How to Ensure Your Construction Documents Hold Up in Court

On every project I’ve ever built or consulted on, the paperwork told the real story. Not the marketing photos, not the ribbon cutting—your emails, daily reports, RFIs, change orders, pay apps, and schedules end up on the witness stand if things go sideways. And they often do. If you want to win the argument later, you need to write it now. This guide walks you through how to build a documentation system that stands up in court, not just one that checks boxes for the file cabinet.

What courts actually look for

Judges and arbitrators aren’t interested in your best speech. They’re interested in evidence that’s:

• Contemporaneous: Created at or very near the time the event happened.
• Business-as-usual: Kept in the ordinary course of your operations, not cobbled together after the dispute starts.
• Authenticated: It’s clear who created it, when, and that it wasn’t altered.
• Complete and consistent: The story doesn’t change from one document to the next.
• Clear about notice and timing: You followed the contract’s steps and deadlines for notices, claims, and changes.
• Tied to cost and schedule impact: Not just “we were delayed,” but exactly how many days, on what critical path, and what it cost.

That’s because of a few legal concepts you should bake into your habits:

• Business records exception: Records you routinely keep (like daily reports, RFIs, time sheets) are more likely to be admissible if made near the time by someone with knowledge.
• Best evidence rule: The “original” or a reliable duplicate is preferred. Store your originals securely.
• Authentication: You need to show the doc is what you say it is. Metadata, signatures, consistent headers/footers, and audit logs help.
• Contractual notice: If your contract says “written notice within 7 days,” judges will enforce that. Miss the window and you may waive the claim even if you’re right on the facts.

The core document set that wins cases

Think of your project record as a system of cross-checks. Individual documents matter; consistency across them wins cases.

• Contract and amendments
• Scope documents (drawings/specs, BIM models, addenda)
• Schedules (baseline, updates, narratives, TIA analyses)
• RFIs and submittals (logs, approvals, responses)
• Change management (PCOs, CCDs, COs, T&M tickets)
• Daily reports (labor, equipment, weather, work areas)
• Meeting minutes and action logs
• Cost records (pay apps, SOV, vendor invoices, timecards, delivery tickets)
• Photos/video (with metadata)
• Quality and testing (special inspections, test reports, punch lists)
• Safety (JHAs, toolbox talks, incident reports, OSHA logs)
• Communications (emails, letters, text summaries, collaboration platform records)
• Insurance and claims correspondence
• Closeout documentation (as-builts, O&M manuals, warranties)

If a claim shows up, you’ll be grateful for each category.

Contracts: build admissibility and claims hygiene into the foundation

Your contract shapes what evidence matters and how you have to present it. A few clauses have oversized impact:

• Notice periods. AIA A201 typically requires notice of a claim within 21 days; some bespoke contracts cut that to 7–14. Calendar these deadlines on Day 1. Make a template letter for cost and schedule impacts.
• Change process. Spell out pricing methods (unit rates, T&M with markups, labor burden), required back-up, and approval authority. Reference attachments with standard rates and crew compositions.
• Schedule requirements. Require a CPM baseline, monthly updates, narratives, and the method of time impact analysis. Define weather days (e.g., based on 10-year NOAA averages).
• Dispute resolution. Know whether you’re heading to mediation, arbitration, or court. This affects discovery scope and how you’ll present records.
• Digital signatures and communications. Incorporate acceptance of e-signatures under UETA/E‑SIGN and designate the official communication platforms.
• Integration clause. The contract is the entire agreement; pre-bid emails generally don’t count unless incorporated. If a pre-bid clarification matters, memorialize it in an addendum.
• Flow-down. Your subcontract terms should mirror your prime contract obligations, especially on notice, changes, schedule updates, insurance, and dispute resolution.

Pro tip: During negotiation, get paid for the documentation burden you’re accepting. If the owner wants weekly 360° photo scans, four-week look-aheads, detailed T&M back-up, and executive meeting minutes, that’s more hours. Put a modest line item or overhead mark to cover it.

