106.12 Qualified Lists (QL) and Pre-Acceptance Lists (PAL)
106.12.1 Qualified Lists
The Qualified Lists (QL) are lists of materials and suppliers that have been evaluated by the department and determined to comply with the specified requirements of the Standard Specifications. The materials on the QLs need to be inspected and reported by District Materials personnel before incorporating them into the project. Information on how QL materials are inspected can be found in the respective material details sections of the Standard Specifications. The QLs can be found on MoDOT’s website at https://www.modot.org/materials-qualified-lists.
106.12.2 Pre-Acceptance Lists
Manufacturers and material components may have a Pre-Acceptance list (PAL) included in this article. Construction and Materials will take every reasonable precaution to ensure that the lists are kept current, however if there is a question, Construction and Materials should be contacted. There are occasions when items are dropped from the list. If the deletions are critical, the district will be advised by letter or other communication. Otherwise, deletions and additions will be taken care of with subsequent article updates. Specific producers and/or specific products will be listed with an expiration date, depending on the material. This date designates when the item’s Pre-Acceptance will be terminated and should be referenced to verify the PAL status, prior to the use of that material.
The PAL Inspection Guide assists the inspector in performing a thorough PAL Facility Quality Assurance Review.
Pre-Acceptance lists indicate materials or sources that have complied with the pre-acceptance requirements of the specification and have committed to providing specification compliant material. (See New Product Evaluation Form.) After an initial transition period, materials that have a Pre-Acceptance List will require PAL inclusion for acceptance. During the transition period, materials that have a PAL may be accepted by PAL inclusion or an alternate inspection procedure. All PAL material will be considered for acceptance in accordance with the appropriate specifications.
106.12.2.1 Responsibility
106.12.2.1.1 Construction and Materials Responsibility
Construction and Materials, also referred to as Materials (or Central Office – Materials), is responsible for the following regarding the PAL inspection program:
1) List Maintenance
Evaluation of material products for pre-acceptance will be coordinated by Central Office Materials. Inclusion and removal of materials or sources from the lists will be the responsibility of Central Office Materials. Frequency of testing will be determined or approved by Materials. The expiration date shown for a company or product will be three years from the first day of the month following the month in which approval of the company was granted. Approval of each branded product will be handled independently. A company may submit reapplication at any time and a new three-year approval will be established if the application is in order. If the company is simply renewing its application, and none of its product listing has changed, they need only complete Form M-STMNT (GS-13 Form 4) in full. If a company is renewing its application and the product listing has changed, a New Product Evaluation Form should be completed in full for each changed product. A product listing change includes a formulation or other physical or chemical change in a product. All pertinent product documentation required by the applicable Specification and New Product Evaluation Form should be included. Form M-STMNT (GS-13 Form 4) should also be fully completed. Reapplication cannot be used to offset the status of any material or producer with regard to PAL failures.
2) Removal from PAL for Sample Failure
In general, removal of a PAL material or source for sample failure will occur upon the second failed sample in any 12 consecutive months. However, Materials reserves the right for immediate removal upon any failure, if such action is deemed necessary based on specific circumstances. The Producer/Supplier will be notified of the first failure, and any subsequent failures, by written letter under the signature of the State Construction and Materials Engineer. The letter will be sent via certified mail, with return receipt requested. The letter will be kept on file at the Central Office and district PAL representatives will be made aware of the failure and that notification to the Producer/Supplier has been made. The date of the letter will serve as the start date for the beginning of the probationary period or suspension period. Removal for reasons other than sample failure will occur as indicated in the specifications.
- PAL Review Committee. A committee will consider all PAL probationary or suspension actions relative to the PAL process. The committee will include the Chemical Laboratory, Physical Laboratory, the Assistant State Construction and Materials Engineer, and two Construction and Materials Liaison Engineers, one with a materials background and one with a construction background, as selected by the State Construction and Materials Engineer. The materials Construction and Materials Liaison Engineer will arrange a meeting of the committee when so requested by any committee member. Three members of the committee must agree to any action recommended. The recommended action is forwarded to the State Construction and Materials Engineer for approval.
