Professional Documents
Culture Documents
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Rev.
Date
Prepared by
Checked by
Approved by
30/12/2015
Aamir Faridi
B.J. Jeon
S.K. Choi
Informatics reference:
SSPP-11-PQP-Q-43-001-001 Rev.A
Project Quality Plan
Document date
12/30/2015 10:35 AM
Printing Date
12/30/2015 18:56
Page 1 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
DESCRIPTION
0
00 0A 0B 0C 0D 0E F
PREFACE
PART I
QUALITY MANAGEMENT SYSTEM
1
GENERAL
PROJECT ORGANIZATION
2.1 GENERAL
2.2 QA/QC PERSONNEL CHANGES
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
DESCRIPTION
00
4.1 GENERAL
4.2 RESPOSIBILITIES
4.3 METHODOLOGY
4.4 PLANNING, SCHEDULING,
PROGRESS & EVALUATION
REPORTING
5
Page 3 of 81
0A 0B
0C
0D 0E 0F
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
DESCRIPTION
00
6.1 SCOPE
6.2 REPONSIBILITIES
6.3 INSPECTION AND TEST PLAN(ITP)
6.4 MANAGEMENTS OF INSPECTION POINTS
6.5 TEST AND INSPECTION DOCUMENTS
6.6 TEST AND INSPECTION SCHEDULE AND STATUS
7.1 SCOPE
7.2 RESPONSIBILITIES
7.3 PROCEDURES
Page 4 of 81
0A 0B 0C
0D 0E 0F
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
DESCRIPTION
00
Page 5 of 81
0A 0B 0C
0D 0E 0F
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
DESCRIPTION
00
10
10.1 SCOPE
10.2 OBJECTIVE
10.3 REFERENCE
10.4 RESPONSIBILITIES
10.5 PROCEDURES
PART II
QUALITY PLAN FOR PROCUREMENT &
MATERIALS MANAGEMENT
11
PROCUREMENT PLAN
11A
Page 6 of 81
0A 0B 0C
0D 0E 0F
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
DESCRIPTION
00
PART III
QUALITY PLAN FOR CONSTRUCTION &
PRE-COMMISSIONING PLAN
12
Page 7 of 81
X
X
0A 0B 0C
0D 0E 0F
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
DESCRIPTION
00
Page 8 of 81
0A 0B 0C
0D 0E 0F
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
PREFACE
This Project Quality Plan shall be used as reference during the implementation of BKC
Contract scope of HHI. Contract No. B1303A-A016. PERMANENT HOUSING
COMPOUND WORKS.
The preparation of this Project Quality Plan is correlated with BKC Established Company
Quality Manual and its Operating Procedures, which describes the Management Policies
and commitment of its resources to support the effectiveness of the Quality system
implementation in all of its business operations.
This Project Quality Plan is subdivided into three (3) parts, i.e.:
Part I
Part II
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
each work phase i.e. Civil Works, Associated Civil Works, Special Works
Processes & Pre-commissioning that includes Inspection & Test Plans (ITPs), and
the QP Management approach for the Readiness to Testing and Precommissioning.
It is therefore expected that those who deal in the performance of this Contract job
shall adhere to this Project Quality Plan and thus, contribute to the attainment of
the Companys expected quality standards and objectives of the overall Project.
Page 10 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Page 11 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
4.1
General Requirements
4.2
Documentation requirements
4.2.1
General
4.2.2
Quality Manual
4.2.3
Control of documents
Sections 3, 5 and 7
4.2.4
Control of records
Sections 3, 5 and 7
Management Responsibility
5.1
Management commitment
Section iii
5.2
Customer focus
Section iii
5.3
Quality Policy
Section iii
5.4
Planning
5.4.1
Quality objectives
5.4.2
5.5
Section iii
All the Sections of PQP
5.5.1
5.5.2
Management representative
Section iii
5.5.3
Internal communication
5.6
5.6.1
All Sections
Management Review
General
Page 12 of 81
5.6.2
5.6.3
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Review input
Review output
Resource Management
6.1
Provision of resources
6.2
Human resources
All Sections
6.2.1
General
6.2.2
6.3
Infrastructure
6.4
Work environment
Product Realization
All Sections
All Sections & Project Loss
Prevention Program
Manual
7.1
7.2
Sections 11 to 12
7.2.1
Sections 11 to 12
7.2.2
Sections 7 & 11 to 12
7.2.3
Customer communication
7.3
Section 7
7.3.1
Not Applicable
7.3.2
Not Applicable
7.3.3
Not Applicable
7.3.4
Not Applicable
7.3.5
Not Applicable
Page 13 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
7.3.6
Not Applicable
7.3.7
Not Applicable
7.4
Purchasing
7.4.1
Purchasing process
Section 11
7.4.2
Purchasing information
- do -
7.4.3
- do -
7.5
7.5.1
7.5.2
7.5.3
7.5.4
Customer property
7.5.5
Preservation of product
7.6
8
Sections 4, 6 & 11 to 12
Sections 11 to 12
Section 11 & 11A under
11A.4
Section 11A under
11A.5.2
8.1
General
8.2
8.2.1
Customer satisfaction
8.2.2
Internal audit
8.2.3
Sections 11 to 12
8.2.4
Sections 11 to 12
8.3
Page 14 of 81
8.4
Analysis of data
8.5
Improvement
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Sections 8, 9, 11 to 12
8.5.1
Continual improvement
Section 9
8.5.2
Corrective action
8.5.3
Preventive action
Page 15 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
1. GENERAL
1.1 SCOPE AND OBJECTIVE
This document summarizes how BKC shall manage the Contract Agreement Work Scope
based on the Quality System as set forth in their Companys Quality Manual and
correlated with HHI / SECs Documents which identifies the scope of work.
