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View Full Version : How to phrase a DFARS compliance statement


ScottK
23rd January 2008, 03:56 PM
We have a part that has brass and stainless steel components.

We specify in our POs that brass (that we machine) must be doemstic and we can prove that through certs and such.
We can't say the same for the dtainless because we are buying these components, not machining them ourselves.

The customer is asking if we are DFARS compliant... Not demanding it, but asking for a formal statment.

How would you phrase such a thing?

Thanks

domingue
23rd January 2008, 03:58 PM
On our Certificates of Conformance, I write "Complies with DFARS 252.225-7014." People seem to be fine with that - never had any issues.

EDIT: After rereading your question, I think I misunderstood. You might be able to get the information from your supplier to provide a definite statement, if you haven't already done so. I've found that most of our material certifications list the melt source anyway, although that may be because all our work is in aerospace to begin with. There's a long list of countries that are acceptable by the Specialty Metals Preference requirements, and I've found that most of the major mills around us come from one of those sources.

ScottK
23rd January 2008, 04:30 PM
On our Certificates of Conformance, I write "Complies with DFARS 252.225-7014." People seem to be fine with that - never had any issues.

EDIT: After rereading your question, I think I misunderstood. You might be able to get the information from your supplier to provide a definite statement, if you haven't already done so. I've found that most of our material certifications list the melt source anyway, although that may be because all our work is in aerospace to begin with. There's a long list of countries that are acceptable by the Specialty Metals Preference requirements, and I've found that most of the major mills around us come from one of those sources.

This is an aerospace customer. I kinds of find it odd that they are asking for a statement and not a line on the C of C.
Is there something in the Buy American legislation that call out a percentage?
The brass in this part is easily 75% by weight.

domingue
23rd January 2008, 05:27 PM
Yeah, I've never been in a situation where a statement on the CofC was insufficient. Weird - we deal with a bunch of OEMs too and they've never complained or asked for anything more.

I'm rather inexperienced so someone may know better than me, but to the best of my knowledge, any handling of any part of it outside of a DFARS country makes it noncompliant. Any other input is welcome though - I could very well be wrong on that.

Steve Weber
29th May 2008, 06:27 PM
According to one of our Aerospace customers the requirement states "specialty metals incorporated into products must be melted/smelted in the U.S. or one of the 21 qualifying countries". I do not know anymore than that. How do we determine if helicoils are DFARS compliant?

Jeff Frost
29th May 2008, 07:43 PM
The Defense Federal Acquisition Regulation Supplement (DFARS) Part 252 thought its various sub-sections require procurement of materials that have been made in the United States or from a qualified country of origin listed in the supplement.

DFARS 252.225.7014 specifically relates to specialty metals based on chemistry of the metal in question. I do not remember if brass is considered a specialty metal but I do know that stainless steel is and you should review the requirements at Defense Federal Acquisition Regulation Supplement (DFARS) and Procedures, Guidance, and Information (PGI) at http://www.acq.osd.mil/dpap/dars/dfarspgi/current/index.html.

Just remember you should not make a blanket certification to DFARS 252.225.7014 unless your supplier’s certification states their conformity to DFARS or it lists the country of melt.

Hope this helps

Jim Wynne
29th May 2008, 08:15 PM
According to one of our Aerospace customers the requirement states "specialty metals incorporated into products must be melted/smelted in the U.S. or one of the 21 qualifying countries". I do not know anymore than that. How do we determine if helicoils are DFARS compliant?

Have a look at the PDF file in the first hit (http://www.google.com/search?q=helicoil+dfars&ie=utf-8&oe=utf-8&aq=t&rls=org.mozilla:en-US:official&client=firefox-a).