- PAL Review Process. The PAL review process will be initiated for: failure of a material to meet specifications, failure of a PAL participant to provide proper documentation, failure of a PAL participant to facilitate the inspection process as necessary, or other reasons where a participant might be removed from the Pre-Acceptance List. When a failure occurs, the district inspector is to be notified of the failure. The district will determine the disposition of the failed material. When the material is located in more than one district, the materials Construction and Materials Liaison Engineer will coordinate a determination of appropriate disposition of the material.
3) PAL Material Arrival Confirmation
- Project Specific Material. Upon determination by the manufacturer, supplier, wholesaler, or contractor, that PAL material will be delivered to a project, they must notify Central Office Materials. The notification must include the contractor, contract number, the specific line item number that the material will be used on, the material, the manufacturer of the material (if there are multiple locations for a manufacture, the specific manufacture must be listed), the heat/lot/batch number of the material, the brand name of the product (if applicable), the shipping date, and the quantity to be shipped. (See GS-13 Form 3.) This notification will allow Materials to determine what material is being delivered, if the specific material indicated is an acceptable PAL material, and how much material is to be expected. When the brand name (manufacturer) or shipping date is not firm at the time the form is submitted, they can be predicted. If any prediction is subsequently determined by the shipper to be incorrect, the shipper shall re-submit the GS-13 Form 3, which includes the PAL Identification Number, with the corrections clearly indicated. A handwritten correction of the original form is acceptable. Shippers are allowed to submit the form with predicted values to accommodate their need to have the PAL Identification Number early in the fabrication or manufacturing process. All documentation required by the specification shall be retained on file by the entity submitting GS-13 Form 3, for a period of two years. The information must be made available to the MoDOT inspector upon request.
- Upon receipt and review of the form, Materials will create a sample record for the material, in AASHTOWARE Project (AWP), and notify the manufacturer, supplier, wholesaler, or contractor of the sample ID number. This sample ID will be the “PAL Tracking Number” for the material. The manufacturer, supplier, wholesaler, or shipper shall attach the phrase “PAL” plus the provided number, to the material, so that all material represented shall be readily and accurately identifiable with a tag or label. This will require every bucket, tote, box, or bundle be identified with a tag or label containing the PAL Tracking Number. Immediate use of material properly identified with a PAL Tracking Number is acceptable. The intent is to make the PAL Tracking Number obvious on the tag or label. Inspectors are encouraged to notify Construction and Materials when the tag or label provided does not fulfill this intent adequately.
- Value Added (General) Material. Upon arrival of PAL material at a fabrication, production or mixing facility, (this includes steel fabrication, pre-cast, pre-stress and ready-mix facilities) notification must be sent to Materials. The notification must include the facility name and location, a contact person at the fabrication facility who will be responsible for PAL material concerns, the material, the manufacturer of the material (if there are multiple locations for a manufacture, the specific manufacture must be listed), the heat/lot/batch number of the material, the brand name of the product (if applicable), the arrival data, and the quantity. (See GS-13 Form 2) In most instances, this notification is the responsibility of the facility; however there will be instances where the facility seldom receives PAL material. The MoDOT inspector at that facility is encouraged to assist with submission of the appropriate information. This notification will allow Materials to determine what material is being delivered, if the specific material indicated is an acceptable PAL material, and how much material is involved. Upon receipt and review of the required documentation, Materials will then be responsible to create a sample record for the material in AWP and notify the fabrication facility of the sample ID number. This sample ID will be the “PAL Tracking Number” for the material. The fabrication facility shall attach the phrase “PAL” plus the number to the material, or post the Receiver’s GS-13 Form 2, so that all material represented shall be readily and accurately identifiable. Immediate use of material properly identified with a PAL Tracking Number is acceptable.
- Exempted Facilities. Facilities that are responsible for the “Shipper’s PAL Material Transmittal Form” will not be required to submit the “Fabricator’s PAL Material Receival Form”. Documentation at these facilities will be checked periodically during on-site quality assurance reviews. The facility must retain the documentation on file for one year from the final handling of the material. The documentation must be filed so a representative of the facility can provide it to the inspector within a few minutes of any request.
- Authority. The State Construction and Materials office is responsible for ensuring that the PAL Tracking Number is generated by someone that has the authority and expertise required to make the determination that all PAL requirements have been met. The determination of acceptability shall not be made until all required documentation has been received and verified to be correct.