BKC Quality Management System documents structure, this Project Quality Plan
describes the implementing procedures of the Companys general policies and procedures
covering the management functions of organizing, planning and controlling the required
resource inputs and specific actions to meet the objectives of the Procurement and
Construction activities of the Project pursuant to quality requirements.
The prime objectives of this Project Quality Plan is to ensure effective planning and
facilitate understanding of the specific quality practices, resources and sequence of
activities relevant to all phases of the Contract Job and thus, smoothly implement the plan
in timely manner and meet the overall quality goal of this project.
Page 16 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Page 17 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
and reports all required test values necessary to demonstrate compliance with the
specification.
1.4.9 REVIEW
Means examination of documentation issued by
and correctness i.e. Inspection Reports, Technical Submittals, Mill Certificates, etc.
1.4.10 HOLD (H) POINT/S
Means the Hold (H) point/s during the stage of Inspection/Test activities
whereby Contractor Inspector cannot proceed with the inspection or test
without the presence of HHI/ Inspector/SEC Inspector. Notification to Main
Contractor/Company is required through written "Request for Inspection (RFI)
1.4.11 WITNESS (W) POINT/S
Means the witnessing (W) points during the stage of Inspection/Test activities
whereby Contractor Inspector may proceed with the scheduled inspection
and/or test after notifying HHI / SEC through written Request for Inspection
(RFI).
1.4.11 INSPECTOR
Means the person acting as the authorized representatives either by
Vendor, Sub Contractor, and Main Contractor, SEC or third party
commissioned by any of the contractual parties dispatched to the inspection
site to undertake inspection activities in their respective behalf
1.4.12 INSPECTION
Activities such as measuring, examining, testing, gauging one or more
characteristic of a product or service and comparing these with specified
requirements to determine conformity.
1.4.13 NON- CONFORMITY
The non-fulfillment of specified requirements.
Page 19 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
2. PROJECT ORGANIZATION
2.1 GENERAL
The Project Organization to be adopted in this contract job is shown on the appendix of
this Section. This Project team is linked to BKC Head Office in JEDDAH to provide
technical and functional supportive roles to the project needs.
At BKC JEDDAH Head Office, the Key Personnel to provide authoritative and
supportive roles for this contract job are as follows:
2.1.1 Corporate QA/QC Manager
This position is responsible directly to the Project Manager of BKC for the
overall design and preparation of appropriate Quality Control and Assurance
Program for any contractual services or job of BKC to its clients and its
implementation.
He has the full authority to exercise all the necessary actions for the
management to support the QA/QC group in attaining all the Quality Assurance
objectives cited in this section. He is also reviewing the audit results periodically
to verify the effectiveness of Implementation of Quality System.
He is responsible for setting-up and implementation of the Quality System
requirements of the project in accordance with the Contract Agreement
Provisions. He monitors the status of Non-Conformance Reports and Customer
Complaints for the effective closure of the same. The QA/QC Manager is also
responsible for the review of Project Specification Quality System as per
Contract Agreement.
2.1.2 Engineering Manager
Collaborates with HHI in ensuring that all the contract technical documents (Job
Specifications) issued to BKC are of the latest revisions. He provides technical
Support to the Project Construction Team. Refer to Procurement Plan for
detailed responsibilities.
Page 20 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
PQP.
2.1.9 HSE Officer
In-charge of Safety, Health & Environmental Management Implementation at the
Project site.
2.1.10 Administrative Assistant/Secretary
In-charge of administrative functions for Personnel and secretarial works.
2.1.11 Project QA/QC Manager
Manages the implementation of Project Quality Plan and Quality Control
Procedures, direct all QC Supervisors/ Inspectors, prepare Two Week Look
Ahead Inspection Activities and will be at project site on full time basis and
coordinates with Corporate QA/QC Manager at H. O.
