Slide 1

Quality Assurance Program (QAP) Manual

Define a Quality Assurance Program (QAP)

Review common terminology

Discuss the fundamentals of an acceptance program

Discuss the fundamentals of an independent assurance program

Develop a QAP for your local agency needs

Discuss lessons learned

Objectives

Caltrans Division of Local Assistance Publications

http://www.dot.ca.gov/hq/LocalPrograms/index.htm

Reference Manuals

Local Assistance Procedures Manual (LAPM) ( February 10, 2009)

Section 16.14:

Quality Assurance Program

Section 19:

Oversight and Process Review

3

Quality Assurance Program (QAP) Manual for Use

by Local Agencies (January 20, 2011)

Reference Manuals

4

What is a QAP?

The Code of Federal Regulations (Title 23, Section 637.05) states a state transportation department shall:

develop a quality assurance program which will assure that the materials and workmanship incorporated into each Federal-aid highway construction projectare in conformity with the requirements of the approved plans and specifications

23 CFR 637.205

Local Assistance Procedures Manual

Chapter 16.14, Quality Assurance Program

A sampling and testing program that will provide assurance that the materials and workmanship incorporated in each highway construction project are in conformance with the contract specifications.

LAPM

8

Quality Assurance Program (QAP) Manual for Use by Local Agencies (January 20, 2011)

Caltrans requires that local agencies receiving funds for a Federal-aid transportation project must have a QAP

Updated as needed, at least every 5 years

QAP shall be approved by the Public Works Director (Section 3.2)

QAP Manual Requirements

9

Quality Assurance Program (QAP) Manual for Use by Local Agencies

(January 20, 2011)

A QAP consists of:

Acceptance Program

Independent Assurance (IA) Program

QAP Manual

10

The Caltrans Department of Transportation (Caltrans) Construction Manual

The Caltrans Independent Assurance Manual

Caltrans approved plans and specifications

Caltrans Test Methods

(http://dot.ca.gov/hq/esc/ctms/index.html)

Caltrans Local Assistance IA staff provides IA services

QAP Requirements on the SHS

CT Construction Manual, Chapter 6: Sampling and Testing

Caltrans Acceptance Program

http://www.dot.ca.gov/hq/construc/manual2001/chapter6/

Tester Qualification

Laboratory Accreditation

District IA Staff

Local Assistance IA Staff under METS

Reference Sample Program

Caltrans IA Program

http://dot.ca.gov/hq/esc/Translab/ormt/IA_reports/2005_IA_Maunal.pdf

13

Need a QAP

Acceptance Program/ IA program

Plans and Specifications based on a nationally recognized standard

Caltrans

Greenbook

Test Methods based on a national standard

Caltrans

American Society of Testing and Materials (ASTM)

American Association of State Highway and Transportation Officials (AASHTO)

Independent Assurance Program

Caltrans if CT test methods are used!

QAP Requirements on the NHS(but off the SHS)

There is flexibility, BUT

Still need a QAP!

Acceptance Program

Independent Assurance Program

And what if your agency has projects that are on the SHS, NHS and off the NHS?

QAP Requirements off the NHS

Developing a QAP

Definitions

Acceptance Program Fundamentals

Types of Testing

Preliminary Sampling and Testing

Materials used on the job prior to award

Test for suitability for a project

Acceptance Testing

Testing of material entering the work

Ensure materials meet specification requirements

Source Inspection

Acceptance Testing of manufactured or prefabricated materials at locations other than the job site

Independent Assurance and Sampling and Testing

Dependent upon the Independent Assurance (IA) program used by the agency

Acceptance Testing

Lot size: 4500 tons

Sublot:

750 tons

Caltrans Construction Manual

CT Method of Test for Evaluation of Aggregate for Lean Concrete Base (LCB)

From QAP Appendix D: Sampling and Testing FrequenciesPortland Cement Concrete (or Hydraulic Cement Concrete)

Material TypicalSample Size StandardSampling MethodFresh ConcreteTake approx. 150 lb. (or 1 cu. ft.) after the concrete has been placed. Avoid taking samples directly from the end of the concrete discharge shoot.ASTM D75, C494CT 125AASHTO T127, M85, M295

Material

Type of Tests StandardTest MethodFreshConcreteSlump or Penetration *ASTM C109CT 515AASHTO T106FreshConcreteAir Content *ASTM C109CT 515AASHTO T106FreshConcreteUnit Weight *ASTM C109CT 515AASHTO T106FreshConcreteCompressive StrengthASTM C39CT 521AASHTO T22FreshConcreteFlexural StrengthASTM C78CT 324AASHTO T97 & T23

*Test every 500 cubic yards of concrete. For paving, test for flexural strength once every 500 cubic yards of concrete. For structural concrete, test two cylinders for compressive strength for every 500 cubic yards of concrete.

