Kim Swanson: 0:03

Welcome to AASHTO Resource Q&A. We're taking time to discuss construction materials, testing and inspection with people in the know. From exploring testing problems and solutions to laboratory best practices and quality management, we're covering topics important to you.

Brian Johnson: 0:18

Welcome to AASHTO Resource Q&A. I'm Brian Johnson.

Kim Swanson: 0:22

And I'm Kim Swanson and we are here to talk about Section 3.5 on the AASHTO Accreditation Procedures Manual. It sounds very exciting just the name of that, doesn't it?

Brian Johnson: 0:36

Oh yeah, it sounds thrilling. It sounds like we're going over like an IRS schedule instruction book. But we are going to go over this and I have to. I have to mention I'm fighting a cold. I well, I guess I'm not really fighting a cold. It won, uh, by a lot and I am still recovering from the aftermath of being sick. Um, so that's why my voice sounds like it is. I don't know, maybe it doesn't sound any different, but it does. To me, it sounds a little different.

Kim Swanson: 1:05

A little different, a little bit.

Brian Johnson: 1:07

And I may have to clear my throat here and there, but hopefully Kim edits that out so you're not all subjected to that.

Kim Swanson: 1:14

I hope so too.

Brian Johnson: 1:20

Yeah, but we are going to talk about is because recently had a conversation with a customer that had some concerns about some of the requirements in the procedures manual, wondered you know how these things come about and what the process is for recommending changes, and there was a question about transparency, about how we do things and what we look for, and I felt like, well, this was also I'd considered it to be a complaint, so I sent it.

Brian Johnson: 1:56

So this is all part of the whole continual improvement process which you have heard us talk about before, improvement process which you have heard us talk about before.

Brian Johnson: 2:09

But we I had had this conversation and I had heard some of the complaints coming from this particular customer, so we sent them to our quality manager, tracy, and we said you know what we need to take corrective action here, because not because this person didn't like the requirement, that's not the corrective action, because that is what it is. What the corrective action is about is our staff didn't really understand why these things were the way they were and could not explain that to the customer, and I was also concerned that our customers don't really understand some of these things as well. So I think that there's some improvement. We can make, both in instructing our staff and instructing or getting information out there publicly to our customers and to specifying agencies in the spirit of transparency. So I felt like there was some corrective action to take on our part. So that's where we are. So this is actually part of the corrective action process, this episode.

Kim Swanson: 3:16

So everyone here, everyone is now a part of the corrective action process for us. So thank you very much. Now some background on just the app procedures manual in general. And that's what we refer to it as the app procedures manual, but it is the AASHTO accreditation program procedures manual. But that's a mouthful so I won't be saying that again, probably. So that is, it's a document that is AASHTO resources and the AASHTO accreditation program and that is part of the requirements that AASHTO accredited laboratories need to follow. So to be AASHTO accredited laboratories need to follow our AASHTO R18 and the procedures of annual for the accreditation program and the procedures manual for the accreditation program. But let's go through how, like who approves the changes or who approves the content that's in the procedures manual, not just Section 3.5, but the whole manual itself.

Brian Johnson: 4:18

This is an AASHTO product right. This is an AASHTO service. All the AASHTO technical services have some kind of oversight committee that is members of AASHTO, which are the State Department of Transportation, In our case the materials engineers. So we have an oversight committee called the ATG and that is our de facto subcommittee for handling changes to the procedures manual. So really anybody can suggest a change. Particularly a member of comp would be an appropriate committee on materials payments would be an appropriate person to recommend a change to the procedures manual. But we would also take recommendations from people you know, other interested parties, and see what the ATG thinks of those. So that's our oversight committee again. So anything that gets changed in here gets balloted through the ATG before it can be published and then used by our program. So all of these things that are in, all these documented policies and procedures that are in the app procedures manual have gone through a balloting process, review and approval and probably some editing recommended by members of comp. So that's where this came from.

Kim Swanson: 5:42

So before you go further in that, that's the same general process as an AASHTO standard, right, Like it is balloted, it is approved and edited and things like that, or is it? I know it is not an AASHTO standard, but it's the kind of the same approval process for the most part.