2.1.12 QC Engineer
Are the trained Engineer for each work discipline, who directly conducts
inspection, witness testing and monitoring of the product, fabrication and
installation process. They gather and maintain on orderly records necessary
during inspection and testing based on the pre-designed Inspection and Test
Plans (ITPs) or (ITP) and Method of statements. They are normally assigned at
site when their services are needed.
Page 22 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Page 23 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Organization
Reference Documents
Procurement Plan
The work Quality Control Procedures (QCPs) or Method of statements which are part of
Quality Procedures Deliverables are summarized as appended in Section 12 of this PQP.
Page 24 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
4.2 RESPONSIBILITIES
BKC Site Planning and Scheduling Unit shall be responsible for planning and
scheduling of work activities and required resources in the construction execution and
mechanical completion of the contract activities based on main Contractors Project
Critical Milestone Dates as shown in Contract Requirements. BKC Planning and
Scheduling Engineer shall coordinate with Main Contractor for any changes on
schedules in the work phases and shall make adjustment / updating on the current
project situation. He shall also be responsible for periodical progress reporting,
schedule updating and to include delay analysis if setbacks on schedules are
encountered during the contract execution. Any revisions to the Project Schedule shall
be subject to approval by Main Contractor.
4.3 METHODOLOGY
For an effective control of project activities, the Planning and Scheduling Unit will be
using the aid of MICROSOFT EXCEL or PRIMAVERA PROJECT PLANNER
SOFTWARE for the preparation of computer operated CPM and BAR Chart
Schedules as time saving and useful tool in Project Management. The planning phase
involves the listing of tasks of job, which must be performed to bring about the
completion of the project milestones.
equipment and manpower are determined in this phase and duration for each is made.
Scheduling is done by interconnecting of all the necessary activities of the project in
the logical order as input to the Computer Software Program with its corresponding
early and late occurrences of start and finish dates and the computer handles
processing of the data. Control is a function, which is a periodical review of the
difference between schedule and the actual performance as the aspect of review and
Page 25 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
evaluation and pursuing corrective actions to prevent overall delay impact to Project
Target Critical Milestone Dates.
Page 26 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
5.2 GENERAL
In general, field documents and record management shall be governed and be
handled according to the requirements of the following:
Page 27 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
The Documents identification No, (Doc. No.), Rev. No., Date and Page shall appear at
particular location on each page of the Quality System Documents consistently.
The Controlled and Uncontrolled copies of all the Quality System documents shall be
stamped accordingly.
The Draft copies shall be stamped as DRAFT and they shall not be used for
implementation or for reference purpose in other procedures or activities.
List of all Quality Documents with its revision Status shall be available in Section and
summary status index in this PQP, which shall be prepared and maintained by the
Project QA/QC Manager, reviewed by the Corporate QA/QC Manager and approved by
the Project Manager.
The Project QA/QC Manager at Site shall maintain a separate Master list of forms with
its revision status.
5.4 CHANGES
The changes to the documents shall be carried out by the functional unit/discipline that
originally prepared, approved, and authorized the Documents unless specifically
designated otherwise. The designated functions shall be given access to pertinent
background information.
The nature of amendment/reason (description) in brief shall be mentioned in the
Status column of the cover sheet of the concerned document(s).
The amendment incorporated shall be identified by double vertical lines on right side
of the amended line, paragraph or page
When a paragraph is completely deleted, the number of the paragraph shall be
retained and the word deleted shall appear in its front and in addition to the double
lines on the right hand side of the number.
During subsequent amendments the new amendments shall be incorporated deleting
the existing double lines and paragraph(s) (mentioned Deleted) and the paragraph(s)
renumbered.
Page 28 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Quality Procedures, Work Procedures, Inspection and Test Plans, shall be reissued as
revision(s) after every amendment.
5.5 RECEIPT
Subsequent receipt from HHI is the responsibility of the Site Project Manager through
the Site Technical Support Supervisor.
All incoming documents/drawing transmittals for this project are to be addressed to the
Site Manager, as BKC field representative. The document transmittal notes shall be
date-stamped on the date received and registered in Log Register Book. Distribution of
receipt documents is controlled by the Document Controller for established distribution
schedule under the
The document Log is interactive (both historical and live reference). No document shall
be deleted or deleted from the Log. When any drawing is superseded, it shall be noted
in the Log. Once the drawings/documents are registered, the Drawing/Document
Central File shall be provided a copy as the Master Copy, to replace superseded
revision of the previous Master Copy (applies to reused drawings).
One copy stamped Superseded is retained in a file for all superseded documents and
maintained by Site QA/QC Unit/Document Controller as applicable.
5.6 DISTRIBUTION
At the start of site activities, the Document Controller shall establish the document
distribution schedule (Form No: Q-014) and classify it by type and mainly divides to
Page 29 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
internal and external to BKC in order to ensure that the current issues of all documents
are available at the pertinent locations. This will be discussed and cleared with BKC
Site Manager and other project key staff members to include Secretary/ Administrative
Assistant, Construction Superintendents, P & S Engineer, QA/QC Engineer, Safety
Supervisor, etc.
