Self-Certification & Quality Assurance

As works are constructed on-site, how should the client check they have been completed following the design in the order they can accept the works once complete at the point of handover? Do they monitor the contractor as they build to ensure they are compliant or employ the services of a supervisor or engineer to carry out this function on their behalf?

Equally, if the works are non-compliant, the contractor will face increased costs to rectify a defect and the client, unless they can mitigate the time, will achieve completion later than planned.

A more efficient way to manage this process is self-certification through assurance measures, such as Inspection and Test Plans (ITPs) and Quality and Project Management Plans (MPs and PMPs). All are prepared by the contractor, who will need ISO9001 accreditation with the documents submitted to the client for review. The contractor then approves the contractor’s plans to certify their works with limited involvement by the client. The client always has the fall-back position of protection under the contract regarding defects post patent and latent.

Then, self-certification will require trust between the parties, but it is not built entirely on this. Also, whilst the contractor can provide ITPs and QMPs, they will need to be set against the client’s requirements regarding what design standards they want these control measures to be against where they may be above minimum standards. For example, the client will wish to inspection points as part of the governance and control. Still, it does not make sense to pass the responsibility of standards to the contractor, inspect the works and examine them in detail at every point in the build.

Typically, the client will apply fundamental principles regarding quality. The contractor or supply chain will need to demonstrate how they will achieve this through the plans, measures, and controls listed below. These fundamental principles can include:

• The first time should be targeted, and a cycle of continuous improvement should be established to drive better quality.
• Compliance with regulation, all relevant codes of practice, plus any standards and legislation.
• Those inspecting the works or certifying the completion of works should be qualified and suitably experienced to provide this oversight and sign off.
• Audit programmes to monitor compliance against the plans derived from the above principles should be implemented. They should be able to establish the effectiveness of the measures and controls and suggest improvements where they are needed.

Project Management Plans

The overriding document establishes how the project will be executed, monitored, and controlled. It will link to the other documents referred to above and below. It should refer to the scope of the project, the programme, and the budget. Also, it should include how quality, resources, communications and change against the plan will be managed.

There will be links to separate documents for each component and how they will be integrated to reflect the detail of the project. The document will be submitted to the client, who should then review and approve the document before reviewing the parts of the document, including any documents referred to therein.

Quality Management Plans

The quality management plan aims to state how quality will be managed and achieved through the project’s lifecycle. It will include references to the contractor’s policies and procedures to control quality, including who is responsible for what parts and how compliance will be determined against each piece.

For example, this will include:

• Project Processes and Deliverables – they should describe control measures for how the quality will be achieved and recorded.
• Quality standards include descriptions of what measures will be put into place to ensure the level required is established.
• Quality Control Standards – from the above, then, how the standards will be controlled through the mechanisms required to achieve the standard.
• Quality Assurance Activities – what activities will be established to monitor the above effectively and to check they are being adhered to and remain effective.
• Continuous Improvement – where issues or non-conformities are identified or found against the quality management plan, how they will be addressed and rectified, who is responsible for this and the time they will be addressed.

Where non-conformities are identified, i.e., where work has failed to meet the quality standards, The client should raise a non-conformance report or NCR. The NCR should cover why the works are non-compliant, what can be done to prevent the problem from happening again, an explanation of the corrective action required, and who needs to be aware of the corrective action such that it can be avoided in the future.

Examples of NCRs include works not constructed to the correct drawing revision, tolerances, as shown on the accepted design, have not been met, a demonstrable failure to work to the ITP has been established, and materials used are non-compliant with the specification.

Inspection and Test Plans

The ITP or Quality Inspection Plan is a critical component in the method for quality control and a flow down from the quality management plan. It is crucial as it will define essential points of control at various stages in the processes used to control quality. There is usually a scheduled inspection for each control point for the client to verify that the works have been completed following the quality management plan and, ultimately, the design.

ITPs will be produced following ISO9001 which sets out the criteria for a quality management system. In operation in over 17 countries and used by more than one million companies, it is the international standard to achieve quality products and services.

In specific reference to ITPs against ISO9001 and the need for control points to be established, this is found under clauses 8.5.1 (c) and 8.6 below. Contractors should demonstrate the organisation and control they will provide the works. This will include documentation, e.g., drawings, specifications, the appointment of competent, qualified people, how they will prevent human error and the processes in place for production and service provision.

Part of how they will do this is by producing and recording ITPs to comply with the need for “monitoring” and “measurement” at “appropriate stages”:

“8.5.1 Control of Production and Service Provision

c) the implementation of monitoring and measurement activities at appropriate stages to verify that criteria for control of processes or outputs, and acceptance criteria for products and services, have been met; …”

8.6 Release of products and services

“The organisation shall implement planned arrangements, at appropriate stages, to verify that the product and service requirements have been met.”

In terms of control points, they can be either witness points or hold points. For witness points, documentation can be presented to the client by way of an update since the last control point and depending on the level and risk involved in the stage of the build or phasing of the works; it may be a decision for the client whether they physically visit the site or are content to approve the control point from a desktop review of the records.

For the hold points, these are needed where a visual inspection of the works is critical for the client to discharge the risk. The works are inspected, and a common sign off is required before the works can proceed.

The ITPs will form a record of the client having attended the inspection, and through this control and sign off (assuming the works are signed off), the works are valid and conform to the standards required. For this to be a record, both parties will need to sign off the ITP for the works to proceed.

Competent Person Scheme

In terms of UK legislation, it refers to the fact that in the 1990s, the increase and diversification of the type of work to which the Building Regulations applied meant that supervising quality control was no longer a viable option that could be practically accommodated and faced with the prospect of taking specific works away from the Building Regulations to manage this an alternative, post public consultation, was to allow competent contractors to self-certify their works.

The consultation looked at the prospect of self-certifying whole buildings, but this was considered too onerous. Presumably, leaving such an essential factor to the end was not the most appropriate way to manage such a critical risk.

Competent Persons Schemes were introduced and operated to apply some structure to the proposal. The Department for Communities and Local Government refers to the United Kingdom Accreditation Service as the sole national accreditation regarding the assessment of competence that provides certification, testing, inspection, and calibration services.

Then, organisations and clients can select their supply chain partners from those accredited to self-certify their works for procurement and supply chain management. A Competent Persons Register is in force and accessible.

However, this needs to be considered against the above, i.e.; the quality management plan may refer to the need to employ accredited employees to provide an acceptable level of quality. However, ITPs and overall control via the QMP are still needed. The competent person scheme is one layer of many in establishing, controlling, and maintaining quality through a project’s construction life cycle.

Self-Certification Risks

As noted above, self-certification requires a solid and collaborative working relationship between the client and the contractor. However, upon consideration, those constructing the works are best placed to ensure they are built to the correct standard with oversight by the client at suitable intervals.

However, the client should be aware that accepting that the works are complete does not alleviate the contractor’s risk of finding a defect later, which can be notified separately. The ITP sign off does not override the contract provisions regarding the notification and correction of deficiencies.

The audit has been referred to above and should be undertaken at regular intervals to ensure that processes are not only being followed but are robust and fit for purpose. To avoid conflict of interest, it is good practice for the audits to be opened to the client’s team and periodic reviews by external third parties to carry out their audit and check that the audits undertaken internally are done so by the audit plan.

Photo by Ricardo Gomez Angel on Unsplash

About Dean Suttling

A member of the Royal Institution of Chartered Surveyors, Dean has twenty years of experience in commercial management and quantity surveying, undertaking roles for contractors, clients, and consultants.