Sampling: Testing:

Websites for Additional Testing Standards

American Society for Testing and Materials (ASTM)

http://www.astm.org/

American Association of State Highway and Transportation Officials (AASHTO)

https://www.transportation.org/

National Institute of Standards and Technology (NIST)

http://www.nist.gov/

California Test (CT) Methods

http://www.dot.ca.gov/hq/esc/ctms

Timely reporting of results to the Resident Engineer

Typical tests and times:

Sieve analysis 24 hours

Sand Equivalent 24 hours

Cleanness value 24 hours

R-value 3 days

Some tests take time!

Testing frequencies and lot sizes can require a great deal of testing

Reporting of Testing Results

Testing Alternatives

Alternative method of acceptance testing

Method to accept prefabricated or manufactured items brought to job site

Certificate by the manufacturer

Specific to project

Includes lot number

Statement of specification compliance (applicable section)

Signed by manufacturer

Certificate of Compliance (COC)

This is to certify that the Portland Cement

Supplied by ABC Cement Company complies with all requirements for Type II Portland Cement when tested in accordance with ASTM C - 494.

Local Agency Project No. Albert Howakowa HP21L 5055 111 Quality Assurance Engineer ABC Cement Company

Date:08/20/14

Example of a Vendors

Certificate of Compliance

Structural Metal Plate Pipe Arches and Pipe ArchesPerforated Steel PipePolyvinyl Chloride Pipe and Polyethylene TubingSteel Entrance Tapers, Pipe Downdrains, Reducers, Coupling Bands and Slip JointsAluminum Pipe (Entrance Tapers, Arches, Pipe Downdrains, Reducers, Coupling Bands and Slip Joints)Metal Target PlatesPaint (Traffic Stripe)ConductorsPainting of Electrical EquipmentElectrical ComponentsEngineering FabricsPortland Cement, Mineral Admixtures and Chemical AdmixturesConcrete Coarse Aggregate (Cleanness Value)Concrete Fine Aggregate (Sand Equivalent)PCC AdmixturesMinor Concrete Liquid AsphaltAsphaltic EmulsionsEpoxyHot Mix Asphalt (Quantities Less Than 10 Tons)

Construction Materials Accepted by a Certificate of Compliance

Independent Assurance (IA) Fundamentals

66

An Independent Assurance Program ensures the sampling and testing is performed correctly and the testing equipment used in the program is operating correctly and remains calibrated. It involves a separate and distinct schedule of sampling, testing and observation.

http://www.fhwa.dot.gov/pavement/materials/hif12001.pdf

IA Main components

Qualification of Personnel

Laboratory Accreditation

Equipment Calibration

Proficiency Testing

Corroboration Testing

Dispute Resolution

Types of IA Programs

Project Based

10% of acceptance frequency

Independent Assurance Sampler and Tester performs IAST test independent of acceptance tester on a project by project basis

System Based

90% of testers once or twice a year

Personnel qualifications are evaluated through written examinations, witness tests and corroboration testing

Annual report requirements

Project Based

Examples and Frequencies of Witness Testing

California TestDescription of Test ProcedureFrequency of Witness Testing205Percent crushed particlesOnce every twelve months206*, 207*, 208*Specific gravity and absorptionOnce every twelve months211*LA RATTLEROnce every twelve months213ORGANIC IMPURITIESOnce every twelve months223, 226MOISTUREOnce every twelve months229*DURABILITY INDEXOnce every twelve months301*R-VALUEOnce every twelve months302FILM STRIPPINGOnce every twelve months303*CENTRIFUGE KEROSENE EQUIVALENTOnce every twelve months205Swell and permeabilityOnce every twelve months307Vapor susceptibilityOnce every twelve months338Titration (cement/lime)Once every twelve months366*Stabilometer valueOnce every twelve months529Proportioning of rockOnce every twelve months

Require independent lab accreditation

Hire an outside qualified consultant to perform IA services

Cannot perform acceptance testing

Use a qualified employee from within the local agency to perform IA services

If using CT test methods, Local Assistance IA personnel is available

IA Program Alternatives

AASHTO Certificate of Accreditation

75

AASHTO

Accreditation

Details

Look for:

Location

Test Methods

Expiration date 2 years after accredited.