A copy of the document transmittal shall be circulated to each concerned
Engineer/Supervisor and initialed by them to indicate their awareness of the
new/revised drawing.
The Document Controller shall do distribution of the drawing/documents as per the
Distribution Schedule as Controlled Copy.
The Controlled copy holders shall destroy the superseded documents when the
revised documents are issued to them.
Documents shall be distributed to all concerned through Document Transmittal
(Form No.: Q-017)
The document controller shall maintain both the electronic version and hard copy of
the drawing register at the same status at all times.
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Data
to
authorized
users
(BKC
Work
Personnel,
Engineers,
Subcontractors or Vendors)
All issues of these data as distributed to authorized users are recorded and controlled
in a logbook.
All authorized recipients of these Data are to be made aware of their obligation to
safeguard these data during the duration under their custody. These data should not
be allowed to remain and left in unsecured place nor seen scattered at the jobsite
exposed to risk of reaching to the wrong persons/unit or unauthorized users.
BKC file copy of HHI / SEC Engineering Data at jobsite control office shall be
maintained in orderly manner and updated accordingly to its latest revisions and re-call
those issued ones that were superseded.
At the end of the Project Contract Completion, all the HHI / SEC Engineering Data
issued to BKC shall be returned except those, which will form part of the Mechanical
Completion Documents Package to be turned-over to SEC upon Final Project
Completion. Discarded or dilapidated documents/data of no use shall be completely
destroyed with prior approval and presence of HHI Authorized Representative.
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Page 32 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
6.2 RESPONSIBILITIES
This preparation of Work Quality Plan and its management during implementation is
vested primarily under the functional responsibility of BKC QA/QC Department and
Project Sites QA/QC Unit. They have the full authorities and responsibilities to perform
generally the following:
-
Page 33 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Applicable Test Record Sheet approved for use during Test Operations for
In- process and Final Test.
After construction or installation, the work shall be subjected to all final and
inspection required by HHI/SEC specifications.
Page 34 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Units
involve
the
intervention
of
BKC
Site
QA/QC
QC
Inspector
proceeds
to
raising
an
RFI
to
HHI
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Proceed or Use as is
Rework
Re-graded
Rejected
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Week
collaboration with the Work Planning & Scheduling Engineer and the Work
Production Units. Based on the updated Project Work Activities Schedule, the
Construction QA/QC Supervisor prepares the relevant Inspection Check and
Test activities. The actual date of each Inspection and Test activity shall be
confirmed through Request for Inspection (RFI)/QMIS for each Inspection and
Test activity that required presence of HHI/SEC representative/ Inspector for
their witnessing.
Status of performed test and related results will be monthly issued. This report
will make reference to (as applicable):
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
7.2 RESPONSIBILITY
The Site Technical Support Services Supervisor (Resident Engineer) is responsible of
performing the above scope of technical services in coordination with BKC Engineering
Manager (B.O.), Site Construction Superintendent/Supervisors and HHI. He will be
assisted by technical staff members and/or draftsmen to perform effectively these
Page 40 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
7.3 PROCEDURES
7.3.1 Shop Drawings Preparation and As-Built Drawings Management
Shop drawing preparation required only to facilitate fabrication and
construction activities shall include title block indicating shop drawing
nos., reference drawing / documents, description, revision no., date
and approving internal authorities. All shop drawings prepared by the
responsible draftsman shall be checked by Supervisor and reviewed
by the Site Manager for endorsement to main Contractor for final
review & approval (only on cases if ever warrants.)
Note: All shop Drawings shall be controlled in a log sheet Register
for monitoring of subsequent changes/revisions.
As-built mark-ups also include those revisions initiated by BKC and its
Vendors and/or with official concurrence from HHI.
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
7.3.1.5 Resolution
Resolution to the Site Technical Query shall be fed-back by HHI to BKC on
returned Site Technical Query with filled-up comments and/or disposition to
subject query for BKC implementation.
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
endorsed to HHI.
The Waivers Particular shall indicate the following:
Referenced Standard or Specification Affected
Statement of Requested Waiver
Brief statement of what should be waived
Justification to Waiver
A rational explanation to justify or give merits to the waiver or
proposed change from the SECs Standard or Specification
requirements.
The originating BKC QA/QC Supervisor shall sign the waiver Request
and forward it to the Construction Site Manager for endorsement to
HHI.
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Refer to
8.7.1 General
BKC shall follow the guidelines set forth in SAEP 122 (Project Records) on the mode of
preparation of gathering the contents and indexing of the Inspection Record Books,
which will be eventually part of the final documents to be transmitted to Saudi Armco
during the Project Completion period and / or one (1) month prior to Plant Start-up.
Basically, the following shall be observed:
Inspection Record Books- The contents shall generally include S e l e c t e d
Drawings, supplier information, inspection and
test records, etc.
