This IM is intended to provide additional instruction to the Build America, Buy America (BABA) requirements under the Infrastructure Investment and Jobs Act (IIJA) and Standard Specification 1107.06.
With the exception of the excluded items listed below the IIJA requires the following three BABA preferences. An article, material, or supply shall only be classified into one of these categories, and not multiple categories.
All iron and steel permanently incorporated into the project must be produced in the United States, including all manufacturing processes, from the initial melting stage through the application of coatings.
A manufactured product that is predominantly steel or iron shall be treated as an item of iron and steel.
2. Manufactured Products
Items that consist of two or more construction or non-construction materials that have been combined together through a manufacturing process will be treated as a manufactured product rather than a construction material. Manufactured products are exempt from the requirements of BABA.
All construction materials must be manufactured in the United States.
4. Excluded items-The following items are excluded from the requirements of BABA:
· cement and cementitious materials
· asphalt binders
· chemical admixtures
· aggregates such as stone, sand, or gravel
· asphalt release agents
· aggregate binding agents
PRODUCTS of Iron and Steel
The following lists of Iron and Steel products, at a minimum, are subject to the Buy America requirements.
Group 1 Products requiring mill test reports with shipments to projects
IM 440 - Trenchless Steel Casing and/or Carrier Pipe
IM 451 Steel Reinforcement
IM 451.02 Galvanized Steel Bars
IM 451.03B Epoxy-Coated Steel Reinforcement
IM 452 Deformed and Plain Stainless Steel Bars for Concrete Reinforcement
IM 453.06B High Strength Fasteners
IM 453.07 Stainless Steel Fasteners
IM 453.08 Anchor Bolts
IM 467 Steel Piles
IM 467.01 Steel H-Piles
IM 467.02 Steel Sheet Piles
IM 467.03 Steel Pipe Piles
IM 468 Pile Points for Steel H-Piles
IM 557 Qualification of Steel Fabrication Shops & Plants
Group 2 Products not requiring mill test reports with shipments to projects, when the product is from an approved fabricator/supplier
IM 411 Truncated Domes/Detectable Warning Systems
IM 441 Corrugated Metal Culvert Pipe
IM 441.01 Coupling devices for corrugated metal culvert pipe
IM 443.01 Rodent Guards
IM 443.02 Safety Grates
IM 444 Corrugated Zinc-Coated Steel Plates for Pipes & Arches
IM 445 Precast Concrete
IM 445.01 Concrete Pipe & Special Sections
IM 445.02 Precast Box Culverts
IM 445.03 Mechanically-Stabilized Earth (MSE) Retaining Wall Panels
IM 445.06 Precast Concrete Noise Walls
IM 449.05 Inspection & Acceptance of Utility Access Adjustment Rings
IM 451.01 Reinforcing Steel Supports
IM 453.04 Steel Castings (Carbon), Gray Iron Castings, and Ductile Iron Castings
IM 453.09 Concrete Anchors
IM 453.10 Shear Stud Connectors
IM 454.10 Chain-Link Fence and Field Fence
IM 455.01 High Tension Cable Guardrail
IM 455.02 Formed Steel Beam Railing, Cable Rail, Anchor Cable & Steel Post for Guardrail
IM 485 Light Pole Bases
IM 485.10 Inspection & Acceptance of Rigid Steel Conduit
IM 486.10 Perforated Square Steel Tube Post and Anchor
IM 558 Structural Field Welding & Inspection
IM 565 Steel Fabrication Shop Documentation
IM 570 Precast & Prestressed Concrete Bridge Units
IM 571 Plants for Production of Precast Concrete Barrier
Standard Specification Section 4185 Junction boxes, control cabinets and control boxes
The required documentation for all iron and steel products incorporated in a project will be at a minimum the mill test report and materials identification in addition to all product specific information identified in the pertinent IM.
The mill test report must include the following information: Steel mill name and location, material heat number, material grade, product specifications met, material dimensions, mechanical properties, chemical analysis, heat treatment (if applicable), certified mill signature.
The materials identification must provide traceability by heat number, grade, and type. As an example, the bill of lading may help provide this traceability.
Additionally, mill test reports must contain a certification statement indicating all steel or iron has been melted and manufactured in the USA in accordance with the Buy America requirements. All coated steel or iron must have a certification statement indicating all coatings have been applied in the USA.
Products from Approved Fabricators/Suppliers
The approved fabricator/supplier is required to maintain a file containing all required documentation for a minimum of seven years from the time the products are shipped for incorporation into a project. The required documentation will be at a minimum the information indicated above plus anything product specific identified in the pertinent IM.
Project Documentation from Approved Fabricators/Suppliers
If an item is not identified as a group 2 item, then the product is classified as a group 1 item.
Product IMs identified above in Group 1 indicate the fabricator/supplier will be required to provide mill test reports with shipments to the project.
For products in Group 2, the fabricator/supplier must
provide a letter certifying all of the materials are in compliance with Buy
America and the necessary supporting documentation will be retained as
in A above. Documentation shall be made available to the
Engineer upon request.
Products from Unapproved Fabricators/Suppliers
All documentation from unapproved fabricators/suppliers must be provided at the time of shipment and prior to incorporation.
The producer/supplier must provide a letter certifying all construction materials are in compliance with BABA in addition to all product specific information identified in the pertinent IM. Necessary supporting documentation will be retained for a minimum of seven years from the time the products are shipped for incorporation into a project. Documentation shall be made available to the Engineer upon request