Project Procedure 1.0 PURPOSE 2.0 SCOPE 3.0 REFERENCES. No.: P /21/2012 PAGE 1 OF 12 PROJECT RECORDS MANAGEMENT

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1 Project Procedure PROJECT RECORDS MANAGEMENT 09/21/2012 PAGE 1 OF PURPOSE The purpose of this procedure is to establish the methods and responsibilities for identifying, collecting, indexing, storing, and safeguarding Project Records. This program has the following objectives: Establish consistent and cost effective management for Project Records throughout Pike. Comply with prevailing state and federal regulatory Project Records Management requirements of applicable legislation, including requirements related to litigation, government investigation, and audit for Project Records. Comply with Pike Quality Assurance and Quality Control policies and direction for records classification, document control, retention scheduling, and final disposition of Project Records. 2.0 SCOPE Project Records Management governs the handling of records generated or received by Pike in the course of Project activities, including Proposal Development, Contracting, Project Engineering and Design, Procurement, Construction, Commissioning, and Warranty work. No employee has any personal or property rights to the records of Pike, including those records that the employee has originated or helped create. All records created in the course of business are the property of Pike. An established electronic document management system (EDMS) is used as the official repository for recording and processing Project Records. A secure repository may temporarily be utilized for Project data that will be transferred to the EDMS throughout the Project. 3.0 REFERENCES 3.1 Records Management Policy, Pike Electric Employee Handbook (Corporate Records Management Policy)

2 PAGE 2 OF DEFINITIONS TERM DOCUMENT MANAGEMENT ELECTRONIC DOCUMENT MANAGEMENT SYSTEM (EDMS) OFFSITE STORAGE PROCEDURAL CORRECTNESS REVIEW PROJECT ADMINISTRATOR(PA) RECORD RECORDS COORDINATOR RECORDS MANAGEMENT RECORDS RETENTION CENTER (RRC) DEFINITION Includes the management and control of documents with emphasis on their dynamic and transactional nature, including distribution, indexing and retrieval, revision and version control, work flow, and information content to provide accountability. A computer system used to track and store electronic documents and/or images of paper documents. A remote facility for the interim storage of records prior to their transfer to a Records Retention Center (RRC). This is a Quality Assurance and Quality Control (QA/QC) activity that involves a review of Project records submitted for distribution/storage performed by the Project Administrator. The purpose of this review is to ensure that Project Records are in compliance with Project Procedures (i.e., are consistent with established Project Procedures, the correct revision number is identified, the document has been approved, and all pages of the document are included prior to processing). The individual responsible for administration duties and support to Project Management and in charge of the care, custody, and control of all Project documentation. a) Critical Record A document of long term significance that is safeguarded and duplicated to prevent its loss. b) Official Record A document furnishing evidence of the quality of an item and the achievement of Quality Program requirements. c) Project Record A record created to support specific project tasks. The individual responsible for Records Management. The systematic control of records through the records cycle creation, maintenance, archival, and destruction. A facility that is physically remote from and independent of any Pike facility for the long term storage of records.

3 PAGE 3 OF 12 TERM RECORDS RETENTION SCHEDULE DRAFT DOCUMENTS DEFINITION The published list of record groups and types identifying the retention period for all record types within any given record group. Working files, preliminary files, or in process documents that are maintained by Discipline Leads. 5.0 RESPONSIBILITIES 5.1 BACKGROUND INFORMATION PROJECT INFORMATION To define the roles and responsibilities of Project Records Management personnel, the definition of Project Information first needs to be explained. Project Information at Pike is broken down into two main categories: Project Documentation and Technical Information Project Documentation Project Documentation is the component of Project Information that is comprised of data and information generated and received by the Project Team (Project Manager, Project Controls, Engineering Manager, Procurement, Construction Management, etc.). Project Documentation includes the following: Agendas Budgets (man hours and dollars) Calculations Change Orders Contract documents and drawings Distribution Matrixes for Project Documentation Hazard Reports Job Bulletins Letters Logs/Indexes Minutes of Meeting Operations Manuals