The completed Project Inspection Record Books shall be bound in accordance with
Drawing Number specified by the Company.
The identification of the Project Record Books shall be identified by the equipment
plant number, the name of the facility and the Project record number.
The assembly of the Project Record Books (Inspection Record Books) by section shall
follow the indexing shown in COMPANY Standard Drawing, as applicable per Plant
Facility. This indexing shall be agreed and discussed between HHI and BKC later
which should be correlated with the Construction drawings and quality records
covering those test & inspection activities mentioned in the Project Quality Plan and
approved Vendor's Inspection Assignment Packages shall form part of the contents of
Inspection Record Books.
The procedure of gathering and compiling the quality records during the course of
contract job execution is described hereinafter (section 8.8.2 & 8.8.3).
Page 46 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
8.8.1 General
From the commencement of the contract job, BKC- PHC Site QA/QC Unit shall
organize and maintain adequate space at the site office equipped with enough shelves,
cabinets and necessary folders to be used and dedicated only for filing Quality
Records in an orderly manner and easy traceability and retrieval.
8.8.2 Procedure
8.8.2.1 Compilation of Quality Records, Storage and Retention
a-1. During Procurement Stage
All inspection and test records conducted at Vendor's source by BKC
assigned QC Inspector shall be compiled by the respective QC Inspector
and submitted to BKC Procurement QC Supervisor who is responsible for
consolidation and filing to its respective Inspection Record Book.
a-2. During In-Process Construction / Installation
All inspection and test reports / records and relevant document being used
while in the process of job construction and installation are compiled in
provisional book files per job work disciplines and work areas in accordance
with the Inspection and Test Plan as prepared for the specific project. These
will be the sourced back-up quality record documents to be used for the next
milestone phase of the project when it reached the Plant System Testing and
Pre-Commissioning stage prior to Mechanical Completion. These quality
records are filed with proper book identification and safely stored in shelves /
cabinets for easy retrievable or traceability. Original copies of these quality
records shall be filed in their assigned book files.
a-3. During Plant System Testing and Pre-Commissioning Prior to
Mechanical Completion.
All plant system test and pre-commissioning quality records shall be
organized in accordance with the Plant Facility / System Mechanical
Completion Checklist Packages which will form part of the whole projects PreCommissioning Plan.
Relevant in-process installation quality checks and test records required to
form part of the Mechanical Completion Checklist Package per Plant System
shall be in the form of migrated photo copies in order to retain the original
copies intended for Project Inspection Record Books on a separate indexed
form & filing.
Page 47 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
procedures for special process activities associated with the contract Works such as
coating application, welding, cable splicing/termination, concrete batching, cable
conduits seals, cleaning and specific NDT/NDE that are required by the job
specifications as shown under table.
Page 48 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Work
Code
procedure
Qualification
Approval (A)
Procedure
or Review
Approval
Approval
(R)
Required
Required`
Personal
Qualification
Special Process
Required
Page 49 of 81
Yes
Yes
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Yes*
Yes
No
No
Concrete Installation
No
No
Structural Bolt
No
No
Refractory Installation
No
No
Coatings
No
No
/ Examination
Concrete & Asphalt Mix
Design
Tensioning
8.10.1 General
Pursuant to the Contract Agreement, BKC shall observe proper control of its
measuring and testing equipment to ensure certainty is known and consistent with the
required measurement capabilities.
8.10.2 Responsibility
Instrument Laboratory in-charge is responsible for the control and management of
Measuring and testing equipment and ensures proper control is done per the
prescribed procedure. QA/QC Supervisor shall originate, maintain and provide all
documentation as required for the purpose of calibration.
Page 50 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
- On receipt of the calibrated test and measuring instruments (with validated calibration
certificate), they are recorded in the list of calibrated measuring and test equipment
showing also the interval of re-calibration in accordance with Vendor but not more than
six (6) months. Refer to Appendix of this Section for the appropriate Form to use.
- The QC Inspector shall check and ensure that only properly calibrated equipment is
used by personnel performing test inspection operations both in the construction field
or site laboratory.
- When deficiencies are found in equipment, the deficient equipment shall be
immediately segregated from the construction work to prevent inadvertent further use
of the equipment until repaired and/or re-calibrated.
- The list of calibrated measurement and test equipment shall be immediately updated
to reflect disposition of the non-conforming equipment.
- To the extent possible, previous inspection measurements made with the deficient
equipment shall be rechecked with calibrated equipment to verify accuracy of previous
measurement.
- All calibrated inspection, measuring and test equipment are identified with a label
sticker with its date of calibration and expiry.
- In case calibration validity of the original test instrument used cannot be verified
during a particular inspection already done, re-inspection shall be pursued using
another test instrument with valid calibration certificate.
Page 51 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
BKC Project Manager, as the companys representative at site, regularly reviews the
contract documents and ensures that changes and/or deviations on actual job
executions are properly documented and covered by Change Orders to protect the
business interest of the Company.