76

Army Corps of Engineers

Look for:

Location

Test Methods

Expiration date

77

QAP Section 5.0

If the local agency has an in-house IA Program

IA person should have familiarity with materials testing

IA staff must remain INDEPENDENT from acceptance testing

Main function is to test the acceptance tester

Certify personnel within organization

Not valid for project outside IAs agency jurisdiction

IA person should be first certified in the test method used in certification; e.g. if ASTMs are used, IA person must be certified in ASTMs by recognized entity.

Participate in a proficiency testing program

78

AASHTO MaterialsReference Laboratory

http://amrl.net

Cement and ConcreteReference Laboratory

http://www.ccrl.us/

QAP and Lessons Learned

QAP Appendix Y

Sample of QAP that

has been used

by most if not all.

First lesson learned:

One size does NOT fit all!

84

Define a Quality Assurance Program (QAP)

Review common terminology

Discuss the fundamentals of an acceptance program

Discuss the fundamentals of an independent assurance program

Develop a QAP for your local agency needs

Discuss lessons learned

Objectives

Bomasur Banzon, Lead IA Eng (HQ)

(916) 227-7234

Ignocencio Herrera, Dist. 1, 2, &3

(916) 227-7192

David Small, Dist. 4, 5, & 6 (northern)

(916) 247-7923

Seree Yenjai, Dist. 6 (southern), 7, 8, &9

(916) 247-1911

Afsaneh Ostovar, Dist. 11 & 12

(916) 247-6311

Caltrans L.A. I.A. Engineer

86

STATE OF CALIFORNIA Department of Transportation Division of Local Assistance Office of Procedures Development & Training

LOCAL

ASSISTANCE PROCEDURES

MANUAL

Processing Procedures for Implementing Federal and/or State Funded Local Public Transportation Projects

February 10, 2009 ==========================================================================================================

STATE OF CALIFORNIA

Department of Transportation

Division of Local Assistance

Office of Procedures Development & Training

LOCAL

ASSISTANCE

PROCEDURES

MANUAL

Processing Procedures for

Implementing Federal and/or

State Funded Local Public

Transportation Projects

February 10, 2009

==========================================================================================================

TRB GLOSSARY

Glossary of Transportation

Construction Quality

Assurance Terms

Transportation Research

Circular, E-C173

Sixth Edition, June 2013

http://onlinepubs.trb.org/onlinepubs/circulars/ec173.pdf

Table 6-1.7 Materials Acceptance Sampling and Testing Requirements:

Aggregate Bases (2010 Standard Specifications Section 26)

Test

Test Method

Sample Size &

Container Size

Sampling

Location

(See Note 1)

Acceptance

Test Frequency

Remarks

AGGREGATE BASES Class 1, Class 2, and Class 3

Sieve

Analysis

California

Test 202

50 lb

Materials site or

stockpile

Every 3000 tons

or 2000 cu yd;

see Remarks and

Note 2

If material is uniform

and well within

specification limits,

frequency may be

decreased to 1 per day

Sand

Equivalent

California

Test 217

Every 3000 tons

or 2000 cu yd;

see Remarks and

Note 2

If material is uniform

and well within

specification limits,

frequency may be

decreased to 1 per day

R-Value

California

Test 301

50 lb

Materials site or

stockpile

Every 3000 tons

or 2000 cu yd;

see Remarks

R-value testing may

reduced to minimum 1

acceptance test per

project when test

records demonstrate

that material from the

same source, and

having comparable

grading and sand

equivalent values,

meets minimum R-

value requirements

Durability

Index

California

Test 229

50 lb

Materials site or

stockpile

1 per project;

see Remarks

Durability test not

required for Class 3

aggregate base

Moisture

California

Test 226

25 lb

Materials site or

stockpile

2 daily when

aggregate base is

paid for by weight

Relative

Compaction

California

Test 231

Sample for

California Test

216

Project site in

accordance with

California Test

231

Every 2000 sq yd

Maximum

Wet Density

California

Test 216

35 lb

Relative

compaction test

site locations

Every 2000 sq yd,

see Remarks

Wet common-

composite test

maximum value may be

used in accordance

with California Test 231

Dimensions

N/A

N/A

Random locations

As necessary for

acceptance

Verify thickness of

aggregate base

Notes:

1. See California Test 125 for sampling procedures.

2. If material is outside the specification limits sample and test representative material every 500 cu yd so that deductions may

be taken for noncompliant material.