4 PAGE 4 OF 12 Organization Charts Presentations Project Directory Project Execution Plan Project Manual Project Personnel Roster Project Schedules Project Status Reports (monthly, weekly, etc.) Purchasing documentation (Request for Proposals [RFPs], Terms and Conditions [T&C], Purchase Orders, Service Contracts, etc.) Telephone Notes (Telecons) Trip Reports and photos Any other Project support documentation provided to the Client Technical Information Technical Information is defined as the records, drawings, and documents generated by the Engineering staff and the information received from Pike s selected Vendors, Subcontractors, and Joint Venture Partners. The following information is also considered Technical Information: Design Criteria Documentation, including specific Project standards to be used Drawing lists and actual Preliminary, For Approval, and Issued for Construction (IFC) drawings (Client, Vendor, and Pike generated) Specification lists and actual specifications 5.2 PROJECT ADMINISTRATOR Project Documentation and Technical Information is under the care, custody, and control of the Project Administrator of the Project. This role may be performed by a designated Project Administrator or any members of the Project Team based on the size of the Project. The Project Administrator is responsible for the following: Setting up the Project specific document control methods and numbering system together with the Project Manager and the responsible QA/QC party

5 PAGE 5 OF 12 Managing, developing, and delivering Project Documentation in accordance with the requirements of the Contract, this procedure, and the Project Execution Plan Ensuring all Project Documentation has been properly identified and placed into the EDMS or on the secure repository Preparing the Project Documentation in an effective manner that allows effective transfer to the Records Coordinator for proper disposition of hard copy documentation Understanding the Project Scope, implementing the Project Procedures, and adhering to the Project Contract, the QA/QC requirements of the Project, and timely distribution of deliverables Make sure that the latest revisions of all documentation are being utilized in the Engineering, Design, and Construction processes Retrieving and safeguarding original Project Documentation Initiating and maintaining Client intranet and internet access Monitoring and maintaining the flow of Project Documentation and Technical Information from electronic to hardcopy to essential Project File Areas Ensuring office equipment, tools, methods, and work processes are in place to accurately and efficiently convert hard copy documents to electronic format Contributing to and coordinating all revisions of the Project Procedures with the Project Manager, Engineering Manager, Procurement Manager, Construction Management, and Administrative Services Coordinating timely transfer of Project Documentation and Technical Information between Design Offices involved in the Project Maintaining the flow of hard copy originals to the Records Retention Facility to prevent backlog during the Project and at Project Completion Reporting the status of the Vendor Drawing Review Cycle Overseeing and ensuring the flow of Technical Information does not exceed a 48 hour turnaround 5.3 PROJECT MANAGER The Project Manager is responsible for assisting the setup and overseeing the Project Records Management and Records Management Policy in accordance with the Contract requirements and the Quality Program. The Project Manager is also responsible for

6 PAGE 6 OF 12 instructing assigned personnel of the requirements of this procedure. Other responsibilities include the following: Communicating with the Project Administrator on assignments Ensuring the Project Administrator is provided with the information necessary to comply with Project Procedures Coordinating with the Client, as required, records turnover requirements (e.g., record types, media, format, or quantities as early as possible), then pass this information to the Project Administrator who will in turn alert their respective Discipline Leads Providing budget resources for the preparation and transfer of records for archive and retention Projecting and communicating the schedule for initiating the collection, protection, and disposition of records to the Records Retention Center (RRC) and Clients, as required, in accordance with this procedure and Client contractual requirements Approving the destruction of Project Records (see Section 6.10) Ensuring that only the appropriate and pertinent data is retained for archiving 5.4 ENGINEERING MANAGER The Engineering Manager is responsible for the supervision of Design and Engineering of the Project. 5.5 QA/QC MANAGER The QA/QC Manager is responsible for oversight of the set up and maintenance of Project Records Management. 5.6 PROJECT ENGINEER The Project Engineer is responsible for the following: Issuing reviewed and approved Project documents to the Project Administrator for distribution, filing, and retention Storing records on designated Project Directories/File Areas to ensure their protection and to facilitate retrieval and backup protection 5.7 INFORMATION TECHNOLOGY (IT) GROUP At the request of the Project Manager, the Information Technology Department and/or Project Records Management is responsible for establishing the EDMS Project File