Scope, drawings, and as-builts: what “clear” looks like

Ambiguity breeds disputes. A few habits reduce ambiguity and create a defensible record:

• Keep a bulletproof drawing log. Track bid set, addenda, ASIs, bulletins, and re-issues. Note “date received,” “date transmitted to subs,” and “superseded on.”
• Use a revision stamp on field drawings. Red clouds and deltas are fine, but a date-stamped “FIELD SUPERSEDED ON [DATE] BY [ISSUE]” stamp on old sets wins hearts in a deposition.
• As-builts should be a living record, not a last-week scramble. Update weekly, with initials and date. “As-Installed” is stronger than “As-Built” language where you have survey or inspection verification.
• BIM models need version control. Store federated model snapshots at major milestones and for each RFI response that changes geometry. Keep a README with changelog.

Common mistake: Distributing partial sketch screenshots via text. If a sketch directs work, issue it through your document system with an RFI or CCD number so it’s traceable.

Change orders and T&M: assemble the claim as you go

Most disputes center on changes. The projects I’ve seen win change debates did three things well:

1) They gave immediate written notice. 2) They priced changes consistent with the contract. 3) They attached clean, daily back-up.

Action steps:

• Notice template. Preload a template you can fill out within hours. Include date/time, reference to contract clauses (notice and changes), a brief description, potential schedule impact, and a request for direction.

Example notice language: “We have encountered [condition]. Under Section [X] (Differing Site Conditions) and Section [Y] (Notice of Claims), this constitutes a change. We are proceeding to mitigate impacts, reserving rights to an equitable adjustment. Initial estimate: [cost/time]. Please advise within 48 hours if you prefer an alternative approach.”

• Use T&M tickets properly. One ticket per day per change, signed daily by an owner’s rep or inspector. Include:
  • Names and hours by classification
  • Equipment with hours and sizes
  • Material quantities and delivery tickets
  • Photos of the specific work area, tied to ticket ID
  • Overhead/markup consistent with the contract
• Change order pricing fidelity. If contract specifies labor burden at 45% and OH&P at 10/5 (prime/sub), stick to it. Include crew makeups. If you deviate, explain why.
• Link change docs. The PCO should reference the RFI/ASI/bulletin, T&M tickets, schedule TIA, and cost back-up. Courts love chains that tie together.
• Track pending exposure. Keep a live log showing pending PCOs, expected approval dates, and cumulative exposure. If the owner sits on approvals, your log shows constructive acceleration.

Common mistake: Bundling multiple unrelated changes into one CO without cross-references. Break them out or at least create clear sub-items.

Scheduling: CPM or it didn’t happen

Your schedule is your best friend in a delay claim.

• Baseline schedule. Build a logic-driven CPM schedule approved by the owner. Store the original, the native file, and a PDF snapshot. Include a narrative describing assumptions.
• Monthly updates with narratives. Don’t just status bars. Explain variance drivers, added activities, resequencing, weather days, and anticipated risks.
• Time Impact Analyses (TIA). When a delay hits, create a fragnet insert, update the data date, and show the effect on the critical path. Tie it to a specific notice letter and RFI/CO.
• Weather logs. Use NOAA stations and your own site log. Compare actual lost days to the contract baseline of expected inclement weather. Keep photos on those days (wet ground, snow cover).

Quick benchmark: On a $50M, 18-month project, expect to spend 8–16 hours/month on real schedule management. Budget it. A good scheduler (internal or consultant) is cheaper than a schedule expert later at $400+ per hour.

Common mistake: Letting the schedule drift off CPM rigor into “Gantt art.” If logic gets broken, it’s hard to make a credible delay argument later.

Daily reports: the single most valuable routine document

If you change one habit, change this. A clean daily report can make or break a claim.

What to include (and keep consistent across days):

• Date, project, weather (with source), and temperature
• Crews on site by company and trade, with headcount and hours
• Work areas and tasks completed, with quantities (e.g., “placed 180 CY 4000 psi slab-on-grade, grid B–F/2–6”)
• Equipment on site and utilization
• Deliveries (with ticket numbers)
• Visitors and inspections (who, why, outcome)
• RFIs answered or submitted
• Safety observations (good catches and incidents)
• Photos labeled by area and activity
• Constraints or disruptions (who/what/where/impact)
• Signature by the person with knowledge

Keep tone factual. Avoid editorial comments like “architect is clueless” or “owner’s rep doesn’t care.” Those quotes live forever.