- Emergency Shipping. There may be instances when a PAL approved manufacturer, supplier, wholesaler, or contractor must ship PAL material immediately and they are not able to obtain a PAL Tracking Number. With prior approval from Materials, the manufacturer, supplier, wholesaler, or contractor may issue a PAL Tracking Number to themselves. The manufacturer, supplier, wholesaler, or contractor is still required to notify Materials of the shipment, as soon as possible, by use of GS-13 Form 3. The form shall include all of the required information, including the self-assigned PAL Tracking Number(s). Company initials for use in the sample ID will be assigned by Materials and the sample ID will have the form laid out in Sample Record General Information. PAL Tracking Numbers issued by a manufacturer, supplier, wholesaler, or contractor are for emergency situations only. It is not the intention that this method be used on a regular basis.
106.12.2.1.2 District Responsibility
Each district office shall have the following responsibility regarding the PAL inspection program:
1) District PAL Representative
Each district shall designate a district materials employee to be their PAL representative. This person shall be the contact for any PAL related concerns and will represent the district in any meetings and training required on PAL topics. If contacted by a manufacturer, supplier, wholesaler or contractor regarding acceptance into the PAL system, the district is encouraged to provide assistance in the application and any routine PAL processes. Any member of the district with knowledge of the PAL system can provide assistance.
2) Construction Inspection
Construction personnel at the project site will review any PAL material that arrives, for general condition and apparent compliance with the applicable specifications. Material that appears to be specification compliant and that has a proper PAL tag attached may be released for use by the contractor. The PAL I.D. number and a basic description of the material will be recorded by the construction inspection staff for confirmation of the AWP record. The AWP sample record will be reviewed to confirm that the material received and the material reported matches. The match will be documented in the AWP record as a remark or (Services) disposition remark. (Refer to Disposition Remarks for PAL Materials). The remark will include the inspector’s userid, the date, and the comment “material received”. In the event that the material does not reasonably match the sample record description, District office and Materials are to be notified by the inspector. Generally, material that is not accepted due to errors in the PAL documentation, such as tagging, is NOT rejected, it simply must be held for correction. If it is not PAL specification compliant, it is not acceptable, but it should not be “rejected” unless the material itself is not specification compliant.
3) Materials Inspection
Inspection requirements for PAL materials will be as required by the specific section of the Standard Specification, the Standard Plans and the Engineering Policy Guide, except that the frequency of required samples shall be as required by Materials. The PAL inspection policy may reduce the number of samples required, but will not reduce the detail or thoroughness of the inspection. During the transition to PAL from traditional inspection processes, material may be accepted other than as indicated in the applicable EPG articles or sections of the specifications.
4) District PAL Facility Responsibility
Each district shall run the Cognos 8 report “District PAL Producer Responsibility” to determine which PAL facilities their district is responsible for inspecting. This report should be run periodically to ensure that the district is aware of all new and removed facilities. If a district feels that a facility has been incorrectly assigned to them, they should notify Materials immediately.
5) Frequency of Facility Review, Sampling and Testing
Each district shall run, for each facility assigned to their district, on a near monthly basis, the ReportNet report “Facility Review Summary for designated date range” to determine which materials and facilities should be sampled and inspected. The report displays information on shipment, sampling and visits for the PAL facility selected. If a significant quantity of material has been shipped from the facility, that facility should have a PAL Facility Quality Assurance Review. At the discretion of the district, PAL Facility Quality Assurance Reviews may be conducted on a quarterly basis.
A detailed explanation and walkthrough of a PAL Facility Quality Assurance Review are provided in the PAL Inspection Guide. The inspector is encouraged to use the PAL Inspection Guide to ensure that a thorough PAL Facility Quality Assurance Review has been performed. At a minimum, the inspector should review the procedures outlined in the PAL Inspection Guide and be aware of what a complete and proper review includes. The PAL quality assurance inspection of material should always be performed after the plant personnel have conducted their quality control and testing on the material. It is important that the producer be given the opportunity to segregate non-compliant material as part of their quality control process. The quality control process must reliably eliminate suspect material from possible shipment to MoDOT projects.
There are some PAL facilities that are only a distributor of PAL material. These facilities still require a PAL Facility Quality Assurance Review and the frequency will be determined as described above. The procedure for performing a PAL Facility Quality Assurance Review at a distributor is also included in the PAL Inspection Guide. The inspector has the option of sampling any PAL material at any time and any location to ensure compliance with the PAL program.
