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GENERAL APPROACHES TO CONSTRUCTION QUALITY CONTROL Federal agencies are required by the Federal Acqui- sition Regulation (48 CFR 52.246-12) to include a standard clause regarding inspection in all fixed-price contracts for construction in the United States when the contract amount exceeds the small purchase limitation. If agencies wish, they may also use the clause for small contracts. The essence of the clause is summed up in paragraph b, which requires the contractor to "maintain an adequate inspection system and perform such inspec- tions as will ensure that the work called for by this contract conforms to contract requirements" and to "maintain complete inspection records and make them available to the government" but reserves for the government the right to perform additional inspections and tests. Most federal agencies consider the standard clause to be only the starting point, the foundation for their construction quality control efforts; consequently, most have developed various additional procedures and require- ments to supplement or expand on the provisions of the standard clause. However, the nature of the supplemental requirements, are markedly different for different agencies. Some agencies, for example, basically rein- force and emphasize the idea that the contractor is responsible for ensuring the quality of his own work. Other agencies stress the need for additional inspections and tests either by government personnel or firms under contract to the government. Knowing that the various agencies had very different concepts of how quality control should be handled, the committees asked each agency to describe its basic approach. 11
CORPS OF ENGINEERS The Corps of Engineers, like all military agencies, uses the contractor quality control (CQC) approach on all major construction projects. Under the approach, con- tractors are required to assume responsibility for the quality of their work. Corps of Engineers personnel check to ensure that contractors meet their contractual responsibilities regarding quality control, which include performing the following inspections: ⢠Preparatory Inspection. This inspection is per- formed prior to beginning any work on any definable feature of work. It includes a review of contract requirements; a check to assure that all materials and/or equipment have been tested, submitted, and approved; a check to assure that provisions have been made to provide required control testing; examination of the work area to ascertain that all preliminary work has been completed; and a physical examination of materials, equipment, and sample work to assure that they conform to approved shop drawings or submittal data, and that all materials and/or equipment are on hand. The Contracting Officer's Representative (COR) must be notified in advance of the preparatory inspection and the inspection must be made a matter of record in the contractor's quality control (CQC) documentation. Subsequent to the preparatory inspection and prior to commencement of work, the con- tractor must instruct each applicable worker as to the acceptable level of workmanship required in his CQC plan in order to meet contract specifications. ⢠Initial Inspection. This inspection is performed as soon as a representative portion of the particular feature of work has been accomplished and includes examination of the quality of workmanship and a review of control testing for compliance with contract require- ments, use of defective or damaged materials, omissions, and dimensional requirements. The COR must be notified at least 24 hours in advance of the initial inspection, and the inspection is made a matter of record in the CQC documentation. ⢠Follow-up Inspections. These inspections are performed daily to assure continuing compliance with contract requirements, including control testing, until completion of the particular feature of work. Such inspections are made a matter of record in the CQC 12
documentation. Final follow-up inspections must be con- ducted and deficiencies must be corrected prior to the addition of new features of work. NAVAL FACILITIES ENGINEERING COMMAND The general approach to controlling quality on Navy construction projects is to assign every contract to a Resident Officer in Charge of Construction (ROICC). The ROICC is responsible for administering the contract to ensure conformance with contract requirements and for final acceptance of the facilities. The ROICC's staff includes inspectors, construction representatives, and engineers. When necessary, personnel to supplement this staff can be obtained (on a full-time or on-call basis) through contracts with private architect-engineer firms or specialized inspection organizations. The construction contractor is required to provide an adequate inspection system to assure that the work con- forms to contract requirements and to maintain records and submit daily inspection reports. When the contract requires the development of a Con- tractor Quality Control (CQC) system, the construction contractor must have a separate CQC representative, supplemented as necessary by additional personnel, and he must prepare and submit for approval a CQC plan. VETERANS ADMINISTRATION The Veterans Administration's general approach to controlling quality on construction projects is to place primary responsibility on full time resident engineers assigned to the construction site. The resident engi- neers utilize any technical expertise within the architect-engineer's office, the Office of Construction, commercial testing laboratories and even specialized consultants in unique situations. In addition, periodic inspections by the Project Director's office are con- ducted to provide oversight and to promote objectivity. 13
GENERAL SERVICES ADMINISTRATION The General Services Administration (GSA) does not use the contractor quality control (CQC) approach on its construction projects. There is strong sentiment in GSA against using CQC for construction because of the potential conflict of interest that is inherent in the arrangement. Because of staff cuts, GSA is increasing its use of independent third party contractors to perform construction quality control services. PUBLIC HEALTH SERVICE The Public Health Service (PHS) has a Facilities Manual (currently being updated) that establishes policies and procedures to be used in planning, design, and construction of health facilities. The manual includes procedures to be used in construction inspection and management. It also discusses specific duties of the construction engineer, including the scheduling, prepa- ration, and conduct of the final inspection. In general PHS favors hiring the design architect-engineer (AE) firm to provide quality control service on construction projects costing more than $1 million. For small construction projects, PHS generally favors the use of in-house staff for quality control. However, PHS gives its operating programs considerable latitude in imple- menting general policies; thus some PHS programs have established their own practices; specifically: ⢠The Indian Health Service (IHS) staff is directly involved in construction quality control on all contract and "force account" work (i.e., construction performed by federal employees and/or by tribal operators and laborers under a cooperative agreement with the IHS). IHS engi- neers and para-professional technicians perform most of the on-site construction inspection. However, some of the inspection is performed by private engineering firms under contract. ⢠Most Food and Drug Administration (FDA) construc- tion projects are performed under firm, fixed-price contracts that require the contractor to deliver an acceptable facility when all work is completed. The government specifies the minimum quality it will accept in its plans and specifications. Once the contract is 14
awarded it is the government's duty to obtain from the contractor strict compliance with the specifications. FDA philosophy is that inspection should be performed by agency personnel, including resident engineers and consultants when necessary. Since many problems develop during construction that involve defective specifica- tions, it is a conflict of interest to have the design architect-engineer inspect the work. Inspection by an independent AE or testing firm eliminates the conflict of interest aspects, but the independent firm must work under the supervision of agency personnel since inspection is a government right. 15