Training tip: Teach supers to tie quantities to a control (grids, chainage, area names). “Framed 12 LF west wall” is weak. “Framed 12 LF GWB at Grid E—E.3, Level 2 corridor, Rooms 211–214” is strong.

Photos and video: show, don’t just tell

Photos make abstract claims concrete. But random photo dumps won’t help much.

• Standardize naming. Example: 2025-06-14_L2_Corridor_GridE-E3_SlabPlacement_001.jpg
• Keep originals. Store RAW or original JPGs in a read-only archive to preserve metadata (EXIF). Generate working copies for markups.
• Use 360° weekly capture. Walk consistent paths and viewpoints. Courts love a repeatable, time-stamped panorama series.
• Drone footage. Follow FAA Part 107 if commercial. Log flights with date/time/location and pilot ID. Tag frames showing conditions relevant to claims.
• Create photo sets per event. For an unforeseen condition, shoot: wide context, mid-range, close-up with scale (tape/ruler), and overall plan location.

Chain-of-custody light: For incident or critical condition photos, export a hash (e.g., SHA-256) of the original file or store in a system with an immutable audit log. You don’t need to be a forensics lab, but a simple “original created at X, unchanged since” record helps authentication.

RFIs and submittals: control the narrative

RFIs can help or hurt. A sloppy RFI log will be used to say, “Contractor asked 300 questions; clearly they didn’t understand the work.” Shape that perception.

• Write clear RFI questions. One question per RFI. Quote the spec/drawing conflict, list options, recommend a solution, and state potential cost/time impact.
• Track turnaround times. Note days outstanding and follow up regularly. Delay logs tied to RFI turnaround times add weight to your schedule impacts.
• Differentiate clarification vs change. If the response adds scope, state so in a timely notice and convert to PCO. Don’t let scope creep hide in RFIs.
• Submittal register early. Build a submittal schedule aligned with procurement lead times. Missed submittal sequences are a common self-inflicted wound.

Pro move: Include a “Needed By” date on RFIs and submittals that ties back to the schedule. Not a threat—just a link that demonstrates planning.

Meeting minutes: facts + action items

Meeting minutes are often Exhibit A. Draft them like your future self will need to rely on them.

• Structure: attendees, agenda, decisions made, action items (owner, architect, GC, subs), due dates, and next steps.
• Publish within 48 hours. Silence can be treated as acceptance. Include a line: “Please advise within five business days of any corrections; otherwise, these minutes will be deemed accurate.”
• Capture commitments. “Owner to issue CCD for elevator pit waterproofing by 6/21.” Vague statements like “discussed waterproofing” are weak.
• Avoid snark and adjectives. Keep it professional and factual.

Common mistake: Not sending minutes to all parties who need to act. If a sub’s commitment isn’t captured and shared, it’s hard to enforce later.

Cost and payment: tie dollars to work and documents

A court wants to see a clean trail from your contract value to your claim.

• Schedule of values (SOV). Build a logical SOV that matches how work is performed. Don’t bury major components; it hurts progress valuation and claim clarity.
• Pay apps with back-up. Include percent-complete reasoning, photos, delivery tickets for stored materials, and Lien Waivers (conditional/unconditional as appropriate).
• Vendor invoices and time sheets. Match them to cost codes and change numbers.
• T&M materials. Number your T&M tickets and cross-reference to invoices and delivery tickets. Courts dislike “shoebox accounting.”
• Certified payroll (if applicable). Keep weekly certified payroll reports for prevailing wage jobs; they back up labor hours in change claims.

Retention tool: Keep a pay-when-paid clause for subs if permissible in your jurisdiction, but don’t rely on it to excuse poor documentation. Many states limit its enforceability.

Safety and incidents: document carefully, protect privilege where needed

• Pre-incident: Keep daily JHAs, toolbox talks, equipment inspection checklists, and safety observations. Show you had a system, not a binder gathering dust.
• Incident response: Take factual statements, photos, and witness info. Avoid speculation in incident reports. Keep separate attorney-client privileged communications with counsel and insurers; label and store them separately.
• OSHA logs and citations: Retain OSHA 300/301 logs and correspondence. Don’t editorialize in your OSHA response; stick to facts and abatement.

