Good afternoon everyone. "First time caller, long time listener" here. I have a couple questions that I'm hoping someone may be able to give insight into. I tried doing a search in the forums but did not see anything that was in-line with my question. I've also attempted to use internet searches with no success.
At our surveillance audit last year, our auditor was discussing flow down requirements specifically in regards to DPAS rated orders. He said that if we took on a DPAS rated order, all purchase orders to our suppliers would require the DPAS order (which we were doing) as well as the government contract number tied to that DPAS rated order to provide our suppliers with any requirements that would flowed down by default by the Prime as well as the contract requirements from the government branch that issued the contract to the Prime (which we were not doing).
He also stated that when the suppliers provided the product or service, that ALL of their paperwork required the DPAS rating. (Shippers, CofC's, etc...).
The reason I'm coming to the Cove to see if anyone can provide additional insight (and if you have a direct link to something official that corroborates your information, that's an added plus!), is while re-reading the DPAS I came across a clause that I wasn't aware of. 15 CFR Part 700.17f says that if an order is under $125,000 and you are confident that your supplier can meet your delivery requirements without the need of a DPAS flow down, then you are not required to flow the DPAS rating down. For us, this would primarily apply to our heat treat sources. They run our parts like clockwork and flowing down or not flowing down the DPAS would not impact the delivery time in any way for us. If we chose not to flow down the DPAS rating, then how would the supplier know to send paperwork back with a DPAS rating on it if they weren't aware of it.
Long story short:
1) If we provide the DPAS flow down, is it a requirement of AS9100D or of the DPAS itself that ALL returning documentation restate the DPAS rating?
2) If all documents provided by a supplier do actually require the DPAS rating, how would that be applicable if we used the 15 CFR 700.17f clause and our supplier was unaware of the DPAS rating?
For reference, we are a CNC machining job shop. We were AS9100 certified 2022, so we are still in our learning/growing stages with this.
At our surveillance audit last year, our auditor was discussing flow down requirements specifically in regards to DPAS rated orders. He said that if we took on a DPAS rated order, all purchase orders to our suppliers would require the DPAS order (which we were doing) as well as the government contract number tied to that DPAS rated order to provide our suppliers with any requirements that would flowed down by default by the Prime as well as the contract requirements from the government branch that issued the contract to the Prime (which we were not doing).
He also stated that when the suppliers provided the product or service, that ALL of their paperwork required the DPAS rating. (Shippers, CofC's, etc...).
The reason I'm coming to the Cove to see if anyone can provide additional insight (and if you have a direct link to something official that corroborates your information, that's an added plus!), is while re-reading the DPAS I came across a clause that I wasn't aware of. 15 CFR Part 700.17f says that if an order is under $125,000 and you are confident that your supplier can meet your delivery requirements without the need of a DPAS flow down, then you are not required to flow the DPAS rating down. For us, this would primarily apply to our heat treat sources. They run our parts like clockwork and flowing down or not flowing down the DPAS would not impact the delivery time in any way for us. If we chose not to flow down the DPAS rating, then how would the supplier know to send paperwork back with a DPAS rating on it if they weren't aware of it.
Long story short:
1) If we provide the DPAS flow down, is it a requirement of AS9100D or of the DPAS itself that ALL returning documentation restate the DPAS rating?
2) If all documents provided by a supplier do actually require the DPAS rating, how would that be applicable if we used the 15 CFR 700.17f clause and our supplier was unaware of the DPAS rating?
For reference, we are a CNC machining job shop. We were AS9100 certified 2022, so we are still in our learning/growing stages with this.