Brian Johnson: 6:01

It is the same process I was thinking back to when we had a big change, so back in might have been 2016,. I made some major revisions to the procedures manual and my recollection is that it only went through the ATG, but I started thinking about some of the negatives that I received and it definitely went through a full comp ballot.

Kim Swanson: 6:24

Wasn't that 2018? I feel like it was 2018.

Brian Johnson: 6:27

It may have been, I might have started in 2016.

Kim Swanson: 6:30

Oh, that's probably. That sounds more like it.

Brian Johnson: 6:32

It was a big one, so it was not easy to get it all through, but it was really in need of an update and here at this point it's in need of an update once again. We did add a lot of things back then about refusal of service and what we do with falsification of records, and I'm trying to think of some of the other things that we added, but it was pretty extensive as far as the revision is concerned. But one of the things that I didn't do back then was rearrange the document, because I didn't do back then was rearrange the document because, frankly, it is a little disjointed the way it's laid out. So my attempt this time will be to consolidate the document and try to get it to actually flow in the order in which people are interested in the topics, if they are new to the program and they're going through the process. So instead of I, I think there are like two different sections on proficiency samples and two different sections on assessments and like why, why would we do that?

Kim Swanson: 7:37

uh, so I think some of it's just general requirements and then the process, but it should really all be in one section yeah, yeah, yeah, and I'm assuming you probably did that last time just because you didn't want to change section numbers that people were familiar with and things like that.

Brian Johnson: 7:52

I'm assuming that is a big part of it.

Brian Johnson: 7:55

I well, it was more because we had so many updates to make, because it was so out of date that I didn't want to complicate that with additional changes, because sometimes so this happens and this is not a criticism of AASHTO COMP, it is true in any standards development organization Sometimes when you have too many changes, you will get negatives from members of the committee saying there are too many changes, negatives from members of the committee saying there are too many changes.

Brian Johnson: 8:27

They may not object to the content of the changes, but they may feel that it's too much, too fast. So you have to be kind of careful about how you approach some of these bigger changes, especially if you are newish to making changes, because they often will be quick to remind you that you are new to this and maybe need to get a little seasoning before you start making some changes, which I think it and now, being somebody who has a little gray hair, uh, I can I kind of understand that. Uh, because sometimes people don't understand what those ramifications are going to be, or unintended consequences, or have you know, have seen this particular item being balloted many times by many different people and without success. So there's just, you know, some considerations that need to be made, and if I had to do it all over again, I probably would have asked more questions early to avoid some complications. But that just comes with experience.

Kim Swanson: 9:28

So let's get into the meat of it. Section 3.5 of the AASHTO Accreditation Program's Procedure Manual is titled Additional General Criteria, which is super vague and gives you really no idea what this section is. So why don't you tell us a little bit about what this section in the procedures manual really is about and why it exists?

Brian Johnson: 9:52

It has a lot of different stuff in it. Some of it is good laboratory practices, some of it is what I would say falls under the category of just general requirements of the program and some of it is well, I guess it should be really under personnel some of it, and I think that was one of the things that I tried to do in the later revision. I don't want to get too much into the later revision, but I ended up trying to. I totally blew this section up and some of this stuff just got cut in the draft and some of it just got consolidated under, you know, personnel considerations, organizational considerations, facility considerations. So there's all kinds of stuff in here that we can talk about, uh, but we're going to pick through here, uh, the best we can and in in the fastest way we can, which which for me it's not very fast because I tend to go on, but Kim will cut me off, right.

Kim Swanson: 10:57

Well, yes, and I do recommend listening to all of our podcasts at a 1.25 speed or higher. So I just in general, that's how I listen to the podcast at super speed. So maybe this is an episode you should try that on with. I don't know.

Brian Johnson: 11:13

All right. Now that's going to be in my head and I'm going to be thinking that I speak too slowly.

Kim Swanson: 11:17

No, just in general. I do that for most things, so it's not just you.

Brian Johnson: 11:22

Okay, well, because you're editing too, so you don't want to hear the same thing at regular speed.

Kim Swanson: 11:26

Correct.

Brian Johnson: 11:27

That would really kill your productivity. It really would that. That being said, I did listen to a draft of the last episode we recorded and I don't know what I I don't know if I was already sick at that point, but I was speaking so slowly I don't know what was going on. But I'll try to avoid that this time okay anyway.

