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LESSON 5 Product Acceptance and Release. 15November2013. Lesson Introduction.
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LESSON 5Product Acceptance and Release 15November2013
Lesson Introduction Given the Defense Contract Management Agency (DCMA) acceptance and release policies and procedures, the student will be able to determine which acceptance and release method to use when authorizing product/service acceptance and release.
Lesson Objectives Upon completion of this lesson, you should be able to: • Identify the regulations governing the role of DCMA Quality Assurance (QA) in acceptance and release of products and services. • Identify the reasons why documenting the QA records in the official contract file is important. • Discuss the use and application of Department of Defense (DoD) inspection stamps. • Identify the conditions for authorizing shipment and acceptance of products via Alternate Release Procedures (ARP). • Discuss DCMA’s policy on the use of ARP.
Lesson Objectives (cont.) Upon completion of this lesson, you should be able to: • Identify radio indicators on the supplier’s shipping document that are required when ARP or Certificate of Conformance (CoC) are authorized. • Identify the conditions for authorizing shipment and acceptance of products/services via CoC. • Distinguish the differences between ARP and CoC usage for authorizing release of shipment. • Discuss the use of the Wide Area Work Flow (WAWF) Receiving Report (RR) and DD Form 250 by DCMA in the acceptance of products and services from suppliers. • Recognize common mistakes made by suppliers on acceptance documents.
Lesson Topics This lesson covers the following topics: • Authority and Regulations • Quality Assurance Product Acceptance Guidelines • Inspection Stamps • Alternate Release Procedures (ARP) • Certificate of Conformance (CoC) • Documenting Product Acceptance
WIIFM? The ultimate goal of the QAS is to reach the point where he/she can accept a product on behalf of the Government. This is a major role in the Quality Assurance Specialist (QAS) function. Team Takes Pride in SV-1 Successful Launch
Authority and Regulations Lesson Topics: Authority and Regulations Quality Assurance Product Acceptance Guidelines Inspection Stamps Alternate Release Procedures (ARP) Certificate of Conformance (CoC) Documenting Product Acceptance
Topic 1: Authority and Regulations • Federal Acquisition Regulation (FAR) 46.104 Contract Administration Office Responsibilities • FAR 46.5 – Acceptance • Defense Federal Acquisition Regulation Supplement (DFARS), Appendix F – Material Inspection and Receiving Report(Rev Sept 2011)
FAR 46.501 – General • Acceptance constitutes acknowledgment that supplies/services conform with contract quality and quantity requirements. • Acceptance may take place before delivery, at the time of delivery, or after delivery, depending on the provisions of the terms/conditions of the contract.
FAR 46.501 – General (cont.) • Supplies/services shall ordinarily not be accepted before completion of Government QA actions. • Acceptance shall ordinarily be evidenced by execution of an acceptance certificate on an inspection or receiving report form.
FAR 46.502 –Responsibility for Acceptance • Acceptance of supplies and services is the responsibility of the cognizant contracting officer. • When this responsibility is assigned to a cognizant contract administration office or to another agency, acceptance by that office or agency is binding on the Government.
FAR 46.503 – Place of Acceptance • Each contract shall specify the place of acceptance. • Contracts that provide for Government contract QA at source shall ordinarily provide for acceptance at source. • Contracts that provide for Government contract QA at destination shall ordinarily provide for acceptance at destination. • Supplies accepted at a place other than destination shall not be reinspected at destination for acceptance purposes, but should be examined at destination for quantity, damage in transit, and possible substitution or fraud.
FAR 46.503 – Place of Acceptance DCMA Summary The DCMA QAS performs Government Contract Quality Assurance (GCQA) when the contract specifies that the contract will be administered by DCMA and also specifies inspection and/or acceptance at source.
FAR 46.504 – Certificate of Conformance • A certificate of conformance (see 46.315) may be used in certain instances instead of source inspection (whether the contract calls for acceptance at source or destination) at the discretion of the contracting officer if the following conditions apply: • (a) Acceptance on the basis of a contractor’s certificate of conformance is in the Government’s interest.
FAR 46.504 – Certificate of Conformance (cont.) • (b) (1) Small losses would be incurred in the event of a defect; or (2) Because of the contractor’s reputation or past performance, it is likely that the supplies or services furnished will be acceptable and any defective work would be replaced, corrected, or repaired without contest. In no case shall the Government’s right to inspect supplies under the inspection provisions of the contract be prejudiced.
FAR 46.505 – Transfer of Title and Risk of Loss (1 of 5) • (a) Title to supplies shall pass to the Government upon formal acceptance, regardless of when or where the Government takes physical possession, unless the contract specifically provides for earlier passage of title.