Page 52 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
9.5 NON-CONFORMITIES
For BKC Non-Conformities Management of its construction activities, refer to Section
10 of this Project Quality Plan, which describes comprehensively how nonConformances are identified, reported, and the manner of documenting its clearances
and closures. BKC QA/QC Manager is responsible for the non-conformities
management in this contract job.
NCR
issued by
HHI
shall
be resolved
by BKC
following
the procedure.
Refer to Section 10 par. 10.5, how external sourced NCRs are resolved and cleared
by BKC.
Page 53 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
9.7.1 General
BKC personnel to be assigned in this contract project shall possess the required skills
qualification and experience of similar job undertakings.
The basic minimum requirements for the personnel ability to comprehend instructions,
interpret basic documents, read and communicate shall be adhered on selection and
appointing personnel to their respective functional position.
To assure smooth job execution, personnel shall be familiarized on specific project
programs and relevant documents. Examples of these are:
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
The above useful data is gathered and acquiring by the cost control unit during
the contract life deviation.
9.8.1 Statistical data is generated on the following:
Page 55 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
10.2 OBJECTIVE
To have a clear understanding on the proper control of non-conformances and
systematic approach and documented records in pursuing and resolving corrective and
preventive actions in order to attain effectively the required or improved level of work
quality standards and thus, avoid completely any occurrences or recurrences of nonconformities.
10.3 REFERENCE
10.4 RESPONSIBILITIES
10.4.1 Project QA/QC Manager (Site Office)
Participates on advisory functions covering the investigation of identified nonconformities and complaints through Non-Conformance Reports (NCRs), or Corrective
Action Requests (CARs) raised by the Originators and seeks/ oversees appropriate
resolutions by the concerned action persons for its remedial actions and closure.
Page 56 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
10.5 PROCEDURES
10.5.1 Identification of Non-Conformance
In accordance with Contract Requirements, BKC shall exercise proper control and
disposition of identification and documentation of non-conformances, corrective actions
and waivers of contract requirements. These non-conformances possible occurrences
are inadvertent use of design documents, materials, parts, components, services or
workmanship not conforming to the requirements of the contract.
Page 57 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Source and/or areas where non-conformities are identified from the materials and/or
services supplied by BKC Vendors / Subcontractors and BKC in-process construction /
installation activities. The control and management of non- conformances on the
specific process work areas are described as follows:
10.5.2 Materials
Detection of non-conformance of materials is controlled by relevant procedures for
materials classified as levels 1, 2, 3 & 4 that are inspected at Vendors Source location
following the specific Inspection Assignment Package submitted by BKC and approved
by HHI / SEC Project Inspection Division. Level 1 does not require pre-inspection
meeting. For materials classified as level 0, inspection is done once the materials
arrived at site. Reporting and documenting Non-Conformance at Vendor's source
during in-process inspection and once it received at site is described in the proceeding
paragraph 10.5.2(b) under this section. Detection of non-conformances of all materials
received at site and segregation of non- conforming materials procedures is described
fully under section 12 of this Project Quality Plan. Levels of disposition on identified
Non-conformance per Contract Agreement are described in detail under par. 10.5.7 of
this Procedure. Disposition of all rejected materials shall be reported to HHI / SEC and
shall form part of the Monthly Quality Management Report.
10.5.2.1 In-Process Installation / Work Phase Activities
Detection of Non-Conformance of in-process installation or any phase of work
activities during the process of fabrication/installation/testing occurring at the
work places are primarily highlighted by BKC QC Inspectors or HHI Project
Representatives/Inspectors in their course of inspections. BKC QC
Inspectors or Other authorized NCR originators accomplish NonConformance Report (Form No.Q-005) in reporting encountered nonconformities or deficiencies.
10.5.2.2 Customer Complaints
In-order to effectively handle customer Complaints, BKC shall be pro-active to
identify these non-conformities and Document its resolution using the same
NCR. Clients Project Representatives / Inspectors usually report and
document their observed non-conformities / deficiencies addressed to BKC,
either in any of the following written documented forms of
communication/records, i.e.:
Page 58 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
mechanism.
d).2 Preventive Action
Action taken to eliminate the causes of potential non-conformity, defects or
other undesirable situation in order to prevent its occurrence.The Preventive
action required shall be determined by the person responsible for the area
based on the investigations done and shall be recorded in the NCR form.
i) All practical steps / methods to implement this Preventive Action shall be
described by this column to ensure that the preventive action can be
implemented without ambiguity.
ii) All necessary Control Mechanisms to ensure the effectiveness shall also be
entered in the NCR form.
iii) The NCR originator prior to the closure of the NCR shall review
effectiveness of this Preventive Action taken along with the control
mechanism.
d).3 Who are authorized to raise NCR?