Brian Johnson: 11:48

Okay. So section 3.5.1 this is just about how an accredited laboratory needs to notify us anytime they have any major changes that might affect their accreditation within 60 days of the change occurring. That would be a change in ownership, relocation, major personnel changes, any other facilities or any other stuff that might have affected what they can do. Like, say, they all of a sudden lost a major piece of equipment, went down, they don't perform that test anymore. They should notify us within 60 days so that we can keep the directory up to date. And if there are actions that they need to take that we're aware of that they might not be, then we can say go ahead and do that within the next 60 days. That often happens with lab relocations. I think that is the most dominant item that comes into play here. But it can also be a change to their technical director. I think that happens a lot too.

Kim Swanson: 12:54

Yeah, another instance that I a lot too. Yeah, another instance that I was thinking of as I'm kind of skimming this as you're talking about it is if there was a natural disaster and their laboratory just got like, you know, a tornado came through or a hurricane or anything like that comes through, then they need to let us know that they are no longer operating and things like that. Correct.

Brian Johnson: 13:21

That's a great point and that happened recently. There was a really horrible disaster that happened in the East Coast where there was a hurricane that rolled through in mountainous regions of the East Coast, particularly the Asheville North Carolina area, some areas in Tennessee that got absolutely devastated. And you know, there are times when there's news that we see and we say, oh boy, you know, we hope that those people are okay, maybe somebody should check in on them. And a lot of times they'll reach out to us or we'll reach out to them in those kind are okay, maybe somebody should check in on them. And a lot of times they'll reach out to us or we'll reach out to them in those kinds of situations and then we have to figure out okay, were they affected? How badly were they affected? What do we need to do in this situation?

Brian Johnson: 14:07

And we do try to be as lenient as we can when somebody is dealing with a devastating situation like that, where we wouldn't just say okay, sorry that your building is gone and that all your people who work there were affected in such a drastic way. Here's a 60-day deadline. If you don't get back to us, we're going to suspend your accreditation. It's not really like that when there's a disaster. But even in the case where there's a relocation, sometimes there are complications that can't be helped. But we do work with people and we expect them to do their best to get back up and running. Try to identify any changes that took place that we need to reflect on the directory and get it up to date so that when they do bid on projects that it can be accurate.

Kim Swanson: 14:57

So what are the ramifications? I heard you say you know like, so we don't suspend. You know like, in a disaster we're not necessarily going to suspend right away, but is that the ramifications for not letting the Asheville Accreditation Program know of these major changes? For any of these things that we're going to talk about today, what are the ramifications?

Brian Johnson: 15:22

Yeah, and I don't want to give the idea that we don't suspend at all.

Brian Johnson: 15:25

I'm saying if there is a tragedy, we're not going to try to pile on by also suspending your accreditation while you're trying to get back on your feet. But, that being said, if you are just saying, ok, we don't know when we're going to operate, we might put the accreditation in suspension until you are operating again, so that it doesn't go Because our normal process is OK, you didn't comply with this, you get suspended, and then you have 30 days and if you don't do that, you get revoked and you're starting over. Sometimes, when people are like, hey, listen, there's a long-term thing. Can you just leave us in suspension until we're ready to start work again? While we get all this figured out and maybe it takes longer than the normal amount of time that can be okay, given that you know communicate with us, let us know what's going on and we'll work it out. But yeah, if in normal situations, if people don't notify us about things, it could lead to a suspension and then, ultimately, revocation.

Kim Swanson: 16:22

Is there anything else on 3.5.1 that we want to talk about?

Brian Johnson: 16:28

I think that's the biggest one. I mean, there's a lot in there. But the other thing is like ownership change. So if one thing we've been seeing is a consolidation of some of these smaller companies into larger companies and we do want to know about that as soon as possible, and you really want to tell us as soon as possible because business is still going on Right.