Pro tip: Train supervisors to write “what, where, when, who” without causes or blame. Root cause analysis can be done later, ideally with counsel to preserve privilege.

Quality and testing: independent verification carries weight

• Special inspections: Retain reports for concrete breaks, steel bolting/welding, masonry, fireproofing density, etc. Track nonconformances to closure with signed corrective actions.
• Testing labs: Keep chain-of-custody for samples, lab accreditation certificates, and field technician certifications.
• Punch lists: Track items with dates opened/closed and responsible parties. Don’t purge the log; resolve and retain it.

A clean quality trail shows you built to the standard of care. It also helps apportion responsibility if defects appear.

Emails, texts, and collaboration platforms: write like a judge is cc’d

Everyone says “be professional,” but here’s what that looks like in practice:

• Subject lines that mean something: “Notice of Delay – RFI 134 Response Outstanding – Needed by 7/15”
• One issue per email when it’s important. Easier to produce and to prove receipt later.
• Summarize verbal conversations in writing: “Per our site walk at 2:30 pm, we understand you directed us to… We will proceed under protest pending CO.”
• Texts happen. Capture them: Periodically email a summary to the project file—“Summary of texts with Owner’s rep on 6/14 attached.” Some platforms can ingest device backups; get an IT plan.
• No sarcasm, no venting. Emojis, profanity, and name-calling have sunk more cases than technical issues ever did.

Retention plan: Establish which tools are official (Procore, Autodesk Build, Aconex, etc.). Disable shadow systems where possible.

Digital practices, signatures, and authenticity

Courts widely accept electronic records and signatures, if they’re handled correctly.

• Use e-sign tools with audit trails (DocuSign, Adobe Sign). Store the certificate of completion with the document.
• Lock PDFs for final versions; keep native versions in a controlled folder.
• Version control: Use a consistent naming convention, e.g., CO_017_Pump_Room_Piping_PCO-023_Approved_2025-06-21.pdf
• Backups: 3-2-1 rule—3 copies, 2 different media, 1 off-site. Cloud plus local plus cold archive is best.
• Access logs: Limit and log who can alter official records. Immutable storage for executed contracts and COs is ideal.

Authentication checklist:

• Creator identifiable (name/role)
• Date and time stamps
• System audit trail (created, modified, by whom)
• Unique document IDs
• Hash or checksum for critical originals

Preservation and retention: don’t delete your case

If a dispute is likely or a claim letter arrives, issue a litigation hold.

• Litigation hold steps:

  1) Identify custodians (PMs, supers, estimators, schedulers, executives). 2) Suspend auto-deletion on email and chat for the project. 3) Instruct staff not to delete texts and to preserve devices. 4) Preserve project databases (RFIs, submittals, PM software exports). 5) Capture hard copies and field notebooks.

• Retention timeframes:
  • Private construction: Keep at least through the statute of repose plus a cushion. Many states range 6–10 years after substantial completion; some up to 15 years. I tell clients 11–12 years as a baseline, 15+ for structural or facade work.
  • Federal jobs: FAR requires 3 years after final payment for many records; claims under the Contract Disputes Act can extend practical retention.

Spoliation risk: Destroying relevant records after you should reasonably anticipate a claim can lead to sanctions or adverse inferences, even if you were right on the facts.

Government projects: extra paperwork, extra scrutiny

• Notice and claim procedures are stricter. Follow the contract to the letter. On federal projects, the Contract Disputes Act imposes formal claim certification for amounts over $100,000.
• Certified payroll and Davis-Bacon compliance. Missing or inconsistent reports can sink unrelated claims by attacking credibility.
• Buy American/Build America: Keep product origin documentation with submittals and invoices.
• FOIA/Public records: Assume your emails to public owners may become public. Keep it clean and factual.

Insurance and claims: align your documentation with your policies

• Notice to insurers: Most policies require “prompt” notice of circumstances that may give rise to a claim. Late notice can void coverage. Document your notice with date-stamped emails and claim numbers.
• CGL vs professional liability: Construction means mixed exposures. If design-assist or delegated design is involved, your professional liability carrier matters. Keep design decisions and approvals documented.
• Builders risk: For property losses, preserve evidence, take systematic photos, and keep invoices for mitigation.

