FAR/Prime Contractor Flow-down Tool - AS9100

[brekke777]

Hi all,

I'm in the process of fixing a few issues with our AS9100 QMS for my company. One the issues we have is a lack of a proper flowdown process/procedure for ensuring all required FAR clauses, and customer specific clauses are flowed down to our sub tier vendors. We have our own Quality Clauses that cover some things. But can anyone provide me with any guidance as to how they perform this? We issue purchase orders through Job Boss, and list our applicable clauses. I'm just looking for an efficient way of flowing down everything that is required. All I have right now is looking at copying and pasting the FAR and customer related clauses into notes, but I don't know if that's feasible with how lengthy some can be. Any thoughts or suggestions? Thank you!

 

[David-D]

For the FAR clauses, you might consider inclusion by reference, particularly for the clauses which don't require any fill-ins. Many FAR based USG contracts do this (Section H or I ?) And they carry the same weight as if they were fully pasted in.

In that case you could list the clause number, title and date as well as a source for the clauses ( suggest the official source Acquisition.GOV | www.acquisition.gov ) This would atleast limit the amount of entry and limit the liklihood of transcription errors.

On the other hand, it doesn't guarantee that someone will READ or FOLLOW them, but neither does putting them in the contract itself.

David

 

[John Predmore]

The way we resolved this audit finding was put the Terms & Conditions on our company website, "Doing Business with xxx". At the bottom of the purchase order template we added the boiler plate verbiage to reference Ts & Cs from our website. At the top of the 8-page list of Ts & Cs is a version number, so a supplier can tell at a glance if the version in their file is the same as the version on our website.

Now in your case, if not all requirements apply to all suppliers, you could number the clauses and on individual purchase orders, list the numbers which apply or the ones which do not apply.

 

[brekke777]

The way we resolved this audit finding was put the Terms & Conditions on our company website, "Doing Business with xxx". At the bottom of the purchase order template we added the boiler plate verbiage to reference Ts & Cs from our website. At the top of the 8-page list of Ts & Cs is a version number, so a supplier can tell at a glance if the version in their file is the same as the version on our website.

Now in your case, if not all requirements apply to all suppliers, you could number the clauses and on individual purchase orders, list the numbers which apply or the ones which do not apply.

That is exactly how we handle our own clauses. We reference the clause # on PO's, and point to our web site for the actual clauses. That works perfectly for our own internal requirements. I've given our purchasing agent a "cheatsheet" with the clauses they need to attach depending on what it is they are buying. What I'm after is how to flow down our customer's specific clauses (we deal with the big three in aerospace, and several others who have their own clauses they want flowed down) and most of these are all owners of prime contracts, so FAR clauses and so forth need flowed down as well. I've done alot of searching around hoping for an online tool or something to somewhat automate this. But might have to work each individual purchase order and do it similiar to how we flow our internal clauses. List the applicable FAR, customer, etc specific clauses that are required, and a note pointing to the www.acquisition.gov or customer's clause site to reference. It's starting to look like this is the only route, which is OK, we have to do what's required. But it's going to add ALOT of workload to our purchasing agent's plate. Posted here hoping to see how other's tackled this, as I'm sure it's a common theme and everyone has a method.