C
CoronaMachining
We are seeking some assistance or guidance for an issue which recently arose concerning a request from our Quality Assurance Inspector, (QAI), to provide an inspection schedule for our Critical Safety Items, (CSIs), and First Article Inspections, (FAIs). Our concern in providing this schedule is we will be held accountable to these new dates. If we slip, a Corrective Action(s) will be issued.
I am the owner of a small machine shop located in Corona, California. The company is an ISO9001/AS9100 certified company, and we have been certified for more than 10 years. Approximately 75% of our current business is with the Defense Logistics Agency, (DLA), and the U.S. Air Force. Several of our contracts are for CSIs and some of the others require FAIs. Our contracts require us to contact the Santa Ana office of the Defense Contract Management Agency, (DCMA), for source inspection [FAR 52.246-2(i)(1) and (2)].
When our DCMA QAI requested a schedule for our CSIs and FAI inspection dates, we informed him we could not give him exact dates. The reason for our response was we are dependent on subcontractors to move the product forward. In many cases, we adjust our schedules based on the needs of our customers - contract officers. Furthermore, in order to meet this date requirement I would need to hire a fulltime production planner to monitor dates and this I can't afford. Our on-time shipping record is very good, and we honor our expedited order requests. In cases where our dates have slipped, we have contacted our contract officer to obtain an extension. Our QAI advised us that failure to provide the requested information could lead to a Corrective Action. We advised our QAI that our contract states we are only required to ship on or before the required shipping date. Our understanding is as long as we meet our contract requirements for inspection and shipping dates, we are not in violation our contracts; therefore, we do not understand how our QAI can issue a CAR. He cited ISO 9001 7.2.2, Review of Requirements Related to the Product, and 7.2.3b, Customer Communication, as the specific clauses requiring us to provide the information he requested. Our response was we are meeting our contract requirements and are not in violation of our contracts. We contact our QAI prior to the required contract shipping dates and follow the FAR clauses including GSI requests 7 days prior to the ship date to perform inspections.
Recently Joe Wible, Director of Quality Assurance for DCMA Santa Ana, CA. hosted a meeting, which I attended regarding a program called Path Forward. During the meeting the subject of GSI requests came up, and Mr. Wible stated DCMA is not looking for exact dates, but what will be shipping for the month so the QAI may schedule his/her work load. I advised the QAI of Mr. Wible’s comment, and he said Mr. Wible flowed down, to all QAIs, that they must obtain inspection dates and they would be accountable for any slipped dates by their contractors. I sensed our QAI was doing what was required of him, but was not happy about it.
As a side note, I contacted two of our contract officers and both advised me the only date we are required to adhere to are the dates stated in the contracts. Both seemed confused with why DCMA would be requesting this type of information. In fact, one contract officer stated this was in clear violation of the FAR and DLA and DCMA policy. The only date(s) they are required to honor is per FAR 52.246-2(i)(1) and (2)- 7 days to act on the GSI request.
I would appreciate any suggestions on how to approach this issue so we are not tied into a schedule which will result in our company receiving a CAR.
I am the owner of a small machine shop located in Corona, California. The company is an ISO9001/AS9100 certified company, and we have been certified for more than 10 years. Approximately 75% of our current business is with the Defense Logistics Agency, (DLA), and the U.S. Air Force. Several of our contracts are for CSIs and some of the others require FAIs. Our contracts require us to contact the Santa Ana office of the Defense Contract Management Agency, (DCMA), for source inspection [FAR 52.246-2(i)(1) and (2)].
When our DCMA QAI requested a schedule for our CSIs and FAI inspection dates, we informed him we could not give him exact dates. The reason for our response was we are dependent on subcontractors to move the product forward. In many cases, we adjust our schedules based on the needs of our customers - contract officers. Furthermore, in order to meet this date requirement I would need to hire a fulltime production planner to monitor dates and this I can't afford. Our on-time shipping record is very good, and we honor our expedited order requests. In cases where our dates have slipped, we have contacted our contract officer to obtain an extension. Our QAI advised us that failure to provide the requested information could lead to a Corrective Action. We advised our QAI that our contract states we are only required to ship on or before the required shipping date. Our understanding is as long as we meet our contract requirements for inspection and shipping dates, we are not in violation our contracts; therefore, we do not understand how our QAI can issue a CAR. He cited ISO 9001 7.2.2, Review of Requirements Related to the Product, and 7.2.3b, Customer Communication, as the specific clauses requiring us to provide the information he requested. Our response was we are meeting our contract requirements and are not in violation of our contracts. We contact our QAI prior to the required contract shipping dates and follow the FAR clauses including GSI requests 7 days prior to the ship date to perform inspections.
Recently Joe Wible, Director of Quality Assurance for DCMA Santa Ana, CA. hosted a meeting, which I attended regarding a program called Path Forward. During the meeting the subject of GSI requests came up, and Mr. Wible stated DCMA is not looking for exact dates, but what will be shipping for the month so the QAI may schedule his/her work load. I advised the QAI of Mr. Wible’s comment, and he said Mr. Wible flowed down, to all QAIs, that they must obtain inspection dates and they would be accountable for any slipped dates by their contractors. I sensed our QAI was doing what was required of him, but was not happy about it.
As a side note, I contacted two of our contract officers and both advised me the only date we are required to adhere to are the dates stated in the contracts. Both seemed confused with why DCMA would be requesting this type of information. In fact, one contract officer stated this was in clear violation of the FAR and DLA and DCMA policy. The only date(s) they are required to honor is per FAR 52.246-2(i)(1) and (2)- 7 days to act on the GSI request.
I would appreciate any suggestions on how to approach this issue so we are not tied into a schedule which will result in our company receiving a CAR.
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