shall document actions taken by management to eliminate recurring non-conformities. These actions include identification of the root cause of recurring nonconformities, implementing changes to company procedures and practices to improve production, and follow-up to ensure implementation has been effective.

3.4 Safety and Health, Regulatory Compliance: The contractor shall implement a compliant safety and health program applicable to its operations. The plan shall be reviewed and approved by a safety professional at least every three years or when there is a major change in an applicable regulation or change in production processes used by the contractor. The contractor shall keep track of regulatory compliance and take corrective action, when necessary, to comply with applicable regulations.

3.4.1 Safety Procedures and Record-Keeping Systems:

The contractor shall maintain safety records and have access to safety resource material as follows:

• Document all safety education meetings (such as toolbox talks and related activities).
• Show that field crew competent persons perform and document job specific hazard identification and analysis, and provide documented notification of results to all site-specific crews on a routine and as needed basis.
• Report accidents in accordance with federal, state and local regulations, contract requirements or other applicable requirements.
• Provide Documentation (e.g., meeting minutes, evi­dence of revisions to safety program) that executive management and key personnel evaluate at least annually the effectiveness of the company’s safety, health and loss control program. This includes but is not limited to efforts to reduce EMR or other workers compensation experience modifiers, evaluation of illnesses and injuries (annual OSHA 300 and 300AFilings), evaluation of near misses, and evaluation of incident rates.
• Ensure that safety procedures (such as field copies of standard operating procedures for all major surface preparation and coating application equipment) are available for field reference by personnel operating specialized equipment.
• Provide field personnel with adequate personal pro­tective equipment (PPE) and ensure it is correctly used and maintained.
• Make provisions (e.g.,communication;transportation) during pre job planning to provide prompt first aid and medical attention in an emergency. Make available employees trained in first aid on all sites where work is performed.
• Enforce all safety rules.
• Maintain copies of applicable safety regulations or current safety & health program on each job site.
• Keep records of citations or fines concerning any and all federal, state, and local worker safety and health, wage and hour, tax, and other applicable code or governing regulations, and document that actions are taken to avoid repeat violations.

3.4.2 Resource Materials:

Maintain a written procedure to ensure that safety information and materials referenced in submittals are available to on-site personnel.

3.4.3 Environmental Compliance: The applicant shall have procedures for general environmental compliance condi­tions such as proper disposal of paint and solvent waste; proper disposal of waste water; and use of VOC compliant materials. Environmental compliance procedures for hazardous paint debris such as lead-based paint are covered under SSPC-QP 2.

4. Evaluation Sequence

4.1 Submittal of Written Application Package: The initial step is to request an application form and instructions. The completed application form, along with an application fee and required submittals shall be submitted to the qualifying agency.

4.2 Review of Application Package: The qualifying agency’s certification manager reviews the contractor’s application package,using guidelines for evaluation established by the qualifying agency. The evaluation items are based on Section 3 above.

4.3 Initial Auditing of Contractor: Subject to satisfactory evaluation of the application package referred to above and on dates mutually agreed upon by the contractor and the qualifying agency, the qualifying agency will visit the contractor’s business offices and job site(s) where industrial or marine surface preparation and coating application is in prog­ress on a steel structure to perform an audit of the contractor’s Quality Programs to verify through sampling conformity with the requirements of this standard procedure.

4.4 Exit Interview: Following the audit, and before the auditor leaves the site, an exit or closing interview will be held with a supervisor and/or officer of the company. At the exit interview, the auditor will review findings with the contractor, including discussions of concerns, corrective actions or defi­ciencies and omissions, if any. Awritten list of deficiencies and omissions will be provided to a supervisor and/or officer of the company, 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 audit findings. Failure of the supervisor and/or officer of the company to acknowledge in writing receipt of the audit finding report will render the audit incomplete.

