SSPC QP1/2 policy on subcontracting

The current SSPC QP1/QP2 policy for subcontracting work appears here. Reprinted from pages 18-19 of the QP1 application.

Subcontracting Work

SSPC certified contractors are responsible for the actions of subcontractors, to ensure they perform in accordance with PCCP requirements. Contracted tasks include (but are not to be limited to) environmental monitoring and testing; personal monitoring; medical surveillance; cleaning, surface preparation and painting; erecting and moving containment and scaffolding; and equipment maintenance.

The contractor will control its subcontracting process to ensure that its subcontractors conform to PCCP requirements. The contractor shall evaluate and select subcontractors based on their ability to provide products/service in accordance with the contract and PCCP requirements

Purchasing documents sent to the subcontractor shall specify information describing the product or service being purchased. The contractor shall ensure that specified requirements are adequately defined in the purchasing documents prior to their release to subcontractors. Subcontractors must also be notified by you, the certified contractor, that SSPC holds the right to audit their surface preparation and coating application operations.

In all circumstances, SSPC certified contractors should hire only SSPC certified subcontractors for surface preparation and coating application work. SSPC certified contractors MUST hire SSPC certified contractors as required by the facility owner.

SSPC realizes that there are circumstances when you are hired because of your credentials as an SSPC certified contractor and yet are required to hire painting subcontractors, as part of your contract, that may not be certified (e.g., minority or set aside contracts). In cases when you do hire non-certified sub-contractors to fulfill a contract obligation which cannot practically (or reasonably) be met by the contractor or other PCCP certified subcontractor, you will need a written waiver of the QP requirement for the subcontractor from the facility owner or contract administrator. Regardless of the subcontractor's certification status, you are still responsible for the actions of those subcontractors to ensure they perform in accordance with your QP I and QP 2 quality programs.

All subcontractors hired by SSPC certified contractors must be formally approved in writing by the facility owner or its official representative. Failure to comply will result in issuance of a "SEVERE" critical fault under the DAC.

If a certified contractor's job site is audited and one or more of the painting subcontractors performing surface preparation and coating application work at that job site are not in compliance with QP requirements, SSPC will issue the certified contractor a warning for violations of the PCCP Subcontracting Special Provision. A second incident will result in an automatic 12-month suspension from the certification program.

SSPC certified contractors who hire non-certified contractors even though the facility owner, general contractor or specifying engineer specifically call out in their contract or general notice to contractors that all cleaning and painting subcontractors must be SSPC certified, will be subject to disciplinary action (e.g. deliberate violation of specification requirements - a "severe" violation resulting in suspension) under the Disciplinary Action Criteria (DAC).

If a certified contractor utilizes another contractor's workers (e.g. applicators, blasters, helpers, tenders, quality control inspectors, competent persons, etc.) and these workers are paid by another entity (regardless of whether they are under your direct supervision), the workers are considered to be subcontracted from the other entity. If the contract calls for a QP 1 or QP 2 contractor, the other entity must also be certified or it is considered a violation of the DAC.

If a certified contractor is borrowing, leasing, renting, etc., workers, and those workers are on the certified contractor's payroll, and under the certified contractor's direct supervision, the workers are considered employees of the certified company.

Complaints concerning SSPC certified contractors allegedly violating subcontracting practices described above will be investigated by SSPC and may result in an unscheduled audit of job records and/or job site.