7 PAGE 7 OF 12 structure and providing EDMS support throughout the duration of the Project. This also includes supporting turnover of electronic records to the Client. Upon Project Completion and instruction from the Project Manager, the Information Technology Department will archive the electronic Project documents and provide appropriate security. Archived documents may be converted to alternate software or appropriate media if the base system software is no longer supported within Pike. 5.8 INFORMATION TECHNOLOGY (IT) DEPARTMENT Information Technology shall ensure the protection of records residing on Project shared drives and Project mailboxes in accordance with this procedure. Upon Project Completion, the Project Manager will have all Project documents outside of Document Management reviewed by knowledgeable Project personnel and have appropriate documents moved to the EDMS. Upon completion, the Project Manager will request that IT migrate identified Project documents into the Records Management repository. 5.9 DOCUMENT MANAGER The Document Manager is responsible for the following: Complying with the Project Document Management and Records Management Policy Coordinating the storage of Project Records prior to transfer to the RRC Retrieval of records from the RRC 6.0 PROCEDURE 6.1 RECORDS CREATION GUIDELINES Discretion shall be used when creating records keeping in mind that records created in the course of Pike business are the property of Pike. Pike maintains the right to review and monitor all employee communications, including e mail. Employees should be cognizant that e mail is a record subject to legal discovery and may be used as evidence in court. In general, if the contents of e mail can be classified using the Records Schedule, then the record is subject to the requirements of this procedure. 6.2 RECORDS STORAGE/INDEXING An approved EDMS will be used as the official repository for recording, processing, and archiving records created during the execution of Projects. The preferred media for archiving records is electronic. The Project Administrator shall perform the following:

8 PAGE 8 OF 12 Import electronic records of a technical nature from their temporary Project locations (shared Project drives) into the EDMS Record required document information (attributes) for indexing purposes File documents in the appropriate EDMS file The Project Administrator is responsible for ensuring the Project Documentation is handled and managed in similar fashion. Attachment 7.1, Project File Structure, provides the standard template to be utilized for all projects. The Project Manager (and the Project Administrator) will work with the Document Manager and select sections appropriate for the Project. Attachment 7.3, Repository Structure, provides the standard server structure template to be utilized for all Projects. The Project Manager will determine the sections that are appropriate for the Project and will have the sections of the template selected imported into the Project location. This structure is not to be altered. Original Project Records that have been signed or initialed as required by governing Contract and Project Procedures will be maintained in both electronic and paper media. The original signed or initialed paper version of the record will be retained for legal purposes. These records will be assembled by the Project Administrator and transferred into interim storage upon Project Completion. The electronic version of the records will be used as the official record for distribution and reference. The Project Administrator shall process technical records, both electronic and original signed paper documents, as required. Required document attributes are identified and shall be recorded for indexing purposes in the EDMS. Pike Project Records shall be filed by document type, then sequentially by document number. Vendor records shall be filed by Vendor Name, Document Number, and Document Type Purchase Order Number. The Project Administrator shall establish and maintain an index/log of Project Correspondence and Project Documentation transmitted externally from Pike or received from external sources. The Project Administrator shall also manage the disposition of signed originals. Original Purchase Order files and related correspondence shall be part of the respective Project Files maintained by Procurement personnel. Copies of these records shall be turned over to the Project Administrator on an on going basis for input into the EDMS. Discipline leads may maintain working files, preliminary files, or in process documents, generally called draft documents. These files are not considered official Project Records.