4.5 Evaluation of Application and Determination of Status: At the conclusion of the evaluation process, the auditor will report the findings to the qualifying agency’s audit manager and program administrator, who will make the final decision regarding the contractor’s status based on the following options:

4.5.1 Qualify: The qualifying agency has determined that the contractor has met or exceeded the requirements of the audit program. The qualifying agency will make final deter­mination of the contractor’s qualification status based on the audit findings and any disciplinary or other evaluation criteria defined in the program rules. 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 acknowledging compliance with this procedure and other administrative requirements. Once certified to this standard, the contractor shall reapply for renewal of qualification annually and undergo any submittal reviews or audits required by the qualifying agency to maintain certification to this standard.

4.5.2 Withhold Qualification: Based on audit findings and other factors, the qualifying agency has determined that the contractor has not met the requirements of this standard procedure. If qualification is withheld, the qualifying agency shall formally notify the contractor of the reasons for with­holding qualification. The contractor will be allowed up to 90 days after written notification to submit a corrective action plan, and request an audit to verify that non conformities in the quality system have been identified, root causes analyzed and a formal corrective action plan has been implemented to update the quality plan to avoid repeating the system non conformities that led to denial of qualification.

4.6 Method of Appeal: If a contractor disputes the audit findings, the contractor may appeal, using the following steps of recourse:

• The contractor shall notify the qualifying agency’s certi­fication manager in writing within 10 working days after the exit interview, identifying the specific reasons for contesting the findings.
• If the contractor disputes a decision to withhold certification status, the contractor may appeal to the certification manager in writing within 10 working days after formal notification of denial of certification.
• In the event the foregoing steps fail to resolve the dispute, a mutually agreed-upon arbitration panel consisting of three persons (one person chosen by the contractor, one by the qualifying agency, and one agreed upon by both parties) with knowledge of protective coating operations will convene to hear evidence and make a final, binding 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.

4.7 Reconfirmation of Qualification:

4.7.1 Internal Audit: The contractor shall at its own expense perform at least one annual internal audit of its QP 1 Quality System, based on the requirements of this standard procedure, following initial qualification. The results of this internal audit shall be retained on file by the contractor, and made available to the auditor upon request during any announced or unannounced external qualifying agency audits.

4.7.2 Reconfirmation of Qualification Owner Comments: Owners for whom the 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.

4.8 Revocation: Failure to satisfactorily complete the annual internal audit, pass announced or unannounced external audit(s), cooperate with the auditor or qualifying agency manager, or adhere to disciplinary or administrative criteria established by the qualifying agency will be cause for suspension or revocation of certification.

4.9 Qualification Period: The qualifying agency will require that the contractor’s qualification be reaffirmed annu­ally subject to successful completion of internal or external audits (or both) as well as compliance with administrative and disciplinary requirements. External audits may be conducted at the contractor’s office and/or active job site at the qualifying agency’s discretion.

4.10 Qualifying Agency Files: The qualifying agency will maintain a published list of certified contractors.

Information submitted by owners and users who have used the contractor’s services will also be maintained. 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, such as audit findings and other non-public information, will be treated as confidential.

5. Disclaimer

5.1 While every precaution is taken to ensure that all information furnished in SSPC guides and standards 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.

5.2 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, is responsible for instituting appropriate health and safety practices and for ensuring compliance with all governmental regulations.

6. Note

SSPC has developed a set of contractor qualification procedures and supporting administrative certification programs that supplement this standard in order to confirm a contractor’s ability to carry out specialty processes. These include but are not limited to “Standard Procedure for Evaluating the Qualifi­cations of Painting Contractors to Remove Hazardous Paint” (SSPC-QP 2); “Standard Procedure for Evaluating Qualifica­tions of Shop Painting Contractors” (SSPC-QP 3); “Standard Procedure for Evaluating the Qualifications of Contractors who Apply Thermal Spray Metallizing for Corrosion Protection,” SSPC-QP 6; “Standard Procedure for Evaluating the Qualifications of Contractors who Install Polymer Coatings and Surfacings on Concrete,” (SSPC-QP 8); and “Standard Procedure for Evaluating a Contractor’s Advanced Quality Management System” (SSPC-QS 1).

