Title: QA/QC Procedures and Organization

Phase(s): Pre-Preliminary Engineering and Preliminary Engineering

Category: Management

Date: September 16, 2008

1. Background

The Charlotte Area Transit System (CATS) South Corridor Light Rail Project (SCLRP) is located in Mecklenburg County, North Carolina, and links Uptown Charlotte’s Central Business District to the I-485 Station.  The light rail line operates within the existing Norfolk Southern Railroad (NSRR) Right of Way (ROW) for approximately 9.6 miles.  A detailed QA/QC review was performed by PMOC looking at specific issues, including the procedures, organization, and process.  The technical issues were identified and addressed during the course of the project, but some issues were deemed to be too late for South Corridor, and all parties agreed to have these issues addressed as part of lessons learned and include them in the next project.  The summary of findings is explained in more detail below.

In a spot report the PMOC provided an evaluation of the Charlotte Area Transit System (CATS) South Corridor Light Rail Project (SCLRP) Quality Assurance (QA) Program.  This analysis addressed QA/QC Procedures and Organization (NCN identification, reporting, and resolution).

During the course of the review, the PMOC observed that CATS QA appeared to be performing satisfactorily in several areas within the scope of its Quality Assurance Program, while others areas were observed to require reinforcement.  The PMOC’s review, therefore, focused on areas where CATS QA program oversight required additional strengthening and reinforcement efforts and was written to assist CATS QA in identifying weaknesses in its program, thus protecting CATS against the potential consequences of having an improperly implemented contractor QC system (that is, work being installed on the project that was not inspected properly or did not meet the requirements of the approved drawings and specifications). The evaluation focused on a few aspects of the QA/QC, such as the Non-Conformance Notice process, procedures, staffing, and organizational relationships.

The PMOC observed, during several site visits and interviews that non-conformance procedures were not being implemented as established in CATS Quality Plan Rev. 8.  As per section 11.4 of the CATS Quality Plan: “A Non-Conformance Report (NCR) (also called Non-Conformance Notice (NCNs) by CATS) will be prepared for conditions that do not conform or are questionable in conforming to the requirements and will be forwarded to the responsible contractor.”  It was determined, from interviews with the RE for Roadbed, Bridges, and Trackwork and the RE for the I-485 Parking Facility, that NCRs were issued based on the interpretation of what REs considered to be NCRs.

During the monitoring visits to the project, PMOC discussed and emphasized the requirement that CATS QA must follow the mandate of its Project Quality Plan (PQP), which stated that: “A Non-Conformance Report (NCR) will be prepared for conditions that do not conform or are questionable in conforming to requirements and will be forwarded to the responsible contractor.” In addition: “A Non-Conformance and Corrective Action Procedure will be implemented to assure that any work/craftsmanship (internal-external) that does not fulfill the requirements of the contract are identified and, where possible, segregated and removed from work operations to prevent use until an adequate disposition is made.  Discrepant items will be classified to be either “reject”, “rework”, “repair” or “use/accept-as-is.” 

The PMOC also discovered after reviewing several daily reports forwarded by CATS QA Manager and interviewing the project’s RE, that the RE and his field representatives were working diligently in Construction Management tasks, such as documenting headcounts and hours worked, weather conditions and temperatures, the extent of contractor progress, work being performed on specific days, and so forth. However, it was observed that the RE was understaffed to effectively carry out both his contract management responsibilities and his fulltime Quality Assurance Oversight requirements over the entire 9.6 mile alignment.

It was the PMOC’s opinion that a potential conflict of interest existed between the RE’s production and QA efforts, which could have potentially compromised and limited the oversight and documentation of contractor QC implementation requirements.

Project Quality Assurance oversight personnel should have been independent from production pressure.   Individuals tasked in QA within the RE’s organization should have been identified and should have reported at a higher level within the CATS Quality organization, perhaps reporting to CATS QA Engineer. This should have ensured the QA Engineer had the organizational freedom to identify problems in Contractor QC programs, verify the implementation and documentation of solutions to these problems, and assure that the Contractor’s QC programs were properly implemented at all levels.

Reporting to a level of management within the CATS QA organization would have further ensured that top management received unbiased information on existing contractor QC field implementation issues, providing good communication between the Contractor’s QC and CATS QA through the establishment of trust and providing field QC frontline inspection personnel with support and backup when conditions adverse to quality were identified.  In addition, to adequately implement a QA program on a project of this size, individuals tasked with QA oversight over Contractor QC Programs should have worked fulltime and exclusively on matters of Quality Assurance.

CATS Project Management Plan included a section on project Roles and Responsibilities in section 2.3.1 of the plan that defined the roles and responsibilities of various organizational units in performing and carrying out the project.  Included in this plan was CATS Responsibility Matrix that assigned responsibility codes to each organizational unit.  PMOC observed that Unit 7 (CATS QA Manager) was excluded from having contributor/support, reviewer/comment, or signoff/approval authority for Testing and Start-up.  PMOC’s opinion was that, due to the size and complexity of the Contract, the Implementation of Archer Western’s and other Quality Programs should be monitored by full time field Quality Assurance Personnel directly reporting to CATS Quality.  This would have ensured the following:

• The contractor maintained the required level of independence in his implementation of its QC Program
• The contractors QC properly accepted or rejected the work based on documented procedures, construction drawings, and other requirements
• The Contractors QC properly documented all non-conforming work and followed up on the implementation of corrective measures, as required.
• The top management received unbiased information on existing contractor QC field implementation issues.
• The field QC frontline inspection personnel received the necessary support and backup when conditions adverse to quality were identified.

2. The Lesson

It is important to have correct and complete procedures and the organizational structure to support, implement, and enforce QA/QC issues independently.

• CATS Project Quality Program NCR procedure should have been implemented and enforced in a standardized and uniform manner throughout the project.  In addition,
• CATS Quality should have ensured said procedure was enforced and fully understood by all REs or any parties responsible for issuing said document.
• Project Quality Assurance oversight personnel needed to be independent from production pressure.  Individuals tasked in QA within the RE’s organization should have been identified and reported at a higher level within the CATS Quality organization.
• Due to the size and complexity of the Contract, the implementation of Quality Programs should have been monitored by fulltime field Quality Assurance Personnel directly reporting to CATS Quality.
• CATS Quality Manager should have participated and had signoff Authority on issuance of Certificates of Substantial Completion for Systems Integration Testing, Pre-revenue Testing, and other testing as required in adjunct to CATS Director of Safety. Additionally, CATS should have had QA representation that directly reported to CATS Quality Manager physically present during testing.
• The PMOC recommended that the CATS Program Quality Plan should be updated to meet the requirement of the FTA-QAQC Guidelines section 4.4.4: “Testing and Start-up.”

3. Applicability

CATS Blue Line Extension is utilizing the same staff and procedures for QA/QC of the project.  Standard procedures and requirements could be developed for all future projects.  Organization structure discussed here are needed for all projects to ensure contract requirements are followed, supported, implemented, and enforced independently throughout the project.

4. References

• Spot report 20 dated 8/31/07
• Monthly Progress Reports Part 1 including action items
• CATS North-South (I-77) Corridor South Corridor Light Rail Project Management Plan
• Final Design and Construction Phases, Rev. 8, January 2007
• QA Audit 06-17 STV Construction Management, July 27, 2006
• Safety and Security Certification Certifiable Items List, May 18, 2007
• CATS Project Quality Plan Rev. 8, January 2007
• April 2007 CATS Organizational Charts, Senior Management, Executive Division
• Project NCN’s, Daily Logs and Inspection Reports, Test Records, Field Test reports,
• Geotechnical Investigation and Change Orders