9 PAGE 9 OF PROTECTION OF RECORDS The Project Manager shall ensure the protection of records developed by or for Projects. The Information Technology Department will schedule the routine backup of the EDMS and the secure repository. 6.4 RECORDS COLLECTION, TURNOVER, AND TRANSFER Upon completion of a Project or Phase (e.g., Process Design, Project placed on hold, etc.), the Project Manager will authorize the Discipline Leads and the Project Administrator to initiate the Project Records Archive and Turnover Process. The following steps are to be completed for this process: a. Indexes of technical Project Records will be generated by the Project Administrator and submitted to Discipline Leads for verification. b. Discipline Leads will verify that file indexes reflect the latest revision of officiallyissued Project Records and that these Project Records have been submitted to the Project Administrator for archive/retention. c. The Project Administrator shall ensure that retention documents are reconciled with the file indexes. Duplicate records shall be discarded. d. The Project Administrator shall forward appropriate technical records, Project Documentation, and indexes to the Records Coordinator. e. The Project Manager shall prepare a Letter of Transmittal and a receipt acknowledgement to turn over appropriate Project Records to the Client, including their respective indexes, as required by contractual requirements. f. A Records Transfer Form shall be completed identifying each record forwarded for retention or, alternately, the transfer form may be accompanied by an index, and forwarded to the Records Coordinator for interim storage (see Attachment 9.4 for a sample of a typical Records Transfer Form). Containers can be obtained from an official Pike Supplier and shall be used for the transfer of records. 6.5 RECEIPT AND CONTROL OF RECORDS BY THE RECORDS COORDINATOR Upon receipt of paper records and electronic media from the Project, the Records Coordinator shall assume responsibility for the retention copies during interim storage and provide for their protection. Interim storage will be kept to an absolute minimum, and all paper documents and electronic media will be transferred to the RRC as soon as possible. Access to retention copies in interim storage or in the RRC shall be monitored and controlled by the Records Coordinator.

10 PAGE 10 OF TRANSFER TO RECORDS RETENTION CENTER The Records Coordinator, with the concurrence of the responsible Project Manager, shall transfer retention copies and electronic files from interim storage to the RRC. The Project Administrator will periodically send original signature paper archive boxes to the Records Coordinator throughout the Project to be sent to the RRC. Because all such records are in the Project EDMS, this is intended to minimize the amount of Design Office facilities space required to store un referenced paper records. 6.7 RETRIEVAL FROM RECORDS RETENTION CENTER As directed by the responsible Project Manager, the Records Coordinator shall retrieve retention copies from the RRC and arrange for their transfer to the requesting project. Upon the transfer and receipt of records from the RRC, the recipient on the Project shall assume responsibility for records, assuring that the records remain intact, that no alterations are made, and that records are returned to the RRC within the scheduled return date. When returning retention copies to the RRC, the Records Coordinator shall forward records in the same container used by the storage facility, since they are marked to indicate their storage location. Otherwise, the new container shall be marked to indicate the same identification as the original. 6.8 RECORDS HELD FOR LITIGATION, AUDIT, OR TAX Records pertaining to anticipated future and ongoing litigation or audit shall not be destroyed until the matter is complete and the Legal Department specifically grants permission for their destruction. This requirement applies to records stored onsite, as well as offsite records. The Legal Department will advise Project Management of ongoing and anticipated future litigation as warranted via Retention Hold Orders. Once notified, Project Management is responsible for identifying onsite and RRC records affected by the Retention Hold Order and for guaranteeing the preservation of these records while the Hold Order is in effect. Legal will notify Project Management when Retention Hold Orders have expired and will remove Retention Hold Orders from records stored offsite upon completion of audit or litigation.

11 PAGE 11 OF 12 Records identified by a Retention Hold Order can be retrieved only with the permission of the Legal Department. 6.9 APPLICATION OF ALTERNATIVE MEDIA The preferred media for records retention is electronic. Projects have discretionary authority to determine the type of media for storage of existing, non electronic records, except where a particular storage medium is specified by law or prescribed under other standards. The Information Technology Department and Corporate Records Manager (see Reference 3.1) must ensure that all information can be retrieved from stored media at any time during the required storage duration DISPOSITION/DESTRUCTION OF RETENTION DOCUMENTS Pike maintains that all records, regardless of media, should be completely destroyed upon completion of their operational usefulness and upon expiration of their legal and regulatory required storage period. The records retention schedule for all documents is identified in the Corporate Records Management Policy (Reference 3.1). Upon expiration of the required storage period, all records should be approved for destruction unless there is legitimate reason to postpone that destruction. The Records Coordinator will annually provide Project Management with Destruction Eligibility Reports. Project Management should review the list and note, as applicable, records that require extended retention and the reason for the extended retention. The approval of Project Management and the Legal Department are required prior to the destruction of Project retention copies. Project Management or designee will have 30 days to return Destruction Eligibility Reports to the Records Coordinator. If Destruction Eligibility Reports are not returned to the Records Coordinator within the specified deadline, Pike will assume the consent of Project Management and the records will be destroyed. 7.0 ATTACHMENTS 7.1 Project ImageNow Drawer File Structure 7.2 Document Types for ImageNow 7.3 General Repository EDMS Structure 7.4 Transmittal Sheet (Sample)