More information on these and other SSPC qualifica­tion programs are available at http://www.sspc.org (click on “certification”).

Mandatory Annex A: Craftworker Training and Evaluation

A. General Description
In order to meet the requirements of QP 1 section 3.2.1, the contractor must document implementation of a formal written program to:

• Assess the skills and general training needs of newly hired craft workers* and qualify them for their assigned tasks;
• Verify the qualifications of existing craft workers;
• Train inexperienced craft workers (trainees) as necessary
• Evaluate the performance of craft workers at least annually, and provide additional training as necessary
• Ensure compliance with contract specific worker training/qualification requirements

*A craft worker is one who performs surface preparation and/or applies coating materials

B. Contents of the Program – General Training and Qualification Requirements of Newly Hired/Experienced Craft Workers

The program must contain provisions to administer written tests and/or a hands-on evaluation to assess the skills of new hires that claim to have previous experience, or verify previous qualifications through a formal training or qualifica­tion program.

When written tests are used, they shall include infor­mation that the contractor determines to be necessary to verify the general knowledge of the trade and the qualifications of the individual tested to perform work assigned. While it is left to the contractor to create or use the test that works best for its business, the contractor must show that the questions and answers are based on training materials, or standards or publications developed by SSPC, ASTM, PDCA5, the IUPAT6 or its affiliates; NCCER7, or materials de­veloped by another organization, that are acceptable to the qualifying agency.

Hands on Skill Evaluation – At minimum, abrasive blasters shall be qualified using the SSPC C-7 hands-on skill assessment protocol for testing blasters or an equivalent hands-on evaluation, acceptable to SSPC. The hands on evaluation can be done in a controlled qualification session in the shop or yard or in the field at an actual production site. The C-7 skills assessment form is available from SSPC.

Spray painters shall be qualified per the contractor’s Quality Control Procedures Manual using industry accepted qualification procedures from one or more of the sources listed in B (1) above.

Specialty skill qualifications for such processes as UHP water jetting, thermal spray metallizing, or plural component spray shall be developed in house (or outsourced) based on material or equipment sup­plier best practices when industry standard training or training materials do not exist.

Craft workers previously trained or qualified by a company who have been laid off or who have left to work for another contractor, only to return to work for that company within a two year period need not be re-qualified to update assessment of their skills.

Trainees

General training for trainees shall be based on training materials or programs developed by SSPC, PDCA, the IUPAT or its affiliates; NCCER, or equivalent materials, acceptable to the qualifying agency.

C. Qualification To Apply Specific Material and Use New Equipment

The program must contain procedures to qualify craft workers to apply materials or use equipment unfamiliar to the craft worker. The program shall be based on training materials or programs developed by material or equipment suppliers, SSPC, PDCA, the IUPAT or its affiliates, or NCCER, or on equivalent materials acceptable to the qualifying agency The program must also document that the workers have been
qualified/trained.

5 Painting and Decorating Contractors of America (PDCA), 3913 Old Lee Highway, Suite 33B, Fairfax, VA 22030. 6 International Union of Painters and Allied Trades (IUPAT) 1750 New York Avenue, NW, Washington, DC 20006. 7 National Center for Construction Education and Research (NCCER), P.O. Box 141104, Gainesville, FL 32614-1104.

Quality Control/Training Manager

Each contractor shall designate a quality control or training manager to be responsible for implementation of the company’s craft worker training and qualification program and monitoring its effective use in the field.

The Quality Control or Training Manager shall have suffi­cient technical knowledge and documented training in the use of specific materials and equipment.

Annual Performance Evaluation

The contractor must have implemented procedures and documentation to show that its production supervisor evaluates each craft worker’s performance at least annually.

Standard Procedure for Evaluating the Qualifications of Industrial/Marine Painting Contractors