FAR 46.505 – Transfer of Title and Risk of Loss (2 of 5) • (b) Unless the contract specifically provides otherwise, risk of loss of or damage to supplies shall remain with the contractor until, and shall pass to the Government upon–– (1) Delivery of the supplies to a carrier if transportation is f.o.b. origin; or (2) Acceptance by the Government or delivery of the supplies to the Government at the destination specified in the contract, whichever is later, if transportation is f.o.b. destination.
FAR 46.505 – Transfer of Title and Risk of Loss (3 of 5) • (c) Paragraph (b) of this section shall not apply to supplies that so fail to conform to contract requirements as to give a right of rejection. The risk of loss of or damage to such nonconforming supplies remains with the contractor until cure or acceptance. After cure or acceptance, paragraph (b) of this section shall apply.
FAR 46.505 – Transfer of Title and Risk of Loss (4 of 5) • (d) Under paragraph (b) of this section, the contractor shall not be liable for loss of or damage to supplies caused by the negligence of officers, agents, or employees of the Government acting within the scope of their employment.
FAR 46.505 – Transfer of Title and Risk of Loss (5 of 5) • (e) The policy expressed in (a) through (d) of this section is specified in the clause at 52.246-16, Responsibility for Supplies, which is prescribed in 46.316.
DFARS Appendix F • Introduction, Sections F101-104 • Contract Quality Assurance on Shipments between Contractors, Section F201 • Preparation of the Wide Area Workflow Receiving Report (WAWF-RR), Sections F301-307 • Preparation of the DD Form 250 and DD Form 250C, Sections F401-408 • Distribution of WAWF-RR, DD Form 250 and DD Form 250C, Sections F501-502 • Preparation of the DD Form 250-1 (Loading Report), Section F 601 • Preparation of DD Form 250-1 (Discharge Report), Section F701 • Distribution of the DD Form 250-1, Sections F801-802 Material Inspection and Receiving Report
Question and Answer How is acceptance of a product ordinarily evidenced? (Select all that apply.) • WAWF-RR signed by the DCMA QAS with inspection and acceptance blocks checked • DD Form 250 acceptance block checked and signed by Government representative • WAWF-RR signed by the QAS with ARP and acceptance blocks checked • A stamp on the shipping document/packing list
Question and Answer Fred is a new QAS. He needs guidance on using, preparing, and distributing the Wide Area Workflow Receiving Report that his customer uses. Where does he find this information? • FAR 46.104 • FAR 46.5 • DFARS, Appendix F • DFARS 246.471
Question and Answer When FOB destination is stipulated, who is responsible for the transportation arrangements and costs? • Government • Customer • Supplier • Shipping company
Quality Assurance Product Acceptance Guidelines Lesson Topics: Authority and Regulations Quality Assurance Product Acceptance Guidelines Inspection Stamps Alternate Release Procedures (ARP) Certificate of Conformance (CoC) Documenting Product Acceptance
Topic 2: Quality Assurance Product Acceptance Guidelines • FAR 46.104(c) requires documentation of surveillance results • Acceptance of: • Shipments • Software
QA Documentation Requirements FAR 46.104(c) Results of all surveillance must be recorded in any convenient format; but as a minimum, records must reflect who performed the surveillance, where the surveillance was performed (in-plant location), the number and nature of observations made, the number and nature of defects found, and corrective actions initiated to resolve deficiencies.
Authorizing and Accepting Shipments • DCMA personnel must not accept or approve products/supplies offered by the contractor unless there is a basis of confidence in conformance to contract technical and quality requirements. • Where no such confidence exists and it cannot be derived from credible data, personnel must escalate the issue to management for resolution with the customer.
Accepting Software Product Software acceptance, whether stand-alone or embedded (end item or system), is performed by, or in coordination with, Software Professional Development (SPDP) Journeyman Certified personnel.
Question and Answer Katie cannot determine if the solid rivets being manufactured for aircraft use meet the requirements of the contract. What should she do? • Accept the rivets because it’s only a minor nonconformance. • Not accept the rivets and escalate the issue to DCMA management. • Accept the rivets, but notify the Administrative Contracting Officer (ACO). • Not accept the rivets and escalate the issue to the Procuring Contracting Officer (PCO).
Inspection Stamps Lesson Topics: Authority and Regulations Quality Assurance Product Acceptance Guidelines Inspection Stamps Alternate Release Procedures (ARP) Certificate of Conformance (CoC) Documenting Product Acceptance
Topic 3: Inspection Stamps Inspection stamps • Authority • DCMA policy • Who issues stamps • Types • Mandatory use • Optional use
Authority FAR 46.4 – Government Contract Quality Assurance FAR 46.401(g) – Agencies may prescribe the use of inspection approval or disapproval stamps to identify and control supplies and material that have been inspected for conformance with contract quality requirements.