12 PAGE 12 OF FORMS None 9.0 REVISIONS AND APPROVALS Revision Level Revision Date Revision Description Department Head (Approver) 0 01/15/2010 Original Issue Brian R. Hay 1 07/27/2011 Updated logo and company name N/A 2 09/21/2012 Updated EDMS information, as well as general updating and editing Brian R. Hay

13 ATTACHMENT 7.1 PROJECT IMAGENOW DRAWER FILE STRUCTURE PAGE 1 OF 5 Proposals Project Management Standard View Filter 01 Original Docs 02 Addenda 03 Legal 04 Bonds 05 Pricing Approvals 06 Submitted 07 Working Documents 08 Bid Results 01 Contract 01a Change Orders 02 Scope Documents 02a Consolidated Design Criteria 03 Project Set Up Docs 03a Budget Sheets 03b Estimates 03c Financial Summary 03d Job Set Up Sheet 03e WBS 04 Project Execution Plan 04a Notes and Correspondence 04b Execution Plan 04c Photos 04d Schedules 05 Progress Tracking Financial 05a Client Invoices 05b DTR Report 05c EAC Report 05d Historic Project Tracking 05e PM Reports

14 ATTACHMENT 7.1 PROJECT IMAGENOW DRAWER FILE STRUCTURE PAGE 2 OF 5 P&C Engineering Physical Engineering Standard View Filter 05f Unrecorded Liabilities 06 Project Tracking Units 07 Subcontractor Vendor Documents 07a Pricing Agreements 07b Purchase Orders 07c Vendor Invoices 07d Bid Evaluations Technical 08 Material Expediting 08a Material Tracking Reports 08b Purchase Order Log 09 Project Close Documents 09a Client Correspondence 09b Release Forms 09c Waiver and Release of Liens 09 Design Criteria 02 Site Development 06 Permitting

15 ATTACHMENT 7.1 PROJECT IMAGENOW DRAWER FILE STRUCTURE PAGE 3 OF 5 Standard View T Lines Engineering Distribution Engineering Substation Construction Filter 09 Design Criteria 02 Site Development 06 Permitting 09 Design Criteria 10 PLSCADD 01a Red Line Drawings 02 Site Development 06 Permitting 09 Design Criteria 10 PLSCADD 01a Red Line Drawings 02 Site Development

16 ATTACHMENT 7.1 PROJECT IMAGENOW DRAWER FILE STRUCTURE PAGE 4 OF 5 T Line Construction Standard View Distribution Construction Filter 06 Permitting 07a Construction Reports 07b Close out Reports 09 Materials 09a Bill of Materials 09b Bill of Lading 01a Red Line Drawings 02 Site Development 06 Permitting 07a Construction Reports 07b Close out Reports 09 Materials 09a Bill of Materials 09b Bill of Lading 01a Red Line Drawings 02 Site Development 06 Permitting

17 ATTACHMENT 7.1 PROJECT IMAGENOW DRAWER FILE STRUCTURE PAGE 5 OF 5 QA/QC Standard View Filter 07a Construction Reports 07b Close out Reports 09 Materials 09a Bill of Materials 09b Bill of Lading 01 Project Quality Plans 01a Procedures and Forms 02 Submittals to Client CQR 03 Client CQR Comments 04 Sub Vendor QA/QC Plans 05 Manufacturing Plans 05a Inspection and Test Plans 06 Preproduction Reviews and Approvals 07 Certificates of Compliance 07a Shipping Releases 08 QA/QC Training and Records 09 QA/QC Audits 10 Construction Inspection and Testing 11 Nonconformances 12 Instrument Calibrations