Subcontractors: flow-down and field discipline

Your case can be only as good as your subs’ paperwork.

• Flow-down documentation standards. Require daily reports, T&M tickets, and photo documentation from subs that match your format. Provide templates on Day 1.
• Back-to-back schedule and notice terms. Align their obligations with yours to avoid gaps.
• Sub default records. If a sub is failing, document cure notices, manpower charts, schedules, and quality inspections. Keep a contemporaneous cost-to-complete analysis.

Pro tip: Pay for a one-hour documentation training for your subs in the kickoff meeting. The few hundred dollars show up later in cleaner claims and fewer surprises.

Creating a documentation culture that sticks

This isn’t about your best person doing hero work. It’s about normal people following good habits.

• Onboarding packet includes:
  • Documentation playbook (5–8 pages, practical)
  • Templates (daily report, T&M ticket, notice letter)
  • File naming and folder tree
  • Communication standards (subject lines, cc policy)
  • Schedule expectations (baseline/update/TIA)
• Weekly rhythm:
  • Monday: Update look-ahead schedule and submittal log.
  • Daily: Reports with photos uploaded by 6 pm.
  • Wednesday: RFI review and aging report.
  • Friday: Meeting minutes issued; unresolved action follow-ups sent.
• Supervisor coaching:
  • Ride-alongs to help supers quantify work
  • Spot checks on daily reports and photos
  • Positive reinforcement—share “gold standard” examples
• Audits:
  • Monthly internal audits (1–2 hours) checking five random items: a change, an RFI, a pay app, a meeting minute, a daily. Fix gaps immediately.

Budgeting reality: For a $20M job, plan 0.5–1.0 FTE worth of time across the team purely on documentation (PM, PE, superintendent contributions). That’s 800–1,600 hours. It feels like overhead until you avoid a seven-figure dispute or win a time extension.

Practical tools and setups that work

You don’t need the fanciest tech stack. You do need consistency.

• Project management platforms: Procore, Autodesk Build, Newforma, Aconex. Pick one and commit.
• Scheduling: Primavera P6 for large/complex jobs; Microsoft Project can work on smaller projects if you maintain logic.
• Photo management: OpenSpace, StructionSite for 360; site cameras for timelapse; shared drive with strict folder structure for standard photos.
• Signature: DocuSign or Adobe Sign with integrated storage.
• Cloud storage: SharePoint/OneDrive, Google Drive, Dropbox Business. Turn on version history and MFA.
• Backup: Cloud vendor retention plus quarterly offline archive.

Folder tree example:

• 00_Contract
• 01_Drawings_Specs
• 02_RFIs
• 03_Submittals
• 04_Schedule
• 05_Changes
  • 05.01_PCOs
  • 05.02_COs
  • 05.03_TandM_Tickets
• 06_Daily_Reports
• 07_Meeting_Minutes
• 08_Cost_PayApps
• 09_Photos
  • 09.01_Daily
  • 09.02_360
  • 09.03_Incidents
• 10_Safety
• 11_Quality_Testing
• 12_Closeout

Step-by-step playbook for a defensible record

Here’s how I set up projects from Notice to Proceed.

1) Kickoff week

• Load contract into the system; flag notice and claim deadlines in calendars.
• Publish documentation playbook and templates to the team and subs.
• Create the folder tree and permissions. Lock the 00_Contract folder.
• Create a baseline schedule plan and a submittal register draft.
• Schedule the first photo capture and daily report training.

2) First month

• Issue baseline CPM schedule and narrative; get owner approval.
• Confirm RFI and submittal workflows with the design team.
• Install site camera; start weekly 360 captures.
• Start daily reports with quantity tracking and photos.
• Begin meeting minutes cadence; send within 48 hours.

3) When a change pops up

• Send notice letter same day or within 48 hours, referencing contract sections.
• Open an RFI or CCD to document direction.
• Start daily T&M tickets; collect signatures daily.
• Take targeted photos tied to T&M ticket IDs.
• Draft preliminary cost and TIA; update as more info emerges.