There are some PAL facilities that rarely ship material directly to the jobsite and instead ship to other PAL facilities for distribution. These facilities still require a PAL Facility Quality Assurance Review and the frequency will be determined as described above. A visit to one of these facilities should, at a minimum, include a review of PAL documentation and procedures. The inspector may sample PAL material at the facility or obtain a sample from the PAL facility to which it was shipped. If the PAL facility to which the material was shipped is located in another district, the inspector may request that district to sample the material at that PAL facility.
Create an AASHTOWARE Sample Record
Samples taken should be detailed in AWP as "Quality - PAL Related Record or Sample" and linked to the appropriate PAL Tracking Number (a sample ID number), when applicable. The sample ID assigned to a PAL quality assurance sample shall conform to Sample Record General Information. One sample record, using the Material Code 106XXPAL, shall document the findings of the inspector on that date with regard to accessibility and completeness of material documentation, cooperation of facility staff in the documentation review, accessibility to the operation and to samples, assistance with sampling and facilitation of any field testing required.
6) Sampling and Testing at the Jobsite
It is the responsibility of district Materials to ensure that all required samples are taken and field tests performed. Additional samples may be taken at the discretion of the district or as directed by Materials based on the concerns of any MoDOT inspector that has contact with the material. The manufacturer and/or contractor should be notified of the impending sample so they can make the appropriate adjustments to their shipment. Whenever possible, this notification should be made in advance of the shipment. The district should be aware that use of this material is not pending sampling and testing unless some deficiency is observed or suspected, and thus care should be taken to ensure proper, adequate samples are taken and that submittals and contact regarding material concerns should be handled in an expeditious manner. Samples taken at the direction of Materials should be detailed in AWP as "Quality - PAL Related Record or Sample" (Sample Type) and be linked to the PAL Tracking Number (sample ID number). Samples taken at the discretion of the district based on suspicion of contamination, poor handling, or other problems not directly attributable to the manufacturer should be designated “District Project” or “District General”. Report the sample to the contract number, but show quantity as zero. The sample ID assigned to a "Quality - PAL Related Record or Sample" shall conform to Sample Record General Information.
7) Maintenance Purchase Order Sampling and Testing
Material presented to MoDOT to fulfill a purchase order is to be in accordance with PAL if the bid documents reference the Standard Specifications or a Materials General Services Special Provision (MGS) that requires PAL compliance. If the bid documents do not reference the Standard Specifications or an MGS requiring PAL compliance, the material will be inspected for general appearance, conditions after shipment, and to confirm specification compliance based on field tests performed by the inspector and the requirements of the maintenance purchase order and bid documents. Material acceptance or rejection is to be reported in AWP. A copy of the report is to be provided to district procurement services when districts processes require it prior to payment to the supplier.
8) Transferring PAL Material to Other Contracts
There may be times when PAL material can be transferred to another contract. An example would be concrete pavement curing material, leftover from a previous contract. Approved PAL material may be transferred to another contract upon approval from the engineer. The material cannot be transferred after the initial 3-year period date, beginning with the original sample date. The material shall meet current specifications regardless of specifications in place when initially approved or purchased, and still performs as intended. Disposition remarks shall be added to the original sample record to indicate the quantity of material being transferred, and which contract the material is transferring from and transferring to. Transferred PAL material shall be delivered to the correct project location and shall be in good condition as noted above. The transferred PAL material shall have the proper labeling.
PAL material transfers are initiated by submitting a Request for Transfer of Inspected Material form from the District the material currently resides (also see EPG 106.20.6). If the transferred material will remain in the same District but will transfer to another contract, the Request to Transfer form is still required.
106.12.2.2 Sampling
The material shall be sampled and tested as indicated by the applicable specification, except that the Central Office may designate sample size at the time the sample is requested. The PAL specification requires that the contractor or material supplier obtain a representative sample of material when so designated by MoDOT. The MoDOT inspector will designate the material to be sampled and will observe the sampling process. The name of the sampler will be recorded in the sample record. Any deviation from good sampling procedures will be documented in the sample record remarks. It is the responsibility of the material manufacturer to provide instructions for obtaining a representative sample. These samples may affect the manufacturer’s ability to remain on PAL. It is critical that potential sampling errors be documented in detail.
