CHANGES TO SSPC QP1 AND QP2 STANDARDS AND

CHANGES TO SSPC QP-1 AND QP-2 STANDARDS AND THE IMPACTS ON CERTIFIED CONTRACTORS By: Alison B. Kaelin, CQA ABKaelin, LLC

CHANGES TO SSPC QP-1 AND QP-2 AND IMPACTS ON CERTIFIED CONTRACTORS • UPDATED 1/7/19 - SSPC QP-1, Standard Procedure for Evaluating the Qualifications of Industrial/Marine Painting Contractors (Field Application to Complex Industrial Steel Structures and Other Metal Components) • UPDATED 11/1/19 - SSPC QP-2, Standard Procedure for Evaluating the Qualifications of Industrial/Marine Painting Contractors (Removal of Hazardous Coatings from Structures)

CHANGES TO SSPC QP-1 AND QP-2 AND IMPACTS ON CERTIFIED CONTRACTORS • Maintenance application

SSPC QP-1 SUMMARY OF CHANGES • Definitions (2. 1) Added or revised • • • Certified Application Specialist Coating Application Contractor Craft Worker EHS Manager Executive Management Field Application Quality Control Supervisor Surface Preparation • Loss Control was deleted

SSPC QP-1 SUMMARY OF CHANGES • Types of structures was revised to reference complex structures • Referenced Standards Added (3) • SSPC-QP 2 - Standard Procedure for the Qualification of Painting Contractors (Field Removal of Hazardous Coatings from Industrial and Marine Steel Structures) • SSPC-QP 3/AISC 420 - Certification Standard for Shop Application of Complex Protective Coating Systems

SSPC QP-1 SUMMARY OF CHANGES (Cont. ) • Referenced Standards Added (3) • SSPC-Guide 17 - Guide to Developing a Corporate Safety Program for Industrial Painting and Coating Contractors • SSPC-ACS 1/NACE No. 13 - Industrial Coating and Lining Application Specialist Qualification and Certification • ASTM D 3276, Standard Guide for Painting Inspectors (Metal Substrates)

SSPC QP-1 SUMMARY OF CHANGES • Personnel and Technical Qualifications (1. 2 and 2) • QCS • EHS Manager • Subcontracting, Assignment, and Delegation (4. 5) • Craft Worker Qualifications (Appendix A)

SSPC QP-1 TECHNICAL QUALIFICATIONS QUALITY CONTROL SUPERVISOR • Quality Control Supervisor Requirements (4. 3. 1. 1) Ø Must be a full-time employee and report to Management Ø 3 years experience Ø A 16 -hour course in quality control supervision specific to the coatings industry v Acceptable courses include SSPC Quality Control Supervisor or equivalent third-party certification acceptable to the Qualifying Agency Ø A third-party coatings inspector certification v v v v SSPC Bridge Coating Inspector (BCI) Level 2 or Protective Coatings Inspector (PCI) Level 2, NACE Coating Inspector Program (CIP) Level 2, FROSIO Surface Treatment Inspector Certificate Level II, ICorr Painting Inspector Level 2, BGAS-CSWIP Painting Inspector Grade 2 , or Equivalent third-party certification acceptable to the Qualifying Agency

SSPC QP-1 PERSONNEL TECHNICAL QUALIFICATIONS EHS MANAGER • EHS Manager Requirements (4. 3. 1. 3) Ø Must be a full-time employee and report to Executive Management Ø The EH&S Manager shall have at least three years’ experience v experience in industrial painting safety v experience in construction safety related to the Contractors’ operations Ø At least 40 contact hours of training in accordance with the following including one of the following: § § § Successful completion of a trainer course in applicable safety standards plus the required prerequisite course(s). Acceptable training includes OSHA-500, OSHA 501, or OSHA 5400, plus their prerequisites, or equivalent training Successful completion of a course in industrial coating safety management, plus additional contact hours of health and safety training applicable to the Contractor’s operations for a total of 40 contact hours of training. Successful completion of a minimum of 40 contact hours of training covering the elements listed in Section 10 of SSPC-Guide 17 applicable to the Contractor’s operations.

SSPC QP-1 PERSONNEL TECHNICAL QUALIFICATIONS EHS MANAGER § Section 11 of SSPC-Guide 17, DOCUMENTS COMPRISING A SAFETY PROGRAM applicable to the Contractor’s operations. § This would be contents of Safety Program and would include topics such as fall protection, respiratory protection, airless spray hazards, electrical, etc.

SSPC QP-1 SUBCONTRACTING, ASSIGNMENT, AND DELEGATION (4. 5) • The Contractor has an ultimate responsibility to maintain all QP 1 requirements when delivered directly by subcontractors. • The Contractor shall maintain documentation that subcontractors are selected on their ability and qualifications to perform to the Facility Owner’s contract requirements and within applicable regulations. • The Contractor shall consider the subcontractors' experience, successfully completed projects, competence, adequacy of safety and health programs, safety and health performance record, operational and financial ability to provide necessary resources, and reputation for performing quality work.

