Technical specifications for industrial painting projects frequently require the painting Contractor to submit plans and procedures describing how the surface preparation and coating application work will be performed. These are frequently referred to as “submittals.” The plans and procedures (submittals) are reviewed by the Owner or its representative for compliance with the requirements of the specifications, and in the case of projects involving removal of paint containing lead or other toxic metals, applicable OSHA and EPA regulations. While it may be viewed as a paperwork exercise by the painting Contractor, the procedures provide the Contractor’s project staff with a description of the means and methods that will be used to comply with all aspects of the specification. In addition, the submission and review process provides the Owner with a level of comfort that the painting Contractor understands the scope of the project and is prepared to perform the work in accordance with the specification and contract.
Painting Contractors are frequently asked to submit Quality Control Plans, Work Plans with specific details about how surface preparation and coating application will be performed, and information (i.e., product and safety data sheets) related to the coating system that is intended to be applied. When the project involves the removal of coatings that contain lead or other toxic metals, Contractors are frequently required to submit plans and procedures related to containment, confined space entry, worker protection from lead and other toxic metals, hazardous waste management, and environmental compliance.
The submittal review and approval process can be either aggravating or nearly painless. Frustration from the Contractor’s standpoint may include poorly defined submittal expectations and too many hands in the review process, leading to costly delays in getting the project started. Frustration from the Owner’s viewpoint may include submittals that aren’t timely or are incomplete and lack job-specificity.
So, what can Owners and Contractors do to streamline the submittal management process, remove some of the aggravation, and make it as painless as possible? Here are a few suggestions…
- Develop a stand-alone Submittal section in the specification. This simple formatting effort can provide a focused approach to the submittal management process. When the specification does not include a separate Submittal section, requirements are scattered throughout the specification and often lost among other technical language. As a result, the Contractor is likely to miss a submittal or two because the requirement was buried. All of this slows down the submittal management process and ultimately the start of the project.
- Verify that there aren’t contradictory statements in the specification. For example, the Submittal section of the specification may require that the Contractor submit results of ambient air monitoring within 48 hours after sampling, but the Execution section only requires that the results be submitted within 5 days after sampling.
- Ensure that the requirements for each submittal are clearly defined in the specifications. A specification with vague or generalized submittal requirements makes it extremely difficult for the Contractor to know what to submit, and even more difficult for the reviewer to ascertain whether a plan should be accepted/approved or returned for correction.
- Provide a submittal review checklist as the feedback mechanism (sample appended to this article). A simple checklist should include the required items for each submittal, where the submittal requirement is referenced in the specification, and whether the item was addressed, all which help to streamline the review process. Alternatively, a checklist could be included with the specification as part of the bid package. From the Contractor’s standpoint, a checklist takes the guessing out of the process by clearly identifying the items that should be addressed in each submittal. The completed checklist identifies whether the submittal adequately addressed the item, enables the Contractor to quickly address any deficient items, and ultimately limit the number of re-submittals before the plan is accepted/approved.
- Provide project-specific information and detail when required. Template or generic plans typically do not provide the project-specific level of detail necessary. Similarly, Corporate Quality Control Manuals or Safety and Health Programs are useful in communicating company-level policies and procedures, but they are not site-specific. Site-specific plans can reference corporate plans, but details are needed on the steps that will be taken to accomplish the work on the specific project.
- Transmit a complete submittal package that addresses all the required items at once, rather than sending information to the Owner piecemeal.
- Submit only the plans and documentation required in the specification. Submission of unnecessary information leads to the unnecessary expenditure of resources for both the Owner and the Contractor.
- Verify that there aren’t contradictory statements in the submittals. For example, a project-specific plan may indicate that visible emissions will be limited to less than 1% of the workday while the specification requires no visible emissions.
- Confirm that submittals are provided in a timely fashion. Many specifications will require that pre-project submittals be provided within a certain timeframe (e.g., 21 days) prior to the anticipated start of the project. This timeframe affords the Owner the requisite time to review the initial submittals as well as ample time to review re-submissions should they be required. Submitting the required documentation in less than the specified number of days prior to project start-up may lead to delays in project start-up.
- Confirm that submittals are provided through the proper channels. Each Owner (and potentially each project) has their own unique submittal management process. Some will mandate that submittals be uploaded through an electronic submittal management system, while others may indicate that submittals go through the General Contractor or the Construction Management firm. In any case, confirm that the submission process is correctly followed to avoid delays in the submittal review process.
- If/when a submittal checklist has been created, identify by page number or section number (i.e., Section 23.1.b) where a required submittal item has been addressed. This is especially helpful when a resubmission is provided, and the resubmission includes the entire original plan rather than addressing the deficient items as an addendum to the initial plan.
Submittal management can be a challenge for the Owner and the Contractor or be a nearly painless process. There are several ways that Owners/specifiers and painting Contractors can positively (or negatively) affect that process. Mutual understanding of the purpose of submittals, and the impact that delays in the submission, review, and/or approvals have on the project will help Owners and Contractors better manage the process. The suggestions provided herein offer a few examples for ways that both Owners and Contractors can positively impact the submittal management process.