18 ATTACHMENT 7.2 DOCUMENT TYPES FOR IMAGENOW PAGE 1 OF 1 Attachment 7.2, Document Types for ImageNow Document Type (Key Words for Coding) Document Type (Key Words for Coding) Addenda Permits Bid Evaluations Photos Bid Results PLSCADD Bill of Lading PM Report Bill of Materials Pricing Agreements Bonds Pricing Approvals Budget Sheets Procedures and Forms Calculation Progress Tracking Finance Certificates of Compliance Progress Tracking Units Change Orders Project Close Document Client Correspondence Project Execution Plan Client CQR Comments Project Quality Plans Client Invoices Project Set Up Docs Close out Reports Purchase Order Log Const Inspect and Test Purchase Orders Construction Reports QA/QC Audits Contract QA/QC Training and Records Correspondence Red Line Drawings Design Criteria Release Forms Drawings Reports DTR Report Reviews and Approvals EAC Report Schedules Estimates Scope Execution Plan Shipping Releases Financial Summary Site Development Historic Project Tracking Specifications Inspection and Test Plans Studies Instrument Calibrations Submittals Job Set Up Submittals to Client CQR Legal Documents Unrecorded Liabilities Manufacturing Plans Vendor Documents Material Expediting Vendor Invoices Material Tracking Vendor QA/QC Plans Materials Waiver Nonconformances WBS Original Documents Working Documents

19 ATTACHMENT 7.3 GENERAL REPOSITORY EDMS STRUCTURE PAGE 1 OF 5 Attachment 7.3, General Repository EDMS Structure File Level 1 Level 2 Proposals 01 Original Documents 02 Addenda 03 Legal 04 Bonds 05 Pricing Approvals 06 Submitted 07 Working Documents 08 Bid Results Project Management 01 Contract and Change Orders 02 Scope Documents 02a Consolidated Design Criteria 03 Project Set Up Documents 03a Budget Sheet 03b Estimate 03c Financial Summary 03d Job Set Up Sheet 03e WBS 04 Project Execution Plan 04a Notes and Correspondence 04b Execution Plan 04c Photos 04d Schedule 05 Progress Tracking Financial 05a Client Invoice 05b DTR Report 05c EAC Report 05d Historic Project Tracking 05e PM Reports

20 ATTACHMENT 7.3 GENERAL REPOSITORY EDMS STRUCTURE PAGE 2 OF 5 File Level 1 Level 2 05f Unrecorded Liabilities 06 Project Tracking Units 07 Subcontractor Vendor Docs 07a Pricing Agreements 07b Purchase Orders 07c Vendor Invoices 07d Bid Evaluations Technical 08 Material Expediting 08a Material Tracking Reports 08b Purchase Order Log 09 Project Close Docs 09a Client Correspondence 09b Release Forms 09c Waiver and Release of Liens P&C Engineering 09 Design Criteria Physical Engineering 02 Site Development 06 Permitting

21 ATTACHMENT 7.3 GENERAL REPOSITORY EDMS STRUCTURE PAGE 3 OF 5 File Level 1 Level 2 09 Design Criteria T Line Engineering 02 Site Development 06 Permitting 09 Design Criteria 10 PLSCADD Distribution Engineering 02 Site Development 06 Permitting 09 Design Criteria 10 PLSCADD Substation Construction 01a Red Line Drawings 02 Site Development

22 ATTACHMENT 7.3 GENERAL REPOSITORY EDMS STRUCTURE PAGE 4 OF 5 File Level 1 Level 2 06 Permitting 07a Construction Reports 07b Close Out Reports 09 Materials 09a Bill of Materials 09b Bill of Lading T Line Construction 01a Red Line Drawings 02 Site Development 06 Permitting 07a Construction Reports 07b Close Out Reports 09 Materials 09a Bill of Materials 09b Bill of Lading Distribution Construction 01a Red Line Drawings 02 Site Development 06 Permitting

23 ATTACHMENT 7.3 GENERAL REPOSITORY EDMS STRUCTURE PAGE 5 OF 5 QA/QC File Level 1 Level 2 09 Materials 01 Project Quality Plans, Procedures and Forms 02 Submittals to Client CQR 03 Client CQR Comments 04 Sub Vendor QA/QC Plans 05 Mfg, Inspection and Test Plans 06 Preproduction Reviews and Approvals 07 Certificates of Compliance and Ship Releases 08 QA/QC Training and Records 09 QA/QC Audits 10 Construction Inspection and Testing 11 Nonconformances 12 Instrument Calibrations 07a Construction Reports 07b Close Out Reports 09a Bill of Materials 09b Bill of Lading

24 ATTACHMENT 7.4 TRANSMITTAL SHEET (SAMPLE) PAGE 1 OF 1