SSPC QP-1 SUBCONTRACTING, ASSIGNMENT, AND DELEGATION (4. 5) • QP-1 Specified by Facility Owner Ø All subcontractors performing Surface Preparation and Coating Application shall be QP 1 certified Ø If owner requires QP 1 certification for other elements of work, the subcontractor shall be QP 1 • QP-1 Not Specified by Facility Owner Ø Notify the owner of non-certified contractors performing Surface Preparation and Coating Application Ø Subcontractors providing QP-1 elements are subject to audit by SSPC and your internal audits

SUBCONTRACTORS DELIVERING QP-1 ELEMENTS REQUIREMENTS § Written Subcontracts Ø Ø § incorporate all applicable project, regulatory, qualification, and certification requirements require subcontractors to submit to and cooperate with Qualifying Agency audits and to maintain all relevant documentation Work under QP-1 programs for quality control and worker health and safety Ø Ø Under their own compliant programs (You should review for adequacy) OR by formally adopting the Certified Contractor’s programs

SUBCONTRACTORS DELIVERING QP-1 ELEMENTS REQUIREMENTS • Reasonable oversight to ensure that subcontracted requirements are met through: Ø Review of documentation Ø Ø Pre-project: JHAs, Safety training, ability to wear respiratory protection, quality control, programs, etc. During work: daily checklists, training, implementation, NCRs/CAs, etc. Post-project: Closure of NCRs/CAs, PDS and certificates of analysis for coatings and materials, final QC documentation Observation of performance Ø Ø Ø Pre-project: set-up, rigging, equipment During work: quality of work, compliance with safety Post-project: clean-up

SSPC QP-1 APPENDIX A – CRAFT WORKER QUALIFICATIONS • Administer a formal training and qualification program for training and evaluation and documentation. • Annual evaluation required • Evaluation of inexperienced workers must include a written test and/or hands-on evaluation

SSPC QP-2 SUMMARY OF CHANGES • Scope • References Guide 6 • Added: The Contractor is required to be knowledgeable of applicable federal (U. S. OSHA and EPA ), state and local requirements (or applicable regulations for contractors operating outside the U. S. ) for handling these hazardous coatings, and to demonstrate the ability to invoke these requirements in project-specific compliance programs and during exposure producing operations.

SSPC QP-2 SUMMARY OF CHANGES • Definitions (2. 1) Added or revised • • Auditor Contractor Competent Person Hazardous Coatings - Coating systems that contain substances (e. g. , lead, arsenic, cadmium, hexavalent chromium, or other hazardous metals) in sufficient concentrations to create an occupational hazard for the worker, or an environmental hazard, or result in a regulated or hazardous waste. • Qualified Person was deleted

SSPC QP-2 SUMMARY OF CHANGES • Reference Standards and Regulations (3) • Updated • Authority and Responsibility of Competent Persons (4. 2. 2) • Personnel Qualifications and Training (4. 4) • Environmental and worker monitoring competency (4. 4. 5) • EHS Manager (4. 4. 6) • Subcontracting, Assignment, and Delegation (4. 5)

SSPC QP-2 AUTHORITY AND RESPONSIBILITY OF COMPETENT PERSONS (4. 2. 2. 1) • The Competent Person shall be on site and perform continual monitoring of work activities disturbing hazardous coatings during any activities that may produce emissions of or exposure to hazardous material. • These activities include but not limited to: Ø power tool cleaning, Ø abrasive blasting, Ø Blowdown and vacuuming grit, Ø handling waste, or Ø working on equipment or containment contaminated with hazardous materials. • A back-up competent person shall be desginated and available in the event to competent person is absent.

SSPC QP-2 AUTHORITY AND RESPONSIBILITY OF COMPETENT PERSONS (4. 2. 2) • The Competent Person(s) may have additional responsibilities and carry out other work assignments, as long as they these duties and responsibilities do not prevent him/her from continually fulfilling the responsibilities of the Competent Person such as: Ø Monitoring effectiveness and continued integrity of containment and ventilation systems Ø Ensuring that employees working in the regulated area are wearing required personal protective equipment and use of exposure control methods, personal hygiene facilities, respiratory protection, and decontamination Ø Ensuring that fugitive emissions to air, water, or soil are minimized Ø Handling of all waste streams Ø Controlling access to the work site and ensuring that contamination control boundaries are marked off Ø Correcting conditions that are unsanitary, hazardous, or dangerous to employees, the public, and the environment.