Brian Johnson: 16:48

So you may be applying for a contract or bidding on a contract. You may be applying for a contract or bidding on a contract. You just acquired this company and in order to be awarded the contract, they need to know who you are. So we want to be able to help you by properly identifying your company so that when that specifying agency looks on the directory for you, they can actually find you. So it's not just a matter of conformance. There's a good reason, a good business reason, for you telling us this information and us getting it right, gotcha. So I think that's all I wanted to say about 351. That's the biggest one, so it's not going to be like this for all of them, okay. So next one we're going to talk about is 352. It just says that the laboratory's functional organization shall be consistent with that reported by the laboratory and appear to be adequate to support their testing capabilities. So there's a couple things there.

Kim Swanson: 17:45

Okay.

Brian Johnson: 17:46

Laboratories. A lot of times, you know, for an annual review, for example, we ask the laboratory to send us an org chart showing you know who works there and who their technical director is. And let's say, we perform an assessment there and we go and none of those people are there, or the person who said that that you know they listed this one person as a technical director. They're not there anymore. Okay, well, you need to update your org chart, so there's an issue there. The other thing is they may say, well, we have two field techs. And you go there and you say, oh well, wow, you know, that seems like not very many field technicians for the size of this laboratory. And then we find out that they actually have 30 field technicians, but they only wanted to list two because they were the only certified people and they were trying to hide that. So that happens too. But we also want to make sure that the and this is a tricky one Some of these things are things that we're not going to be able to adequately assess or evaluate, but they are expectations, like the laboratory, when they get accredited, they need to say I will adhere to these right?

Brian Johnson: 19:01

So, like we usually have them, agree to these terms in 3.5 before they like, when they're filling out their initial accreditation request form and during the annual review, because I'm not really going to be able to tell if it's appropriate or adequate to support their testing capabilities. I'm going to have an idea based on how many samples are laying around, but I don't know what their customers' expectations are for turnaround. I don't know if some of these are just being retained in case there's a problem later. You could find out by asking questions. But really it's going to be hard for somebody who's there for two days once every two to three years to judge properly whether the staffing is appropriate.

Brian Johnson: 19:42

That makes sense Makes sense yeah definitely makes sense. All right. In line with that 353, interviews with supervisory and technical staff members responsible for performing tests shall indicate that the documented practices for training and assuring competency are consistent with actual laboratory practice. What does that sound like to you? Are you following?

Kim Swanson: 20:04

I'm following you. It sounds very similar to the one above it, but this is where not just the it's what they say, like it's that they're saying what they're doing and doing what they're saying, kind of thing.

Brian Johnson: 20:18

That's right. That's right. And that's when it comes to training stuff and evaluating competency. And this one actually is auditable. Because if I am at, let's say, I'm the assessor, I'm at the laboratory, I'm looking at training records and I see that everybody's been trained for the work that they're doing. And then I watch somebody run the test and they have no idea what they're doing and I say, well, this doesn't seem right.

Kim Swanson: 20:43

Yeah.

Brian Johnson: 20:44

Hey technician, when did you get trained on that? Oh, I've never been trained on this. This is the first time I've ever used this equipment. And then I look at the record and I say, boy, that's funny, Because according to this, you were trained last week on it and it was like, well, I wouldn't do that to the technician because that would probably scare them.

Kim Swanson: 21:03

Yes.

Brian Johnson: 21:03

But I would be taking note of that. That would probably scare them, but I would be taking note of that and I'd go back to whoever signed off on that and say can you please explain what happened there?

Kim Swanson: 21:13

Question then would that result in the assessment report being two separate nonconformities, one for the actual issue that they weren't trained, but then another for the app procedures manual, or no? Can you not get a nonconformity on the app procedures manual?

Brian Johnson: 21:32

No, you can definitely get a nonconformity on the app procedures manual. This could be a couple of different things. First of all, you definitely get the nonconformities related to the poor performance of the demonstration of the test. The next thing would depend on what the actual problem was. So let's say I asked the person who made up the record. I say, hey, you know, you have this record here that said that you trained the technician last week. What happened? They said well, this is how we do it. We say on this day you're going to read through all the standards and we consider that to be training. I know you're making a face.

Kim Swanson: 22:13

For people who are not watching on YouTube. I definitely made a face at that.

Brian Johnson: 22:17

Yeah, you're making a face, but this happens. This happens so a lot of times. When people write a procedure about how to train people, it starts with have the technician read the standard, but then it it should. Step two is show them. Show them how to do it Right.

