Why the evidence gap opens
On most EPC projects the ITP is written once, signed by three parties, then filed. Field execution drifts: inspectors sign for activities they witnessed weeks earlier, photos are stored in a shared drive with no ITP reference, mill certificates arrive in PDFs no one links back to the heat number they cover.
By the time the owner's team assembles the turnover data-book, 20–40% of hold-point rows cannot be evidenced. The registrar or regulator then either extends the punch list, or worse, accepts a package that will not survive a downstream incident investigation.