SSPC QP-2 PERSONNEL QUALIFICATIONS AND TRAINING (4. 4) • Environmental and worker monitoring competency (4. 4. 5) • If Contractor staff or Competent Person is directly performing environmental or worker monitoring, that person shall provide evidence of competency in the monitoring techniques being used. • NOTE: SSPC C-3 training provides an overview of worker and ambient monitoring but does not include hands-on instruction in the of calibration or operation of monitors and does not evaluate competency

SSPC QP-2 PERSONNEL QUALIFICATIONS AND TRAINING (4. 4) • EHS Manager Requirements (4. 4. 6) - Can be employee or and employee meeting SSPC QP-1 and supplemented with an outside party Ø The EH&S Manager shall have at least three years’ experience in environmental monitoring, hazardous waste sampling or monitoring, and worker monitoring in the removal of hazardous coatings industry Ø Training: v SSPC C 3 Lead/Hazardous Coating Removal v Additional 16 hours of formal training in the body of knowledge (BOK) of this standard, including training in hazardous waste management per 40 CFR 262 v Substitution formal training requirements § Certification by a nationally recognized agency as a Certified Hazardous Materials Manager (CHMM) , Certified Industrial Hygienist (CIH) , or Certified Safety Professional (CSP) or similar, or § Being a degreed professional in environmental science, environmental engineering, or similar fields, with ability to demonstrate education and experience in the BOK required by the standard Ø SSPC C 5 refresher training and 16 hours continuing EHS training every 2 years

SSPC QP-2 SUBCONTRACTING, ASSIGNMENT, AND DELEGATION (4. 5) • The Contractor has and ultimate responsibility to maintain all QP 2 requirements when delivered directly by subcontractors. • The Contractor shall maintain documentation that subcontractors are selected on their ability and qualifications to perform to the Facility Owner’s contract requirements and within applicable regulations. The Contractor shall consider the subcontractors' experience, successfully completed projects, competence, adequacy of safety and health programs, safety and health performance record, operational and financial ability to provide necessary resources, and reputation for performing quality work.

SSPC QP-2 SUBCONTRACTING, ASSIGNMENT, AND DELEGATION (4. 5) • QP-2 Specified by Facility Owner Ø All subcontractors performing Surface Preparation and Coating Application shall be QP 2 certified Ø If owner requires QP 2 certification for other elements of work, the subcontractor shall be QP 2 • QP-2 Not Specified by Facility Owner • Ø Notify the owner of use of non-QP-2 certified contractors performing Surface Preparation and Coating Application and any tasks that could create an occupational or environmental exposure to hazardous coatings Any tasks delivered by subcontractors that could create an occupational or environmental exposure to hazardous coatings will be subject to audit by the Qualifying Agency as if being delivered directly by the Contractor.

SSPC QP-2 SUBCONTRACTING, ASSIGNMENT, AND DELEGATION (4. 5) • All Subcontractors delivering QP-2 elements Ø Written Subcontracts v v incorporate all applicable project, regulatory, qualification, and certification requirements require subcontractors to submit to and cooperate with Qualifying Agency audits and to maintain all relevant documentation

SSPC QP-2 SUBCONTRACTING, ASSIGNMENT, AND DELEGATION (4. 5) Ø Reasonable Oversight 1. Require work under contractor’s or subcontractors QP-2 programs including at minimum lead and other hazardous coatings compliance programs, respiratory protection and PPE, environmental compliance and hazardous waste management quality control and worker health and safety 2. review regulatory required documentation (e. g. , medical surveillance, worker exposure monitoring, training, PPE, TCLP testing, etc. ), observation of performance and track implementation of corrective actions as appropriate 3.

TOP TEN 2018 AUDIT DEFICIENCIES QP-1 AUDITS u. DIR/QC Documentation u. Safety Manual/Training/JHA u. QCS Qualification and duties being accomplished u. CAS issues u. Job Notification Submittals u. Technical Resources/Library u. QCI qualifications and eye exams u Calibration issues/Lack of verification of calibration per PA-2 u. PPE/Respiratory program issues u. ESH Manager qualifications u. First Aid CPR certification of personnel

TOP TEN 2018 AUDIT DEFICIENCIES QP-2 AUDITS u Documentation on site (Air monitoring/Air flow readings/Training, etc. ) u. Hazardous Waste Storage u. Competent Person (CP) carrying out duties as prescribed u. CP Qualifications u. Hazcom training of personnel u. CP reports (not filled out properly)

2018 PCCP CONCERNS/COMMENTS • Use of “Consultant” programs for QP-1/2 and QS-1 certification. • Contractor familiarity with programs • Use of Consultant forms vice company legacy forms • Relying on Consultant to “pass” an audit vice organic knowledge of QP/QS processes • Nature of QCI and third party inspector relationship • Joint inspections being accomplished vice “independent” inspection required • Lack of NCRs/CARs • Lack of Management Reviews for Quality and Safety by Senior Management • Industry is production driven (like any other business) • Lack of Corrective Action program to identify areas for improvement • Review of CAPs reveals a need for Root Cause Analysis training

CONCLUSIONS • Update existing programs to meet new requirements • Watch for updates to the QP-1 and QP-2 Initial and maintenance applications • These are being developed by SSPC staff and the PCCP Advisory committee • Consider staffing levels for competent persons • Verify EHS Managers and QCS have sufficient training • Verify subcontractor are evaluated, written subcontracts issued and perform reasonable oversight of their activities