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DCMA (Defense Contract Management Agency) asking for Inspection Schedule Dates

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CoronaMachining

#1
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.
 
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JLyt207

Involved In Discussions
#2
Is it possible that they were only asking for the dates just because they want to witness those inspection points? That is what happened to us. The DCMA wanted to witness our inspection using a laser tracker. We also could not provide an exact date for the inspection. We had a good working relationship with the DCMA and so we explained why we couldn't give a date. We worked out a plan in which we could contact them the day before inspection began. It worked out well. They did their overseeing and we didn't have to risk setting a schedule that was unlikely to be accurate.
It may be an apple and orange situation. Our build was around 9 months in length and the tracker would need a day and a half to shot the part they wanted to see. So there was plenty of flexibility in time.
 
C

CoronaMachining

#3
Thanks for your reply. Unfortunately these are not inspection points. They want specific dates of when product will be called in for GSI. I received an email from my DCMA QAI this morning and he wanted specific dates for contracts I will be calling in for the month of September.

I might add, afternoon I reached out to another contractor in Fullerton and he told me the same thing DCMA requesting dates of when product will be ready for GSI inspection. He is not happy about it either!
 

JLyt207

Involved In Discussions
#4
This is a new, and not so welcome, development to me. I don't currently have DCMA in the house. But I will look out for this change.
 
S

Shoes

#5
Hi CoronaMaching,
I attended the same meeting with the same speaker. My take on the scheduling is that in the past, Government Source Inspectors have not been performing their inspections in a timely manner, then claimed too heavy a work load to accomplish them. In my view the shipping schedule is not firm until we send the GSI Request via email to DCMA for each shipment.
A schedule of 3 shipments in September, estimated as the 12th, 18th, and 24th informs them of how much work they should anticipate from your facility. The driver for scheduling the actual date is the email. Remember they are monitoring every request and if the inspectors do not respond, their Supervisor will hear about it.
Hope this helps, we have not had any suggestion of Corrective Action, but have been asked to provide schedules.
 

David-D

Involved In Discussions
#6
I'm not completely certain of your situation but the standard Government Federal Acquisition Regulation (FAR) contract clause 52.246-2 (Inspection of supplies) requires (or allows for the requiring of) notification of the USG prior to the inspections to allow participation/oversight of the testing and acceptance. I'd particularly point you to paragraphs i(1) and i(2). I'd expect the clause itself to be included in Section E of your contract either in its entirety or by reference.

The clause overall establishes much of the essential Government's rights regarding quality: oversight, acceptance and rejection, corrective action, inspection system requirements, records, flow down, etc., etc., etc.

You can get copy of the clause at:
http://www.acquisition.gov/far/html/52_246.html

If you're looking for all the FAR clauses (and DFAR, etc but not local clauses), I'd suggest:
http://farsite.hill.af.mil

David
 
J

John 1910

#7
As a retired DCMA Quality Assurance Representative (QAR) with 25 years’ experience, requesting dates is not a QAR function. Date modifications, date clarifications and shipping dates are administered by the DCMA Industrial Specialist (IS) and the Procuring Contracting Officer (PCO) or Administrating Contract Officer (ACO). The QAR has no jurisdiction for holding a contractor to a date let alone requesting a date from them. The only exceptions would be for a process validation which would be agreed upon during a pre-award, a hold point as to perform an inspection or oversight or by means of a letter of delegation and per a GSI request.

If a QAR threatens you with a corrective action for NOT supplying dates, ask him or her where this is in DCMA policy and the FAR? If a corrective action is generated for missing a date, again, ask your QAR where this is in policy? And immediately forward the CAR to the PCO or ACO.
As a contractor, you’re only responsible for ensuring you meet the requirements per the awarded contract. Any issues to include changes with the contract you must speak with the CO/PCO first (listed on the front page of the contract). Read FAR 42.302 as to understand what they can or can’t do. He or she may have delegated authority to the ACO who works for DCMA. Only these two can make changes to a contract and this includes dates! Anything outside of this is a violation of the FAR and DCMA policy.

Supplying this information to a QAR and not meeting it could cost you a corrective action with your 3rd party auditor and DCMA. The ISO9001 and the AS9100, section 7.2.3 b should be treated with high regards – communications! The DCMA QAR is performing the inspection and either accepting or rejecting product on behalf of the customer. Thus, they are the customer. If you supply a date and miss it, you failed per 7.2.1 section a. Failing could lead to a CAR.

To answer your original question, no, you don’t have to supply this information to the QAR. If they threaten you with a CAR, again, ask them to show you where this requirement is stated in the FAR or DCMA Policy. If they reference the ISO or AS9100 clauses, ask the QAR who has authority to change a date in the contract? No policy exists either in DCMA or the FAR that authorizes the QAR to request and hold a contractor to a date beyond of what is in the contract.

Shoes; I spoke with 2 QAR’s out of the Santa Ana office. Both told me they have been threaten with disciplinary action if the contractor slips their date once it has been finalized with the contractor. I advised both of these QAR’s to contact legal immediately and or DCMA HQ to make them aware of this. Some pretty serious ramifications here to include cost, authority and delegation with a QAR holding a contractor to a date that is not listed in the contract. Regarding the workload, it has been a mess there for some time. Recently it has been corrected with the formation of a new team and shifting the workload around.

Regarding the presenter, I have worked with this individual and I would caution you with what he does or says. I highly recommend any communications with him you ask him to provide the FAR or policy section(s) for clarification.
 
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C

CoronaMachining

#8
John and David, and all, thank you for your responses.

From what I gathered;

1. Providing date(s) to the QAR I will be held accountable for these date(s) per the ISO9001 and AS9100 system.
2. Nothing in their policy states I need to provide this information to the QAR with a few noted exceptions.
3. Not to provide this date and to honor the contract date.
4. When ready to ship, contact the QAR as per the FAR and they will schedule the GSI inspection.
5. CAR issued, contact the PCO or ACO.

Did I miss anything?
 
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