Kim Swanson: 22:35

Yes, I'm like that's a fine first step, but there can't be the last step unless it's a very simple standard.

Brian Johnson: 22:43

Yeah, we've had people talk to us about you know you really have to define what training is and I think, well, that's kind of the dictionary definition of training, right?

Kim Swanson: 22:51

Yeah.

Brian Johnson: 22:51

You're teaching somebody how to do something, so people get creative as to how they would like to define that and I would say it's not very effective training to just say read this and figure it out. That's not real training. But people do it because they're trying to go quickly and they don't have time and they're under stress. So that's a different finding right.

Kim Swanson: 23:16

Yeah, yeah.

Brian Johnson: 23:17

That's a much different finding than you completely made all these records up, gotcha Right, gotcha Right. So completely, completely made records up as falsification could lead to revocation, refusal of service, all of these severe consequences. But did a bad job. Training is just. You need to make some improvements here, like you have to seriously train people. Yeah.

Kim Swanson: 23:41

Well, I mean quickly I can see where, if you have a really seasoned technician who has been doing it for years, maybe training, just reading, it is enough. But uh, but yeah, maybe not for everyone.

Brian Johnson: 23:53

That's. That's something that comes up there's. There is something in in the in R18 about training that says you know, if somebody comes in with prior experience, you can just evaluate their competency.

Kim Swanson: 24:05

Yeah.

Brian Johnson: 24:06

But that's still a thing. That is still a thing you are doing. Yes, to ensure that that person knows what they're doing. Now you're paying this person to perform the test according to the standard. Your company name is on there. You're probably signing off on it. You want to make sure they're doing it correctly, right?

Kim Swanson: 24:25

Yeah, for sure. Yeah, seems obvious.

Brian Johnson: 24:26

Yeah, seems obvious.

Kim Swanson: 24:27

Yeah.

Brian Johnson: 24:28

So take the time to do it. You don't have to spend forever on it, but you need to do it. Anyway, that was a tangent that was a tangent and I apologize I contributed to that tangent and I apologize.

Brian Johnson: 24:41

That's quite all right. That's quite all right. Okay, now let's move on to the next one Laboratory Right, that's quite all right. Okay, now let's let's move on to the next one. Laboratory operations shall not be impaired by management problems. Wouldn't we all like to say we are not impaired by management problems? Right? Everybody listening to this would like to say that, but we can't all say that all the time. Now, this is one that I would say is very hard to include in a report.

Brian Johnson: 25:04

Yeah it would have to be a pretty severe case yeah for us to say, to conclude, after two days or however long they're there that they are somehow impaired by management problems. I have gotten, as when I was an assessor, I was very close to writing this really a few places. Yes, because they were clearly impaired by management problems, but that wasn't all that they were impaired by, so it would be hard for me to isolate that to strictly management.

Kim Swanson: 25:32

How are we defining management problems, like impaired, like that seems very subjective, like you were saying it's totally subjective. So how do we define that and how do we make sure that laboratories, laboratories who agree to this, and you know are meeting our intent of this is a very.

Brian Johnson: 25:51

This is a very difficult one and it I like it being in there. I always like things being in our back pocket in case we need to, in case we need to use them. Because if you, if you run into a situation where we say, okay, let's say I go to a laboratory where the management has totally run this place into the ground and there is no doubt that that's what's going on, what do I write the technician? You know, I could. I could just write the technician didn't do things the right way, equipment wasn't calibrated doesn't really tell the story. Yeah, somehow there's some like management has got to be called out, somehow, I think yeah but.

Kim Swanson: 26:30

I see, I see your point, but then I also on the on the other side of it. If it's that impaired, it's going to show up everywhere else too, so that it does yeah, so it's not going to be the only thing that, uh, you're going to get a non-conformity on.

Brian Johnson: 26:42

If that's the case, I'm assuming- and really if, if you have an organization that cares, somebody above that manager is going to be reading these reports and say this can't be normal right, yeah. And they'll probably talk to their friends in the industry and say, is it normal to get 130 nonconformities on your assessment report? And they'll say, no, that is not normal. We don't get anything like that. Um, I, I do.