4) Monthly routine

• Update CPM schedule and narrative with delay log.
• Reconcile PCO log; escalate items aging beyond agreed cycles.
• Pay app with photo and cost back-up; collect conditional waivers.
• Audit five random records and coach for improvement.

5) If a dispute emerges

• Issue litigation hold.
• Engage counsel and your scheduler/claims consultant early.
• Freeze records exports: RFIs, submittals, emails, schedules, cost reports.
• Maintain “business-as-usual” documentation cadence—don’t go dark.

Real-world scenarios

Scenario 1: Differing site conditions in a hospital renovation

• Situation: Demolition revealed asbestos-containing material in a chase not identified in the abatement plan.
• Actions:
  • Superintendent sent a same-day notice letter citing differing site conditions and hazardous materials provisions.
  • Daily T&M tickets began immediately, signed by the owner’s rep.
  • Photos included wide shots, close-ups with scale, and air monitoring logs.
  • RFI requested direction; architect issued CCD to encapsulate.
  • Scheduler inserted a fragnet showing a 14-day impact to the critical path.
• Outcome: The documented chain (notice → RFI → CCD → T&M → TIA) resulted in a negotiated CO for $132,000 and a 10-day time extension. No claim.

Scenario 2: Steel delivery delay on a private office build

• Situation: Fabricator missed the delivery window, citing mill delays.
• Actions:
  • GC’s monthly narrative already flagged supply risk and required submittal approval dates.
  • When the delay hit, emails summarized a meeting where the owner declined to pre-release steel.
  • The TIA showed resequencing options and cost of acceleration.
• Outcome: Owner accepted resequencing with adjustment to general conditions. Later, when a claim surfaced, meeting minutes and emails demonstrated the owner’s informed choice, undercutting their back-charge attempt.

Scenario 3: Water intrusion claim two years after completion

• Situation: Condo association alleged window leaks.
• Actions:
  • GC produced as-built drawings with window install details and QA checklists, including photos per unit with date stamps.
  • Testing reports showed sealant adhesion tests and water tests passed initially.
  • Sub’s daily reports named installers and weather on install days.
• Outcome: Expert analysis pinpointed a handful of units where homeowner modifications compromised pans. The rest were within spec. The claim settled for a fraction of the initial demand.

Common mistakes that sink good cases

• Missing notice deadlines by a few days. Courts rarely “forgive” this.
• Inconsistent stories between daily reports, emails, and meeting minutes.
• T&M tickets without signatures. Unforced error.
• Schedules without logic or with retroactive edits. Experts can spot it in minutes.
• Inflated or sloppy change pricing not tied to contract rates.
• Venting in emails and texts that undermines credibility.
• Poor photo practices—no context, no dates, no linkage to events.
• Letting subs run their own documentation “their way.” Herd the cats early.

What it costs to do this right (and what it saves)

• Time investment:
  • Daily reporting: 15–30 minutes per foreman/super per day
  • Photo capture: 20–45 minutes for daily set; 60 minutes for weekly 360
  • Monthly schedule update: 8–16 hours
  • Meeting minutes: 60–90 minutes/week
• Direct costs:
  • 360 capture software: roughly $400–$1,200/month depending on project size
  • Drone pilot time: $150–$300/flight, or internal training/certification
  • E-sign platform: $25–$60/user/month
  • Claims consultant if needed: $200–$450/hour
  • eDiscovery if litigation hits: $25–$75/GB to process/host, plus review time

A single avoidable dispute can eat six figures in fees before you blink. The documentation habits above routinely prevent or shorten disputes, and when you do fight, you spend less time “finding” evidence and more time leveraging it.

Advanced tips for heavy hitters

• Immutable storage for key docs. Some teams use write-once, read-many (WORM) storage or repositories with retention locks for executed documents and schedules.
• Metadata preservation policy. For critical evidence (incident photos, baseline schedule), export and retain metadata reports or hashes.
• BYOD policy. If employees use personal phones for work texts/photos, have a policy to preserve and export project communications, with privacy protections.
• Harmonize time zones and time stamps. Set all project systems to the same time zone to avoid confusion in timelines.
• Privilege segregation. Use separate matter folders for attorney communications and label them. Don’t mix business and legal strategy in the same email thread.