The Corporate QA/QC Manager of BKC authorizes and entrusts to all
personnel under the Project's QA/QC Unit to issue NCRs to concerned
production or support units, either directly identified by them or through an
external/clients sources of complaint.
d).4 Monitoring Non-Conformance Resolution Activities & NCR Closures
To effectively handle the customer complaints / Non-conformities and to keep
track of activities covering resolutions to Non-Conformities on issued NCRs to
various addressees responsible for the Corrective/Preventive actions, Project
QA/QC Manager maintains a Register of Non-Conformance Reports (NCRs)
and Status (Form No.Q-015). This register shall be updated regularly to show
in summary the status of outstanding and closed NCRs at current date. The
copy of this form is appended in this section.
Note: For issued NCR, refer to SAEP 1150 par. 9.6 for the procedure,
clearance and closure to be observed.
QA/QC Manager shall submit The Register of Non-Conformance Reports
and Status for Management Review along with all copies of NCR / Customer
Complaints.
d).5 Distribution Copies of Closed NCRs
Original Copy BKC QA/QC Unit File under the custody of Project QA/QC
Manager.
Copies Distribution:
Page 61 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
1 NCR Originator
1 NCR Addressee
1 Site Manager
1 HHI
Page 62 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Repair / Correction
Disposition can be imposed within the level of non-conformance does not
affect the reliability and safety of the item. These items found accepted after
re-inspection may be used in WORK.
Re-graded
This disposition can be effected if it can be concluded that the degree of
discrepancy cannot result to negative functional or operational use of the item,
if it is re-graded to suitable alternative level that ensures the performance,
reliability and safety.
If item is considered usable, BKC shall submit application for a waiver to SP.
The item may be used in the WORK only if COMPANY approves the waiver.
This shall be accepted after inspection by HHI / COMPANY.
Rejected
This disposition shall be governed by Contract Requirements covering
rejected items not complying with COMPANY Standards. The following shall
be observed.
Page 63 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
11.2 REFERENCE
The procurement procedures described in this plan shall be implemented in
conjunction and/or referred in the following procedures/documents.
HHI
COMPANY Contract Schedules
Sub-contract Schedules
11.4 RESPONSIBILITIES
11.4.1 BKC Engineering Department Manager
As technical support to procurement functions, his main responsibilities are:
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Page 65 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Item Description
Location of use
Quantity
Page 66 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
BKC Procurement Department shall use this list as the master guideline for the
Procurement of all the items as indicated on the list. HHI/ SEC shall provide BKC the
formats for the Purchase Order Control Log and Material Technical Submittals as may
be appropriate.
11.5.2.1 Priority Listing and Long Lead Items
The master procurement list prepared by Engineering Department shall be
reviewed by the Planning and Scheduling Unit to establish the priority listing as
per the schedules. The Procurement Department identifies the long lead items
from the master list.
Page 67 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
11.5.2.5 Expediting
BKC shall ensure that the Inspectors and/or expediters of HHI/ SEC and/or
those appointed by them shall have free access to BKC and its Vendors
offices and works.
During HHI expediting, BKC shall be responsible for giving complete and
reliable information on the purchase order status.
The information will
include shipping Schedule, issuance and progress status of any orders, critical
orders and the expected arrival dates.
BKC shall prepare and forward at regular intervals to HHI/ SEC, an up-to-date
status report of Vendors.
BKC shall expedite all purchase orders, revisions and amendments (including
vendors quotations, any applicable engineering design calculations, drawings,
spare parts data, installation, operating and maintenance instructions, other
Non- material requirements, invoices etc.) after placement of purchase orders.
BKC shall verify with vendors, before placement of an order that their deliveries
meet the required shipping schedule.
BKC shall maintain control of delivery dates established for the project.
BKC shall ensure that all vendors meet the applicable quality assurance
requirements of Sub-contract Agreement and BKC Quality Assurance and
Quality Control Procedures, as set forth in the Project Quality Plan.
BKC shall expedite the review and approval of all Non-Material Requirements
received from the vendors. These include, but are not limited to, Design
Calculation, Drawings, Spare Parts Data, Special Tools (if any), spare parts
recommendations (if applicable) and other data generated by vendors requiring
Page 68 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
BKC assigned Vendor's Inspector or its approved Third Party Inspector shall
schedule & perform source inspection at Vendor or sub-supplier fabrication
shop as specified in the approved ITP.BKC shall submit to HHI/ SEC the
Vendors test reports.
11.5.2.8 Inspection Schedule and Status
BKC shall submit each week a Three Week Look Ahead Schedule of planned
QA/QC activities for procurement and status of resolution on issued NCRs to
Vendors / Subcontractors. BKC QA/QC department is responsible for its
preparation and control. The forms to be used are shown in the appendix of
this section. The format of these forms (Q-020 & Q-015) is subject to
acceptance by HHI/ SEC and electronic copy to be provided to them
accordingly.
