The Project That Runs Long and the Paperwork That Does Not Follow
A school district is abating 2,400 sq ft of floor tile and mastic in a middle school during summer break. The notification lists a start date of June 9 and a completion date of June 27. The work begins on June 9, but the contractor finds unexpected additional mastic and the job runs to July 18. The district's project manager keeps the notification, the inspection report, and the contractor's accreditation certificates in a folder at the district office, not on site. The on-site supervisor has a copy of the notification but not the inspection report or the waste shipment records. The agency inspector arrives on July 10 and asks for the project records. The project manager says the records are at the district office and can be produced the next day.
1. Evaluate the recordkeeping and on-site documentation deficiencies and what the district should have done.
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The district has two problems: the project ran past its notified completion date without an updated notice, and the required records were not on site. The completion date in the notification is not a formality. When the project extends beyond the notified completion date, the owner or operator must submit an updated notification reflecting the new completion date. The district should have filed the update as soon as the extension became apparent, not waited for the inspector to ask.
The records that must be available at the work site include the notification, the inspection report and laboratory results, the contractor's and supervisor's accreditation certificates, and the waste shipment records. Keeping them at the district office defeats the purpose, which is to allow the inspector to verify compliance during the work. The supervisor's copy of the notification alone is not enough.
The district should have assembled a project file at the site before work began, with copies of every required document, and assigned the supervisor to maintain it. The project manager's offer to produce the records the next day does not cure the deficiency; the inspector may cite the failure to maintain on-site records even if the records exist elsewhere.
2. The inspector also asks for the waste shipment records for the tile and mastic removed so far. Explain what those records must show and how the district should track them.
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The waste shipment record must identify the generator, the waste transporter, and the disposal site, and must describe the waste, including the amount and the type of material. It must be signed by the generator and the transporter, and the disposal site must sign and return a copy to the generator confirming receipt. The generator must keep the returned copy. If the generator does not receive the return copy within the required period, the generator must contact the transporter and the disposal site to determine the status of the waste.
For this project, the district should have a shipment record for each load of tile and mastic, showing the quantity, the date shipped, the transporter, and the disposal site. The district should reconcile the amount removed against the amount shipped and the amount received at the disposal site. A discrepancy, such as waste that left the site but was never confirmed received, is a red flag that must be resolved.
The district should keep the shipment records in the on-site project file and in a central file, and should follow up on any missing return copies. The inspector's request for the records is a routine check, and the district's ability to produce a complete, reconciled set of records is the best evidence of compliance.