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25th National Aerospace FOD Prevention Conference July 27 - 29, 2004. Ground and Flight Risk Clause and its effect on FOD Prevention Programs. My Background. Former KC-135 Pilot 21 ½ Years Active Duty Retired in 2000 Began second career in same job as civilian
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25th National AerospaceFOD Prevention Conference July 27 - 29, 2004 Ground and Flight Risk Clause and its effect on FOD Prevention Programs
My Background • Former KC-135 Pilot • 21 ½ Years Active Duty • Retired in 2000 • Began second career in same job as civilian • Contractor Aircraft Operations since 1989
Contact Information • john.heib@dcma.mil • DSN 328-1313 • 703-428-1313 • home.dcma.mil
Contractor Ops 101 • Contractors perform all manner of aircraft ground and flight operations including production, modification, repair, overhaul, and routine organic maintenance. • Two Defense Federal Acquisition Regulations come into play with contractor aircraft operations
GFRC/AFRC • The Ground and Flight Risk ClauseDFARS 252.228-7001 • Aircraft Flight Risk ClauseDFARS 252.228-7002 • Both clauses indemnify contractors from loss
GFRC/AFRC • Government’s assumption of risk comes at a price for contractors • Government requires contractors to develop safe and effective Procedures which the Government retains the authority to approve. • Procedures cover all aspects of operations including FOD and Tool Control
GFRC/AFRC Guidance DCMA INST 8210.1 Definitions and FAR/DFARS Reference Policies and Procedures approving authority GFR training delegating authority flight/ground operations verification of contractor compliance Appraisal Criteria for Contractor’s Procedures Contractor Flight and Ground Ops Surveys
DCMA INST 8210.1 • The contractor shall develop a Foreign Object Damage Prevention Program and procedures, which are planned, integrated, and developed in conjunction with Safety, Test, Quality, Maintenance, and Manufacturing offices.
DCMA INST 8210.1 • The program shall identify program goals and individuals/offices responsible for achieving them. • It should address operations such as sweeping of runways, taxiways, and run-up areas; and the process for prevention of FOD during engine test cell activities, flight line maintenance, launch, and recovery.
DCMA INST 8210.1 • It should stipulate the method of hardware and Tool Control and accountability, and include a requirement to report and investigate FOD incidents. Include a process to identify types of FOD and problem areas, develop and utilize trend data and provide corrective action to prevent recurrence.
DCMA INST 8210.1 • Specific FOD/Tool Control procedures shall address: • Control of hardware, expendable tools and supplies used in, on, and around the aircraft. • Control debris created during maintenance/manufacturing operations (AKA clean as you go). • Control of personal items.
DCMA INST 8210.1 • … • Positive control of all tools taken onboard or used around the aircraft. • Methods for establishing tool ownership. • Lost tool procedures. • Training.
Problems/Questions • When does the GFR’s authority come into play? • What authority does the GFR have? • What exactly does the GFRC/AFRC require? • What if I disagree with the GFR?
Deliverables… • Focus ideas • Identify key concerns • Remedies