5.7.1 Receipt Inspection Process
The following describes the material receipt inspection process for the LBNL project team and construction subcontractors. All material to be used on a project shall be inspected using a risk based approach, with high risk materials receiving a more rigorous review. Material delivered should be previously approved by the Registered Design Professional and LBNL Facilities Engineering via the subcontractor submittal process.
Subcontractor shall establish a LBNL project team-approved staging area (lay down area) for all materials received. For projects that cannot accommodate a laydown area, project team and subcontractors will establish an alternate location (e.g., subcontractor truck, warehouse, etc.).
- Subcontractor coordinates receipt and placement of all materials to ensure they are properly staged.
- Subcontractor inspects all materials to ensure that they are consistent with the approved submittal and subcontract requirements. Subcontractor shall promptly remove from the jobsite all materials that do not meet approved submittal and subcontract requirements to ensure that they are not installed.
- After subcontractor inspection, the subcontractor notifies LBNL’s Construction Manager to inspect the material. The Construction Manager or his representative coordinates LBNL project team inspections and should, if possible, include all LBNL parties concurrently to avoid redundant inspections.
- LBNL project team reviews the approved submittal and any previously approved substitution from LBNL specifications. Project Manager is responsible for ensuring the project team receives the approved submittal(s).
- LBNL project team inspects staged materials to ensure that they are compliant with the approved submittal, LBNL technical specifications, and other applicable subcontract requirements.
- Materials that do not conform to the approved submittal, specifications, or subcontract or are damaged shall not be installed and are reviewed to determine if they are Suspect or Counterfeit.
- When non-conforming material is identified, a non-conformance report is issued by the Project Manager to the subcontractor notifying them that the material shall be removed from the site or set aside for additional review as Suspect or Counterfeit.
- If the project team wants to pursue acceptance of non-conforming material, a technical justification by the Registered Design Professional is required. The subcontractor must then follow the substitution procedures in LBNL Master Specification Section 010000, Part 1.8, paragraph E. All substitutions must be accepted by the Registered Design Professional in writing.
5.7.2 Suspect/Counterfeit Items
A suspect item is one in which there is an indication by visual inspection, testing, or other information that it may not conform to established government or industry-accepted specifications or national consensus standards. A counterfeit item is a suspect item that is a copy or substitute without legal right or authority to do so, or one whose material, performance, or characteristics are knowingly misrepresented by the vendor, supplier, distributor, or manufacturer. (Refer to “LBNL Suspect Counterfeit Items (S/CI)” webpage for additional guidance: https://commons.lbl.gov/pages/viewpage.action?pageId=118587972.)
The range of items at LBNL that should be considered as possible Suspect/Counterfeit Items includes the following:
- High-strength fasteners (bolts, screws, nuts, and washers).
- Electrical/electronic components: circuit breakers, current and potential transformers, fuses, resistors, switch gear, overload and protective relays, motor control centers, heaters, motor generator sets, DC power supplies, AC inverters, transmitters, computer components, semiconductors.
- Piping components: fittings, flanges, valves and valve replacement products, couplings, plugs, spacers, nozzles, pipe supports.
- Pre-formed metal structures, elastomers (O-rings, seals), spare/replacement kits from suppliers other than original equipment manufacturers, weld filler material, diesel generator speed governors and pumps.
DOE maintains a list of Suspect/Counterfeit Items and identification guidance on the DOE web site at http://www.sci.doe.gov.
Contact the Office of Institutional Assurance and Integrity if construction materials are found on site with the following characteristics:
- Items that look used, corroded, over-painted, over-stamped and/or stamps or markings look altered, worn or manipulated.
- Items whose Nationally Recognized Testing Laboratory (NRTL) stamps are not accompanied with a product/control ID number and/or UL stamps are not accompanied by the word “LISTED”.
- Items of the same type in the same box that vary in size and color.
- Graded hex bolts/fastener head markings that match the suspect/counterfeit head mark list provided by the US Department of Customs.
- Foreign made items that are custom built, will be used in a critical system/structure and/or will serve a critical/important function. Critical System/Function: a system, purpose or task that must be highly reliable and retain this reliability throughout its lifecycle, whose interruption or failure may result in death; serious injury; significant adverse environmental impact; the inability to complete an overall system, project objectives, or a goal that the system was designed to perform; or severe economic or reputational loss.
- Foreign made items that have other indications that the material or Certificates of Conformance paperwork is suspect.
- Certificates of Conformance cite obsolete or nonexistent consensus standards, or look like they have been manipulated or altered (pull associated equipment/material and segregate it from acceptable material).
Foreign made items identified in the contract or approved in the Procurement variance process are not subject to these requirements. NRTL stamped/marked assemblies/systems are not required to have each individual component inspected.
The Project Manager shall promptly inform, via direct contact, Facilities line management (Project Director, DCM Department Head, and the Facilities Division Deputy Director), the Office of Institutional Assurance & Integrity, and the EHS Team Lead of any Suspect/Counterfeit Items identified on a project. The presence of a Suspect/Counterfeit Item on a project may require a DOE Occurrence Report (refer to LBNL PUB‑3000, Chapter 15, and PUB‑3111, Chapter 2.3.3, "Nonconforming and Suspect/Counterfeit Items", for requirements).
To Help Expedite A&I Determinations, send photos of the entire product, the certificate of conformance, and specifically the markings or areas that are potentially suspect. Also send copies of the packing slip, inspection report, and certificates of conformance for product.