California Department of Transportation

Independent Assurance Manual Procedures for Accreditation of Laboratories

and Qualification of Testers JULY 2005 ISSUED BY: DIVISION OF ENGINEERING SERVICES, MATERIALS ENGINEERING AND TESTING SERVICES

CORE ELEMENTS OF A QA PROGRAM

Agency

Acceptance

Personnel

Qualification

Dispute

Resolution

QA

Program

Lab

Qualification

Independent

Assurance

Contractor

QC

3

QUALITY ASSURANCE

Definition

(1) All those planned and systematic actions

necessary to provide confidence that a product of

facility will perform satisfactorily in service; or

(2) making sure the quality of a product is what it

should be.

QUALITY CONTROL

Definition

The system used by a contractor to monitor,

assess, and adjust processes to ensure that the

final product meets the specified level of quality.

ACCEPTANCE

Definition

The process whereby all factors used by the agency

(i.e., sampling, testing and inspection) are

evaluated to determine the degree of compliance

with the contract elements.

UNDERSTANDING THE TERM

QUALITY ASSURANCE

All provisions of 637.207(a)

are applicable to Design-Build

projects.

*Note: The Design Builder cannot be

Assigned responsibility to perform any

Acceptance (Verification) functions.

15

PROPER USE OF THE

TERMINOLOGY

QC/QA is not the same as Quality Assurance

Quality Control is one of the core elements of a

Quality Assurance Program

VERIFICATION

Definition

Acceptance testing done by the Agency

Used to determine if the contractors QC test

results can be used in the acceptance decision.

VALIDATION

Definition

The mathematical comparison of two

independently obtained sets of data.

INDEPENDENT ASSURANCE

Definition

Activities that are an unbiased and independent evaluation

of all the sampling and testing (or inspection) procedures

used in the acceptance program

DISPUTE RESOLUTION

Definition

An agreed-upon procedure to resolve conflicts

resulting from discrepancies between the agency

and contractor results, of sufficient magnitude to

have an impact on payment.

Design-Bid-Build

Project delivery

system where

design is completed

Owner

before construction

contract is

advertised

Sometimes referred

to as traditional

method

Designer of

Record

Design Subs

Construction

Contractor

Construction

Subs

Design-Build

Project delivery

system in which both

the design and

construction are

awarded to a single

Owner

Design-

Builder

entity

Can reduce project

delivery time

Designer of

Record

Design Subs

Construction

Contractor

Construction

Subs

Construction Manager/General

Contractor

Owner

Designer of

Record

Coordination

Construction

Manager

General

Contractor

Preconstruction

GMP

Construction

Design Subs

Construction

Subs

Other Delivery Methods

Public-Private-Partnership (P3)

Funded and operated through partnership of

government and one or more private companies

Include a concession goal, compensation

structure, and length of time

Design-Build-Finance-Operate-Maintain

Type of P3 where responsibility for design,

construction, finance, operation and maintenance

are awarded to a single entity

Regardless of the Method used.

Core elements of

QA are necessary

Owner performs

Verification

testing and

inspection

independent of

the contractor

Courtesy of NETTCP

Acceptance Plans

Process for evaluating

the acceptability of a

Lot. Includes the

following:

Lot size

Sublot size

Quality measure

Acceptable/Rejectable

quality levels

Risk evaluation

Pay Adjustment

provisions

Lot

Specific quantity of material from a single

source assumed to be produced or placed by

the same controlled process

Days production

2500 tons

500 yd

3

5000 lane-ft

Table 6-1.7 Materials Acceptance Sampling and Testing Requirements:

Aggregate Bases (2010 Standard Specifications Section 26)

Test

Test Method

Sample Size &

Container Size

Sampling

Location

(See Note 1)