Discretionary Sampling. The district may sample any PAL material any time the quality of the material is suspect. Such sampling and testing may cause rejection of the shipment or require other remedy to correct any deficiency, and may affect the material’s status on PAL.
106.12.2.3 Reports
106.12.2.3.1 Material Acceptance
At the time a PAL Identification Number is assigned, the material is considered conditionally accepted and, an AWP Sample Record is created to provide the PAL Identification Number and to be the final material acceptance report.
106.12.2.3.2 Material Rejection
Conditional acceptance is based on the PAL process and may be revoked for material damaged in transit, material that is not accurately represented when the PAL Identification Number was obtained, or material subsequently sampled and tested as part of the PAL quality assurance process, which fails.
Central Laboratory Rejection. When a sample fails to comply with specifications or when material is found to be unacceptable for use, the material will be rejected, and the sample record associated with the material will be marked rejected. The inspector that submitted the sample will be informed of the failure and will then be responsible for notification of the contractor, shipper, and appropriate MoDOT personnel regarding the material failure and any action expected related to disposition of the represented material. The inspector will be responsible for any AWP records necessary to remove the material’s posting to any contracts. The record should detail explicitly that the material was submitted for use and acceptance based on PAL inspection practices, and shall indicate the PAL Identification Number and the cause for rejection. The inspector is not responsible for any action regarding the shipper’s Pre-Acceptance Listing.
Field Rejection. When a sample fails to comply with specifications or when material is found to be unacceptable for use, the material will be rejected, and the sample record associated with the material will be marked rejected. The inspector will be responsible for notification of the contractor, shipper, and appropriate MoDOT personnel regarding the material failure and any action expected related to disposition of the represented material. The inspector will be responsible for any AWP records necessary to remove the material’s posting to the contract. The record should detail explicitly that the material was submitted for use and acceptance based on PAL inspection practices, and shall indicate the PAL Identification Number and the cause for rejection The inspector will notify the Central Office of the failure so action regarding the shipper’s Pre-Acceptance Listing may be taken by the Central Office.
Disposition of Rejected Material. Use of the rejected material will cease immediately and a determination will be made as to the acceptability of any material in place.
106.12.2.4 PAL Inspection Guide
The PAL Inspection Guide assists the inspector in performing a thorough PAL Facility Quality Assurance Review. District PAL Facility Responsibility and Frequency of Facility Review, Sampling and Testing describe the steps that shall be followed in preparation for this inspection. If the ReportNet reports “District PAL Producer Responsibility” and “Facility Review Summary for designated date range” have not been run, please refer to the afore mentioned sections. The frequency for this inspection is also described in EPG 106.12 Pre-Acceptance Lists (PAL).
A PAL Facility Quality Assurance Review can be divided into two types; manufacturer review and distributor review. Manufacturers are facilities that produce a PAL material. Distributors are facilities that do not manufacture PAL material, but ship PAL material, manufactured by other companies, directly to the job site. Each of these types of PAL Quality Assurance Review has different procedures, and will be covered separately and in detail.
106.12.2.4.1 Manufacturer – PAL Facility Quality Assurance Review
A review of the manufacturer’s certifications and test results is required on a PAL Facility Quality Assurance Review. The manufacturer is required to supply these documents to the inspector upon request.
| Are the manufacturer’s documents kept on file, at a minimum, for the period of time required by the applicable Specification Section? If No, notify Construction and Materials for assessment. | Yes | No |
| Are the manufacturer’s certifications and test results easily relatable to their production lots, batches or heats? If No, notify Construction and Materials for assessment. | Yes | No |
A walk-through of the manufacturer’s storage facilities should also be included with this visit.