Brian Johnson: 27:09

I don't want to get into details on exactly what happened, because whoever it is, if they're listening, will know it's their lab. But I was at a lab that was definitely impaired by management problems. Uh, there was, there was a, a clear lack of care, uh, by management, because when any time and this happened several times during the assessment that the technician or supervisor went to management to ask questions or get help or say can we please replace broken down equipment or make tiny changes to make things better, the answer was always no, no, no, no. And some of these we don't get into safety, but some of them were clearly safety issues and if it cost anything, the answer was no. So to me and otherwise, no engagement from said manager, from said manager. So I would say, in that case, while my again, I'm there for a couple days over two to three years span.

Brian Johnson: 28:15

Yeah, interviews with staff observations indicated there was a problem with management there. Yeah, um, however, I don't know all the extenuating circumstances, so you, you didn't end up writing it.

Kim Swanson: 28:26

I didn't end up writing it, I didn't I was very.

Brian Johnson: 28:28

That's the closest I ever got to it. I don't think I ever actually wrote that yeah so maybe it doesn't need to be in there, because I, I was, I was on the edge, yeah anyway, something to think about future, future improvement about it maybe maybe, maybe the ballot will have something about that or it would be worded differently.

Brian Johnson: 28:47

Next one also touches on management. Laboratory asked that managerial staff with the authority and resources needed to discharge their duties. That may have been a problem. So let's say I wrote up they were impaired by management problem and manager says it's not that. I have problems, it's that I don't have the resources or the authority I need. So then the problem goes up the chain or up the chain, and maybe that person doesn't care either. I don't know. See, this is where it gets difficult. It does it really?

Kim Swanson: 29:16

does when you're trying to.

Brian Johnson: 29:22

you really want to see people embrace continual improvement, right. But if they don't want to do it, it's very hard and eventually you hope that they just kind of either improve or leave the program because they really shouldn't be accredited if they really don't want to get any better. Other ones laboratory mischief maintain ratio supervisory to non-supervisory personnel which ensures adequate supervision. Very hard for anybody to tell if that's correct or not, even if you see issues. Hard to tell. So that one I don't love, even though I mean I love the concept, but very hard to enforce. Another one laboratories shall provide effective separation between neighboring testing areas which are incompatible which are incompatible.

Kim Swanson: 30:05

So for that, is that another laboratory like a different business, or is it just like I have my aggregate testing in this room and my concrete testing in that room, or whatever?

Brian Johnson: 30:19

I made those up because I don't know, yeah, and I don't really know what was in mind with that particular line. I can think of a couple scenarios in which the one type of testing could negatively impact the other type of testing, like if there were temperature control issues, if there were vibration issues.

Kim Swanson: 30:39

Yeah, that's what I was thinking of.

Brian Johnson: 30:45

The Proctor hammer going and messing up a balance or something. I think that's the best example and messing up a balance or something.

Brian Johnson: 30:45

I think that's the best example. So if I had a hydrometer a soil hydrometer on a bench top that was getting vibrated by either a mechanical shaker, a compaction device of some kind, or every time a compression machine would break a cylinder, it rattles the whole laboratory and affects the hydrometer readings. Something like that might be what was intended there, but I think that would be. I don't know that anybody's ever written that one up. Usually people know enough not to do that, but I guess anything's possible. I know anything's possible based on my experience.

Kim Swanson: 31:30

Well, I think this is going to have to be a two-parter, brian, because I feel like this is so much stuff and we are only at 3.5.7 or something right now, so I think this might be a good time to end and we'll pick up the rest of it in part two. What do you think?

Brian Johnson: 31:47

I think that's good. As usual, I've gone on too long.

Kim Swanson: 31:51

Well, I think I didn't help the matter at all anyway, but before we go, I do want to let people know about the 2025 Actual Resource Technical Exchange happening March 17th through the 20th in Bellevue, washington, and, as of the recording of this episode, we do have a draft agenda and some registration information on our website and you can find that at ashtoresourceorg slash events. Thanks for listening to AASHTO Resource Q&A. If you'd like to be a guest or just submit a question, send us an email at podcast at ashtoresourceorg or call Brian at 240-436-4820. For other news and related content, check out AASHTO Resources social media accounts or go to ashtoresourceorg.