Description
The United States Coast Guard, Naval Engineering Division is responsible for insuring high quality repairs and overhauls to its fleet of ships. This office is considering implementing the change proposed by SSPC to QP-1, which becomes effective October 1, 2004 within the industry. The change requires painting contractors to implement and maintain a contractor certification program (PCCP). This office is requesting comments from its customers on the impact to ship repair companies/painting contractors on the implementation of this change. You are requested to provide your comments in writing, including the monetary impact to your firm, the impact on your manning and staffing to accomplish and maintain the program. You are also requested to provide for our consideration what viable alternatives currently exist or can be utilized/implemented, in lieu of this program to achieve the same end result intended by the program. You are requested to provide your written faxed comments by COB August 13, 2004 to:Vanessa A. Nemara Contracting Officer – vpl-1 FAX: 757-628-4676 Phone: 757-628-4634 757-628-4591 Proposal for Implementing Painting Contractor Certification Program (PCCP) Background. Historically, the Maintenance and Logistics Command Atlantic (MLCA) has been plagued with pre-mature coating failures on surfaces deemed “critical-coated” surfaces i.e. bilges, u/w body surfaces, potable water tanks, flight deck surfaces, etc…Such coating failures typically lead to a loss of cutter operational days and increase contract costs. When confronting pre-mature coating failures, in most cases, MLCA is dealing with “mom-and-pop” type shipyards; sadly, as a result of careful investigating, these failures are often attributed to a lack of Quality Control (QC) in said yards. What we have done and are doing. MLCA has attempted to remedy this problem by including a variety in-process quality control requirements in coating specifications; in addition, over the past 5 years, one of our main efforts has been that of requiring contractors to hire Technical Representatives/Coating Inspectors, who are professionally trained (at a minimum), to the National Association of Corrosion Engineers (NACE) coating Inspector Session I., to oversee all aspects of critical coating applications. Unfortunately, due in part to the difficulty of enforcement in the field, this effort has been, largely, unsuccessful. An additional contributing factor is contractor use of free technical services from coating manufactures - a practice recently prohibited in our specifications. What we propose as a next step. As is currently required by NAVSEA and various other major facility owners, the next logical step, in addressing this problem, is to require contractor certification. In our view, the Painting Contractor Certification Programs (PCCP), developed and managed by the Society for Protective Coatings (SSPC), would be the appropriate certifying medium. The SSPC programs are based on consensus standards developed by a diverse committee of industry professionals; they are nationally recognized independent contractor evaluation programs. They are also a handy pre-qualification tool for facility owners and others who hire industrial painting contractors. Among several of the certification programs, the “QP-1” program, at a minimum, involves reviewing the painting contractors’ primary ability to provide quality work (surface preparation and protective coating application), and assessing contractor conformance with applicable safety, health and environmental compliance standards. Certification particulars. Initial certification costs are between $5000 and $7500; annual renewal is required at a minimal cost to the contractor. Consequences for certified contractors who violate established safety, quality, environmental, and or ethical practice standards of performance include (but are not limited to) the following: warnings, probationary periods, suspensions or revocation of certification by the SSPC. Enforcing the PCCP requirements. The MLCA recognizes the importance of maintaining a broad contractor base. In fact, as part of the PCCP implementation, we would actively engage contractors by providing advance notification of intent to use the “QP-1” program as a qualifying factor. Specifically, all prospective bidders for preservation work for the aforementioned critical-coated surfaces could expect advance notice of six months to one year - to facilitate their compliance efforts. The notice would read was follows: ”Notice To Contractors: This is to advise all concerned parties that all Maintenance and Logistics Command Atlantic (MLCA) commercial availability projects advertised on or after 01 October 2004 will require that any contractors engaged in surface preparation and coating application be certified by SSPC to the requirements of SSPC-QP 1, prior to contract award. The MLCA retains the option of including these requirements in any projects advertised prior to the listed date above. Information on the SSPC certification programs can be found at www.sspc.org”. The vessel procurement branch (vpl) would enforce the PCCP requirements in a manner that is fair and equitable. Rules for certification and re-certification have been established by SSPC to provide a reasonable amount of time for all parties to perform the required tasks; however, SSPC can provide temporary extensions where "good-faith" efforts have not succeeded in fulfilling all requirements. The policy of enforcement of the basic PCCP requirement, initially, and for fostering continuous certification would be as follows: · Contractors would be allowed to work during their certification period only. · Upon expiration of the certification, work would be stopped and would re-start only upon presentation of a valid certification, or written certification extension, from SSPC. · No grace period would be allowed and liquidated damages would not be waived for non-performance due to expired certification. Placing Requirement for PCCP in Project Specification. At the time of implementation, the “General Requirements” item would be amended with a paragraph that conveys the intent of PCCP implementation; it would read as follows: “All contractors and subcontractors that perform surface preparation or coating application shall be certified by the Society for Protective Coatings (SSPC) to the requirements of SSPC QP 1 prior to contract award, and shall remain certified while accomplishing any surface preparation or coating application. The painting contractors and painting subcontractors must remain so certified for the duration of the project. If a contractors’ or subcontractors’ certification expires, the contractor will not be allowed to perform any work until the certification has been reissued. Requests for extension of time for any delay to the completion of the project due to an inactive certification will not be considered and liquidated damages will apply. Notify the KO of any change in contractor certification status”. Conclusion. The SSPC certification programs would offer the MLCA the advantage of knowing that the industrial painting contractors who are working on its projects have the experience, knowledge and equipment to produce quality work in accordance with the local, state and federal guidelines for safety, health and environmental compliance.