Michael is absolutely correct here, Completion should not have been certified with 4000 Defects and the PM is in breach of contract for doing so. Maybe the Employer should consider recovering their costs from the PM?
It's a nonsense to specify zero defects as an absolute obligation in the WI as it's unrealistic, zero defects is merely an aspiration.
In any case technically these 4000 Defects require correcting within the defect correction period after Completion was certified, which they surely weren't and therefore the PM would have the right to assess the additional cost to the Employer of having them corrected by others.
Each Defect should be managed separately, the purpose of the NEC processes is to avoid long, un-managable lists.
It's a nonsense to specify zero defects as an absolute obligation in the WI as it's unrealistic, zero defects is merely an aspiration.
In any case technically these 4000 Defects require correcting within the defect correction period after Completion was certified, which they surely weren't and therefore the PM would have the right to assess the additional cost to the Employer of having them corrected by others.
Each Defect should be managed separately, the purpose of the NEC processes is to avoid long, un-managable lists.