Acceptance

Test Frequency

Remarks

AGGREGATE BASES Class 1, Class 2, and Class 3

Sieve

Analysis

California

Test 202

50 lb

Materials site or

stockpile

Every 3000 tons

or 2000 cu yd;

see Remarks and

Note 2

If material is uniform

and well within

specification limits,

frequency may be

decreased to 1 per day

Sand

Equivalent

California

Test 217

Every 3000 tons

or 2000 cu yd;

see Remarks and

Note 2

If material is uniform

and well within

specification limits,

frequency may be

decreased to 1 per day

R-Value

California

Test 301

50 lb

Materials site or

stockpile

Every 3000 tons

or 2000 cu yd;

see Remarks

R-value testing may

reduced to minimum 1

acceptance test per

project when test

records demonstrate

that material from the

same source, and

having comparable

grading and sand

equivalent values,

meets minimum R-

value requirements

Durability

Index

California

Test 229

50 lb

Materials site or

stockpile

1 per project;

see Remarks

Durability test not

required for Class 3

aggregate base

Moisture

California

Test 226

25 lb

Materials site or

stockpile

2 daily when

aggregate base is

paid for by weight

Relative

Compaction

California

Test 231

Sample for

California Test

216

Project site in

accordance with

California Test

231

Every 2000 sq yd

Maximum

Wet Density

California

Test 216

35 lb

Relative

compaction test

site locations

Every 2000 sq yd,

see Remarks

Wet common-

composite test

maximum value may be

used in accordance

with California Test 231

Dimensions

N/A

N/A

Random locations

As necessary for

acceptance

Verify thickness of

aggregate base

Notes:

1. See California Test 125 for sampling procedures.

2. If material is outside the specification limits sample and test representative material every 500 cu yd so that deductions may

be taken for noncompliant material.

ACCEPTANCE:

EXAMPLE

VERIFICATION

Definition

Acceptance testing done by the Agency

Used to determine if the contractors QC test

results can be used in the acceptance decision.

VERIFICATION:

EXAMPLE

19

VERIFICATION:

VULNERABILITIES

Chain of custody

20

VERIFICATION:

VULNERABILITIES

Chain of custody

Individual test results

for calculations

Limiting testing

options

VALIDATION:

EXAMPLE

24

Independe nt Sample

Sample taken without regard to any other sample

taken to represent the area in question

Required when validating contractor test results

DOT

QC

QC

QC

DOT

VALIDATION:

VULNERABILITIES

Independent samples

VALIDATION:

VULNERABILITIES

Independent samples

Strength of mathematical comparison

F & t testing (8 of 31 states)

More power to detect actual differences

Minimum 5 verification for 7-20 QC

Single-test comparisons (1 vs. 1 OR 1 vs. many)

Appeal is simplicity: not power

RISK

Definition

Risk

(1) Also called statistical risk. The probability of suffering harm or loss.

(2) Also called engineering risk. A function that represents the expected cost associated

with a risk event.

RISK MANAGEMENT AND

ALLOCATION

Definition

Risk Management

A scientific approach to dealing with engineering risks by anticipating possible losses and

designing and implementing procedures that minimize the occurrence of loss or the

financial impact of losses that do occur

Risk Allocation

The distribution of engineering risk among the various participants in a project

RISK MANAGEMENT AND ALLOCATION

CONSIDERATIONS

Agency must perform risk analyses/assessments when developing

acceptance programs (examples):

Acceptance of manufactured items considering safety, cost and historical

quality

Acceptance based on COC, vendor qualifications, vendor certifications,

especially for non-critical items

Testing frequency relative to amount of risk (structural concrete vs.

striping)

A

gency

or

C

on

t

rac

t

or

R

i

sk

D

irec

t

Co

s

t

($)

BALANCING RISK AND COST

1 2 3 4 5 6 7

Number of Test Samples (n)

INDEPENDENT ASSURANCE

Definition

Activities that are an unbiased and independent evaluation

of all the sampling and testing (or inspection) procedures

used in the acceptance program

The Construction and Materials

Quality Assurance Program is an

integrated, national effort to

improve the effectiveness of

the State acceptance of

materials both in the

inspection, sampling and

testing. The program is

designed to provide tools and

guidance in implementing

Quality Assurance programs.

The program is designed to

provide tools and guidance in

implementing Quality

Assurance programs.

