A schedule that passes a DCMA 14-point health check can still come back from the Corps of Engineers for its activity durations. The two use very different limits, and the Corps' limit is the stricter one by a wide margin.
The sentence
UFGS 01 32 01.00 10, the Corps of Engineers' Project Schedule section, says in paragraph 3.3.2:
Reasonable activity durations are those that allow the progress of ongoing activities to be accurately determined between update periods. Non-procurement activities Original Durations (OD) are not to exceed 20 workdays or 30 calendar days.
Two things in that sentence matter more than the number.
It has no tolerance. The rule applies to every non-procurement activity. One activity at 22 workdays breaks it. The superseded 2008 edition of the section allowed a small share of activities to exceed the limit; the current edition does not.
It is about Original Duration. The limit is measured on the duration you planned, not on what is left. Splitting the remaining work of a long activity in an update does not change its Original Duration.
Why DCMA 14 does not catch it
The DCMA 14-point assessment flags activities longer than 44 working days, and treats up to 5 percent of them as acceptable. A 30-day activity passes DCMA without comment and fails 3.3.2. A schedule built to pass a generic health check is not built to this specification.
What the rule does not cover
The sentence limits non-procurement activities. Paragraph 3.3.4 says what procurement includes:
Include in the schedule activities associated with the critical submittals and their approvals, procurement, fabrication, and delivery of long lead materials, equipment, fabricated assemblies, and supplies.
So a 60-day fabrication or delivery activity is not a 3.3.2 finding. A submittal approval can be part of that chain too, when it is a critical submittal for a long-lead item. Which submittals are critical is a question of your contract, not of the schedule file, so it is worth confirming with your Resident Office rather than assuming.
What the exemption does not cover is administrative work that merely sounds procedural. A method statement, a safety plan or a personnel submittal buys, makes and delivers nothing, so it is not procurement and the 20-workday limit applies to it.
Workdays or calendar days?
The paragraph gives two measures. Paragraph 3.3.10 asks for calendars that fit the work:
Develop calendars to accommodate any contract defined work period such as a 7-day calendar for Government Acceptance activities, concrete cure times, etc.
A concrete cure on a 7-day calendar is naturally measured in calendar days. A field activity on a 5-day calendar is measured in workdays. If your activity sits on an unusual calendar, such as a 6-day week, a compressed week or one with a long shutdown, the span in calendar days and the count in workdays can tell different stories. Ask your Contracting Officer how they read the limit before reworking a large schedule.
How to fix a schedule that breaks it
- List every non-procurement activity over 20 workdays. Filter on Original Duration in P6 and check each one's calendar.
- Split each into steps a reviewer can measure between updates, for example by area, floor or system, linked with logic. The test in the first sentence of 3.3.2 is whether progress can be measured accurately between updates.
- Leave genuine procurement activities alone, and make sure they read as procurement. An activity code value marking them, such as a Category code of PROC, saves a reviewer guessing.
- Put cure and Government acceptance periods on a 7-day calendar, as 3.3.10 asks.
This article describes published specification text. It is not an engineering opinion. Your contract's own specification, and your Contracting Officer's reading of it, govern your schedule.