| If the manufacturer stocks MoDOT compliant and non-MoDOT material, is the material segregated or easily distinguishable? If No, refer to the options below: | - | - |
| Option 1: Notify the manufacturer that if they do not segregate MoDOT compliant and non- MoDOT material, there is a possibility that non-MoDOT material will be sampled. A note should be made in the Remarks or Free Form test of the PAL Facility Quality Assurance Review AWP sample record indicating that there may be a problem with the manufacturer’s method of distinguishing MoDOT material from non-MoDOT material. | ||
| Option 2: If the manufacturer continues to stock MoDOT compliant and non-MoDOT material together after they have been notified of the consequences, sample material that may not be intended for MoDOT use. | ||
| Are there any materials that may be stored in a way that could negatively affect the properties of the material causing it to not be specification compliant? If Yes, refer to the options below. | Yes | No |
| Option 1: Take a sample of the suspect material in addition to any samples already taken. | ||
| Option 2: Make the manufacturer aware of the concern. Re-examine the storage of the material upon the next PAL Facility Quality Assurance Review. | ||
Finally, samples of materials shall be taken in accordance with the applicable section of the Engineering Policy Guide. At a minimum, one sample, or group of samples, shall be taken for those materials that have shipped significant quantity to a MoDOT jobsite. Samples shall be submitted to the Central Laboratory for testing. Additional samples may be taken and tested at the manufacturer’s facilities at the manufacturer’s request. These test results will not be considered for PAL Quality Assurance.
| Was the manufacturer able to easily locate the selected lot, batch, or heat for sampling? If No, notify Construction and Materials for assessment. | Yes | No |
| Did the manufacturer properly obtain the samples? If No,refer to the options below. | Yes | No |
| Option 1: Make the manufacturer aware of their potential sampling error and suggest they resample the material. | ||
| Option 2: If the manufacturer has previously been made aware of their error in sampling procedure, notify Construction and Materials for assessment. | ||
| When tested, does the material meet the requirements of the specification (if applicable)? If No, notify Construction and Materials for assessment. | Yes | No |
Upon completion of your PAL Facility Quality Assurance Review, create an AWP sample record as described in Create an AASHTOWARE Sample Record. Also create additional AWP sample records as required by the applicable Engineering Policy Guide article for each sample taken.
106.12.2.4.2 Distributor – PAL Facility Quality Assurance Review
A review of the certifications and test results, provided by the manufacturer of the material to the distributor, is required on a PAL Facility Quality Assurance Review. The distributor is required to supply these documents to the inspector upon request. The distributor may be allowed to contact their central office, or the manufacturer, to obtain these documents, but the documentation must be supplied in a timely manner. A random selection of certifications and test results should, at a minimum, be reviewed for those materials that shipped in significant quantity to a MoDOT jobsite.
| Was the distributor able to supply the required documents to the inspector in a timely manner? If No, notify Construction and Materials for assessment. | Yes | No |
| Are the documents easily relatable to the material that they were supplied for? If No, notify Construction and Materials for assessment. | Yes | No |
A walk-through of the distributor’s storage facilities should also be included with this visit.
| If the distributor stocks MoDOT compliant and non-MoDOT material, is the material segregated or easily distinguishable? If No, refer to the options below. | - | - |
| Option 1: Notify the distributor that if they do not segregate MoDOT compliant and non-MoDOT material, there is a possibility that non-MoDOT material will be sampled. A note should be made in the Remarks or Free Form test of the PAL Facility Quality Assurance Review AWP sample record indicating that there may be a problem with the manufacturer’s method of distinguishing MoDOT material from non-MoDOT material. | ||
| Option 2: If the distributor continues to stock MoDOT compliant and non-MoDOT material together after they have been notified of the consequences, sample material that may not be intended for MoDOT use. | ||
| Are there any materials that may be stored in a way that could negatively affect the properties of the material causing it to not be specification compliant? If Yes, refer to the options below. | Yes | No |
| Option 1: Take a sample of the suspect material in addition to any samples already taken. | ||
| Option 2: Make the distributor aware of the concern. Re-examine the storage of the material upon the next PAL Facility Quality Assurance Review. | ||
There may be instances where the district performing the PAL Facility Quality Assurance Review has been requested by another district to sample a material. Reasons for this include, but are not limited to; a PAL facility that is too great a distance from the responsible district, a sample of material failed to meet specification and another sample was requested from a different location than the sample was initially taken. Samples of materials shall be taken in accordance with the applicable Engineering Policy Guide article.
| Did the distributor properly obtain the samples? If No, refer to the options below. | Yes | No |
| Option 1: Make the distributor aware that they may wish to contact the manufacturer regarding proper sampling. | ||
| Option 2: If the distributor has previously been made aware of their error in sampling procedure, notify Construction and Materials for assessment. | ||
Upon completion of your PAL Facility Quality Assurance Review, create an AASHTOWARE sample record as described in Create an AASHTOWARE Sample Record. Also create additional AWP sample records as required by the applicable Engineering Policy Guide article for each sample taken.