Quick reference checklists

Daily report essentials

• [ ] Date, weather (source), temp
• [ ] Crews and hours by trade/company
• [ ] Work areas tied to grids/levels
• [ ] Quantities installed
• [ ] Equipment and utilization
• [ ] Deliveries with ticket #s
• [ ] RFIs submitted/answered
• [ ] Inspections and results
• [ ] Safety notes
• [ ] Photos labeled and uploaded
• [ ] Signature/initials

Change event process

• [ ] Send notice citing contract sections within required days
• [ ] Open RFI/CCD and request direction
• [ ] Begin daily T&M tickets, signed
• [ ] Take targeted photos tied to ticket IDs
• [ ] Draft preliminary cost and TIA; update
• [ ] Issue PCO with back-up; track in log
• [ ] Convert to CO and file with e-sign certificate

RFI best practices

• [ ] One clear question
• [ ] Quote conflicting requirements
• [ ] Provide recommended solution
• [ ] State potential cost/schedule impact
• [ ] Include “needed by” date tied to schedule
• [ ] Update RFI log and delay log

Meeting minutes

• [ ] Attendees and roles
• [ ] Decisions made
• [ ] Action items with owners and due dates
• [ ] Changes/impacts flagged
• [ ] Publish within 48 hours
• [ ] Invite corrections within five business days

Litigation hold

• [ ] Identify custodians and systems
• [ ] Suspend auto-deletes
• [ ] Preserve emails, chats, texts, PM platform data
• [ ] Image critical devices if necessary
• [ ] Document hold notices and acknowledgments

Sample templates you can adapt

Notice of potential change (email body) Subject: Notice of Potential Change – RFI 134 – North Stair Landing Elevation

[Owner/Architect Name],

On [date/time], our team identified a conflict between S-402 Detail 7 (landing elevation 102’–0″) and A-312 Stair Section (landing elevation 101’–9″). Proceeding per the structural detail will impact stair headroom at Level 3.

Under Sections 7.3 (Changes) and 15.1 (Notice of Claims) of the Contract, this constitutes a change. We are mitigating impacts and request direction within 48 hours. Initial assessment indicates a two-day impact to the critical path and an estimated cost of $8,500 (labor, material, and overhead) if risers are adjusted.

We will proceed with temporary measures as needed for safety and will submit a PCO with supporting documentation. Please advise.

Regards, [Name, Title] [Company] [Contact info]

T&M ticket fields

• Project / Date / Ticket #
• Change reference (RFI/CCD/PCO)
• Location / Work description
• Labor: Name, classification, hours, rate
• Equipment: Type, size, hours, rate
• Materials: Quantity, unit, source, delivery ticket #
• Photos: IDs
• Signature: Owner/Rep; Contractor Rep

File naming examples

• RFI_0134_NorthStair_LandingElevation_Question_2025-06-14.pdf
• T&M_2025-06-15_RFI-0134_Ticket-004_Signed.pdf
• Photo_2025-06-15_L2_StairA_Landing_Conflict_003.jpg
• CO_017_RFI-0134_StairLanding_Adjustment_Approved_2025-06-28.pdf

Training your team: what to emphasize

From years of coaching supers and PMs, here are the habits that stick:

• Write like a neutral reporter. Facts first. Avoid adjectives.
• Time-stamp everything. If you can’t do it in the field, add the detail before day’s end.
• Close the loop. If you talk on site, summarize in an email.
• Don’t wait for “perfect.” Get the notice out; you can refine the pricing later.
• Be consistent. The same structure, every day, across the team.

Make it easy: Put templates on every iPad/phone, use drop-downs where possible, and reward good examples publicly.

Final thoughts: treat documentation as part of the build

When you pour a slab, you place rebar first. Think of documentation the same way—embedded, continuous, and strong enough to carry load. On projects where our team operated this way, we saw fewer disputes, faster approvals, and when a fight arrived, we brought a coherent, credible story backed by records created in the moment. That’s what holds up in court.

If you’re starting a project soon, pick two improvements from this guide and implement them on Day 1—daily reports with quantities and photos, and a clear change notice template are my favorite starting points. Within a month, add schedule narratives and signed T&M tickets for all changes. Stack those habits, and you’ll be building a record that’s just as solid as your structure.