Office of Pavement Technology

Publication No.

FHWAHIF12001

October 2011

INDEPENDENT ASSURANCE

PROGRAMS

This Technical Brief provides information regarding

independent assurance as it relates to activities for the

evaluation of the sampling and testing procedures

used in a materials and quality acceptance program.

Introduction

23 CFR 637 defines an Independent Assurance Program as:

Activities that are an unbiased and independent evaluation of all

the sampling and testing procedures used in the acceptance

program.

An Independent Assurance Program ensures the sampling and

testing is performed correctly and the testing equipment used in

the program is operating correctly and remains calibrated. It

involves a separate and distinct schedule of sampling, testing

and observation.

Qualified sampling and testing personnel, other than those

performing the verification and quality control (QC) sampling

and testing, should perform the Independent Assurance (IA)

tests. Likewise, equipment other than that used for verification

and QC should be used for IA sampling and testing. By

regulation IA sampling and testing is conducted by agency

personnel or an accredited laboratory designated by the agency.

The regulation requires IA specifically be designed to include

testing performed on project produced materials. Since the

testing of project produced materials are tested in multiple

locations and by multiple personnel it is necessary to have some

assurance the testing is being performed accurately.

Manufactured products are typically tested in the States central

laboratory or by a designated consultant laboratory. Testing in

the central laboratory is considered to be covered by the

laboratories accreditation and participation in proficiency testing.

INDEPENDENT ASSURANCE:

EXAMP LES

Split Samples

IA

Sample

Agency

Split

IA Split

Contractor

Split

Split Sample

Sample divided into two or more portions

Used to verify an operators equipment and procedures

eliminates sampling variability

Used in IA testing and Dispute Resolution

Acc.

IA

DISPUTE RESOLUTION

Definition

An agreed-upon procedure to resolve conflicts

resulting from discrepancies between the agency

and contractor results, of sufficient magnitude to

have an impact on payment.

DISPUTE RESOLUTION:

EXAMP LES

Formal written procedure

Time limits for comparison of data

Third party used for dispute

Division of Local Assistance, Office of Procedures Development and Training Quality Assurance Program (QAP) Manual for Use by Local Agencies Revised January 20, 2011

54

Appendix Y - Example of a QAP

QUALITY ASSURANCE PROGRAM (QAP) AGENCY: City / County of __________

The purpose of this program is to provide assurance that the materials incorporated into the construction projects are in conformance with the contract specifications. This program should be updated every five years or more frequent if there are changes of the testing frequencies or to the tests themselves. To accomplish this purpose, the following terms and definitions will be used: DEFINITION OF TERMS

Acceptance Testing (AT) Sampling and testing, or inspection, to determine the degree of compliance with contract requirements. Independent Assurance Program (IAP) Verification that AT is being performed correctly by qualified testers and laboratories. Quality Assurance Program (QAP) A sampling and testing program that will provide assurance that the

materials and workmanship incorporated into the construction project are in conformance with the contract specifications. The main elements of a QAP are the AT, and IAP.

Source Inspection AT of manufactured and prefabricated materials at locations other than the job site, generally at the manufactured location. MATERIALS LABORATORY The AGENCY will use their own materials laboratory or a private consultant materials laboratory to perform AT on Federal-aid and other designated projects. The materials laboratory shall be under the responsible management of a California registered Engineer with experience in sampling, inspection and testing of construction materials. The Engineer shall certify the results of all tests performed by laboratory personnel under the Engineers supervision. The materials laboratory shall contain certified test equipment capable of performing the tests conforming to the provisions of this QAP. The materials laboratory used shall provide documentation that the laboratory complies with the following procedures: 1. Correlation Testing Program The materials laboratory shall be a participant in one or more of the following testing programs:

a. AASHTO Materials Reference Laboratory (AMRL) b. Cement and Concrete Reference Laboratory (CCRL) c. Caltrans Reference Samples Program (RSP)

2. Certification of Personnel The materials laboratory shall employ personnel who are certified by one or more of the following: a. Caltrans District Materials Engineer b. Nationally recognized non-Caltrans organizations such as the American Concrete Institute, Asphalt,

National Institute of Certification of Engineering Technologies, etc. c. Other recognized organizations approved by the State of California and/or

Recognized by local governments or private associations.