How do you sell a DCMA Inspector on replacements for obsolete items?

apestate

Quite Involved in Discussions
Hello all

I've got a fun topic for conversation. It's about a company that makes parts for the government and a DCMA inspector.

The stuff we're making for the DOD is pretty simple, mechanical tools. Lots of various random highly specific $200 hammers made in quantities of 3 or 12 or so.

The blueprints are getting a little old, 1960's or thereabouts, and sometimes we have to prove that this or that AN- part number has been superceded or discontinued and is equivalent to this or that part number so our DCMA inspector can buy it off.

We have a tool kit made and purchased IAW with these old drawings, where the drawing says material is AISI O2, oil-hardening steel. We used O1. We used O1 without getting a contract mod and have used O1 in the past for this same tool kit that was signed off by the same DCMA guy.

The reasoning that worked in the past is that O2 is just hard to find and O1 is equivalent, or whatever. I'm feeling this reasoning is a little thin. But, in fact, O2 is nearly impossible to obtain, and I have no-quotes from our regular channels and even Carpenter Steel that I can show. AISI O1 and O2 are pretty similar.

Just looking for a little advice on how I might cover our asses after the guys upstairs pulled our pants down.
 
Last edited:

Stijloor

Leader
Super Moderator
Hello all

I've got a fun topic for conversation. It's about a company that makes parts for the government and a DCMA inspector.

The stuff we're making for the DOD is pretty simple, mechanical tools. Lots of various random highly specific $200 hammers made in quantities of 3 or 12 or so.

The blueprints are getting a little old, 1960's or thereabouts, and sometimes we have to prove that this or that AN- part number has been superceded or discontinued and is equivalent to this or that part number so our DCMA inspector can buy it off.

We have a tool kit made and purchased IAW with these old drawings, where the drawing says material is AISI O2, oil-hardening steel. We used O1. We used O1 without getting a contract mod and have used O1 in the past for this same tool kit that was signed off by the same DCMA guy.

The reasoning that worked in the past is that O2 is just hard to find and O1 is equivalent, or whatever. I'm feeling this reasoning is a little thin. But, in fact, O2 is nearly impossible to obtain, and I have no-quotes from our regular channels and even Carpenter Steel that I can show. AISI O1 and O2 are pretty similar.

Just looking for a little advice on how I might cover our asses after the guys upstairs pulled our pants down.


Can someone help apestate and his colleagues to cover their "behinds?" :D

Thank you!!

Stijloor.
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
I have some questions:

What Mil-Std are you working off of to make these tools?

How much of your business is devoted to this contract - is it worthwhile to go to effort to re-qualify the items with substitute material?

Have those MIL-STDs been revised? Being required to use such an old print seems improbable to me.

I found recent government documents that suggest you can negotiate a contract revision based on the substitute material. If you find yourself unable to pass inspection as it is, you can try getting approval for substitution. Your contracting office can give directions or references on that process.

The Department of defense has instituted a Parts Management Process, detailed in MIL-STD-3018. Clauses 5.1h, 6.4.6 and Appendix B, B.5.1 appear to apply.

I also found a Parts management Guide, SD-19. Pages 11, 12, 15, 17, 18, 21, 25 and 34 mention substitution, which suggests to me your case can be made if you can offer evidence that your parts management system meet government contractor requirements and the alternative material would function as well under the conditions in which the tool is used.

I hope this helps!
 
Last edited:
J

Jeff Frost

Your DCMA inspector is not there to accept product that does not meet the drawing and purchase order requirements. He or she is there to assure that your company has performed to the contract requirements and is supplying the materials as ordered by the government. If you want the DCMA inspector to accept product that does not conform to the drawing requirements your organization must get approval up front during the contract review and acceptance process, not at the back end, once the inspector has arrived and finds that you have not performed to government requirements.

My recommendation would be to spend more time during contract review to identify requirements and then propose alternatives during the quotation stage prior to order acceptance. Your offer of sale should state material type, test methods and alternative manufacturing methods. At this point all you can do is request a waver from the government buyer and hope they agree.
 
Last edited by a moderator:

apestate

Quite Involved in Discussions
These parts are made to a drawing, and we are not the design activity, so we can't really engineer the product differently.

The drawing has most likely been revised or changed by a blanket engineering order, but we don't have access to that. :>

You've given me much good information to ponder. Thank you for looking up those standards, Jennifer. Sounds like Jeff has a good idea. I'll try to push that up through management.

We're a small company and don't have a lot of experience with this stuff because most of our product is proprietary, that we sell directly. Most of the big customers we make parts for have been pretty lenient with regard to compliance and quality assurance issues, and the DOD contracts have only been coming for about two years.

Thanks for your attention to this. Learning about doing business with the government has been tough, there's an awful lot to process.
 

apestate

Quite Involved in Discussions
UPDATE:

We were able to obtain a copy of an ECN which does, in fact, substitute O1 for AISI-O2, for this part number.

They really need to start paying attention to these contracts. We've already got enough Level II CA's for stuff like this.

Thank you all for your help.
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
That's good news about the ECN, I had hoped it would already be out there somewhere. The standards I looked up indicated material substitution was possible, but it would entail a qualification process that I wondered if you would be willing to undertake; I got the sense you don't sell a whole lot of this stuff to them.

You say "They really need to start paying attention to these contracts." Who are they?
 

apestate

Quite Involved in Discussions
They, the people I work for. It wasn't long ago when they came to me about a job that was finished and waiting to ship... waiting on first article paperwork. According to the purchase order, first article was to be in accordance with AS9102.
 
M

MRFMACHINE

You can file a waiver or deviation DD form 1694 for a material change they will review and consider it especially if there is a cost savings.
 
Top Bottom