DCMA Stamp Policy • When specifically required by customer, Quality Letter of Instruction (QALI), or a Letter of Delegation (LOD), the QAS must use DoD inspection stamps upon determination of product’s and packaging’s compliance with contractual requirements. • Inspection Stamping- QA Stamps http://www.dcma.mil/policy/310/DCMA-INST-310.pdf • DCMA HQ Operations, International, and Special Programs Directorates/CMOs must be responsible for controlling the issue and use of inspection stamps.
Who Issues Inspection Stamps First Line Supervisor (FLS) – Determining authority for stamp issuance. • Contract Management Office (CMO) Standard Operating Procedure • Routinely Administrative Support activity • QA Co-signature required • Annual accountability
Inspection Stamps–Types The two stamps are: • Round ½ inch • Square ½ inch
Inspection Stamps–Mandatory Use Where DCMA QA proof of inspection or test is required by the customer: • Mandatory Inspection Points • Witness a mandated activity • Test • Inspection • Condition of field returns, etc. • In-process paperwork • Traveler, test record, shipper, etc.
Inspection Stamps–Optional Use • DFARS 246.471(a)(1) – Ordinarily, a representative of the Contract Administration Office (CAO) signs or stamps shipping documentation that accompanies Government source-inspected supplies prior to release for shipment. This is done for both the prime and subcontract level. • Subcontract level - DFARS, Appendix F, F-201 Shipments between Contractors • DD Form 250 Acceptance Photo by Mark Woodbury, DCMA Public Affairs
Question and Answer Don is confused about DCMA’s policy on using inspection stamps. When does DCMA mandate he use inspection stamps? • When required by the customer via a QALI or LOD • When the product and packaging are in compliance with contractual requirements • Upon CMO direction • Upon ACO direction
Alternate Release Procedures (ARP) Lesson Topics: Authority and Regulations Quality Assurance Product Acceptance Guidelines Inspection Stamps Alternate Release Procedures (ARP) Certificate of Conformance (CoC) Documenting Product Acceptance
Topic 4: Alternate Release Procedures (ARP) • Overview • Conditions • Exceptions • Considerations • Document statements • Process
ARPOverview • ARP application, as per DFARS 246.471(b) and DCMA Product Acceptance and Release Policy • ARP eliminates only clerical function of signing shipping documents prior to product release • Planned surveillance must be accomplished • ARP may be invoked at facility, contract, product line, or part number level • Some customers forbid ARP use (Tasking Memo 09-042)
ARP Authorization Conditions CAO may issue the supplier written authorization to release supplies for shipment when: • CAO representative’s stamping/signing of shipping papers interferes with GCQA or is too time consuming. • Sufficient production continuity permits Government establishment of systematic and continuing supplier surveillance. • Supplier’s record indicates satisfactory quality, including shipment preparation. Withdraw this authority when any of these conditions are not met!
ARP Exceptions • ARP is NOT authorized for shipments for National Aeronautics and Space Administration (NASA), Level 1/SUBSAFE (L1/SS), or Navy Special Emphasis Programs (NSEP), unless specifically authorized, in writing. • Not applicable to services
ARP Considerations • ARP does not alleviate U.S. Government source inspection requirements. • GCQA surveillance activities must still be planned and conducted • ARP requires no contract clause. • ARP is applicable for products but not services. • ARP is available/applicable to both prime suppliers and sub-tier suppliers.
Shipping Document Statements When ARP is invoked, the following statements must be typed/stamped/attached to required shipping paper(s) copies and signed: • The supplies in this shipment— • 1. Have been subjected to and have passed all examinations and tests required by the contract; • 2. Were shipped in accordance with authorized shipping instructions; • 3. Conform to the quality, identity, and condition called for by the contract; and • 4. Are of the quantity shown on this document. • This shipment was— • 1. Released in accordance with section 246.471 of the Defense FAR Supplement; and • Authorized by (name and title of the authorized representative of the contract administration office) in a letter dated (date of authorizing letter). (Signature and title of contractor's designated official.)
ARP Process 1 2 3
Question and Answer Under what conditions can the Contract Administration Office (CAO) invoke ARP? (Select all that apply.) • CAO issues ARP authorization at appropriate level (facility, contract, product line, or part number). • QAS performs planned surveillance. • Authorized personnel sign paper DD250 or process in WAWF (DFARS Appendix F-301 (b)(21)(iv)(D)(2)). • A CoC has been provided.