11.5.2.9 Procurement Inspection and Test Records
Prior to release of Vendor's item at their Production Location and after
successful test & inspection, BKC shall require the Vendor to submit all
relevant manufacturing test reports as specified on Purchase Order
requirement in
Reference to HHI acceptance criteria. These reports shall be submitted to HHI
with the Inspection Disposition Report.
Page 70 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
11.5.2.11 Packing
BKC and/or its Vendor shall ensure that the packing shall be capable of
withstanding all hazards normally encountered during transportation including
loading and unloading operations. It should protect goods from weather
conditions.
Spare parts shall be packed separately from the equipment, which they are
referred to.
The packing list (not made on headed paper) shall bear:
ii)
iii)
Page 71 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
iv)
Consignee
BKC Purchase Order reference
Clients reference no.
Materials, type of packages and total gross net weight
The full name and address of the manufacturer
v)
Packing Marking
Each package shall be well marked visibly on three sides.
11.5.2.13.Receiving
For materials directly purchased from foreign Vendors/Suppliers, BKC
Procurement Department shall be responsible for clearing the material through
Saudi Arabian customs, offloading, and inspection on receipt, delivery to the
BKC warehouse BKC shall inform HHI the status of received material.
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Welding rejection rate reported on a per joint basis for structural, and alloy
welds. A chart showing the historical performance during the project shall
be included.
Listing and status of engineering waivers requested.
QA/QC Personnel Listing by Discipline as specified in Sub-Contract
Requirements.
11A.3 RESPONSIBILITIES
BKC Material Supervisor is the overall-in-charge and responsible for the material
management at Project Site covering the following specific functions:
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
HHI.
2)
Copies of the material receipt shall be retained and filed by both HHI and
BKC. The document to be provided to BKC shall contain the following.
a.) Delivery Note
b.) Material Receiving Report
c.) Vendor Inspection Release Note; (For Inspectable Materials /
Equipment Only).
d.) Material Certifications or Manufacturing Data Records.
3)
Page 75 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
11A.6 STORAGE
11A.6.1 Warehousing Facilities
b)
Storage includes all materials, tools and equipment received and held until
they are issued for installation. BKC will submit to HHI a Material Storage
Plan to show material arrangement in segregated manner for each
classification. Refer to appendix of this section showing "Guideline for
Material Storage Warehousing" indicating mode of storage for each item
classification.
c)
Indoor storage shall be by the use of steel van containers equipped of with
shelves and bins to maintain proper segregation of materials by usage
jurisdiction and classes. All items retained their Purchase Order or Tag
Identification for retrievability and inventory control. These containers are
weather-tight, well lighted and ventilated and laid to ground with timber or
any other supports and not subjected to surface water run-off. Outdoor
Storage shall be the designated lay-down area by HHI and constructed
with seclusion fence and padlock. The area should be well drained, free
from traffic and work interface operation.
4) All weather sensitive materials like instruments, small tools, electrical wires
and delicate equipment and specialty items shall be stored in weather
proof container.
Page 76 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
11A.8.2 Issuance
Issuances of materials to construction level are covered by warehousing
proper procedure. The withdrawals of material from the warehouse or storage
areas are covered by Material Requisition Slip initiated by the responsible work
supervisor. The request identifies the material and applicable references to a
drawing and Material List except for equipment, which is by equipment
number. The warehouse distribution personnel process the form through the
established system and release the materials to the requisitioned.
The Material Supervisor posts on a daily basis all issues, returns, receipt and
balances of materials through a manual cardex system of control.
11A.8.3 Stock Location System
An accurate stock locator system is to be maintained for all items stored at the
storage site.
a) File folders for receiving records will be established including location areas
for the material.
b) Any relocation of material will be recorded.
c) A card file with a record card for each storage plot or areas will be
established. This card file will be updated constantly to reflect any changes
in material storage locations.
Page 77 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
Page 78 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
All accepted Materials shall be taken into Stock and Stock file updated
Sub-Contract Agreement
Page 79 of 81
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
12.3 Responsibility
Defines the performing units/persons responsible for the correct execution of the job
and required interfaces of Inspection Units/Persons to control and ensure attainment of
the required Quality Standards.
Third Party Inspection Companies and the services they will provide.
Inspection and Test Plans is the quality plan for each construction work phase
discipline showing in details the methods and timing for examinations, measurement or
tests to assure compliance with contract job requirements. In a matrix presentation, the
ITPs shows the following:
Task descriptions
Doc. No.:
SSPP-11-PQP-Q-43-001-001
Rev. No. : A
ADate: 30/12/2015
Contract No. B1303A-A016
The ITP are supported by suitable and approved certification forms to document all the
test and inspection to be performed during the process of the work. Checklist and Test
Record Sheets shall be the verifying acceptance of each accomplished tasks as shown
in the ITP.
END DOCUMENT
Page 81 of 81