0126--JA_(Redacted).pdf

Justification for Other than Full and Open Competition Department of Labor

Office of Procurement Services

(1) Identification of the agency and the contracting activity, and specific identification of the document as a Justification for Other than Full and Open Competition.

Contracting Activity Customer Agency U.S. Dept. of Labor U.S. Dept. of Labor Office of Procurement Services Mine Safety and Health Administration (MSHA)/ 200 Constitution Avenue Approval & Certification Center (A&CC) Room S4307 765 Technology Drive Washington, DC 20210 Triadelphia, WV 26059

(2) Nature and/or description of the action being approved.

This justification for other than full and open competition authorizes the issuance of an award for hardware (H/W) and software (S/W) maintenance and on-demand, onsite, technical support for the A&CC’s MSHA Imaging Management System (MIMS) (i.e.

electronic document management system) from the following source:

COMPUCOM, Inc.

1401 West Carson Street Pittsburgh, PA 15219 Phone: 800.270.8702 Fax: 412.261.2613 DUNS: 790763189 | CAGE Code: 1VVS3

(3) A description of the supplies or services required to meet the agency's needs (including the estimated value including all options).

a. Description – The MIMS imaging system includes imaging hardware components (e.g., optical jukebox, scanners, and support servers) and imaging software components (e.g., ApplicationXtender (AX) suite of products from EMC) that work and operate simultaneously to allow the components to be a single, cohesive “system”. This procurement is anticipated to establish a maintenance support agreement to support the MIMS. The maintenance package will include: (1) S/W license maintenance, (2) H/W maintenance, and (3) labor hours for technical support and assistance, hardware service calls, and special projects.

Services include but are not limited to the following:

i. S/W License Maintenance

1. Authorization by the S/W vendor to use their S/W products as long as the license is in effect.

2. On-demand CTR-provided technical consultation support services for Federal MIMS administrative and technical support staff to address issues and answer technical questions

3. On-demand, onsite H/W preventative maintenance service calls reserved for older, infrequently used MIMS-related equipment (further outlined below)

4. Special projects including data conversion, data migration, application migration, customized MIMS applications, and on-site training (further outlined below)

Examples of activities not covered under the H/W preventative maintenance agreement and anticipated to be fulfilled utilizing the labor hours include:

1. Special projects including data conversion, data migration, application migration, customized MIMS applications, and on-site training (further outlined below)

2. Assistance recovering from optical write errors experienced on the Plasmon M20-J jukebox, which has reached its end of lifecycle.

3. Assistance with hardware migration from the Plasmon M20-J optical jukebox to the Plasmon G24 optical jukebox.

4. Assistance with the data migration from the Plasmon M20-J optical jukebox to the Plasmon G24 optical jukebox.

5. Assistance with the upgrade of AX 6.5 to release 7.0.

6. Assistance with the indexing of engineering drawings converted from aperture cards.

7. Assistance with the conversion of hardcopy historical records (master approval number; master investigative numbers; master approval holders; master company history) to a pdf format.

Examples of special projects for which labor hours are anticipated to be utilized include:

1. Older technology formerly utilized at the A&CC (e.g., aperture cards) is becoming degraded and also is not supported under newer network software (i.e. as part of the A&CC’s efforts to become “paperless”).

Replacing this equipment was determined to be cost prohibitive and not offer an acceptable return on investment – therefore the A&CC determined to “X-cess” this obsolete H/W. Labor hours were used to transfer/digitize the data from aperture cards to digital media as an alternative; thus negating the need for an aperture card reader. It is anticipated a portion of the block of labor hours procured for this requirement will be utilized to complete the transfer of data (i.e.

loading the aperture cards) into the MIMS imaging system.

2. A project to transfer master approval number records from index cards to digital media was started this past year but was not completed due to insufficient labor hours remaining in the block of hours available on the current purchase order. It is again anticipated a portion of the block of labor hours procured for this requirement will be utilized to complete this additional transfer project

3. An additional project was begun to transfer historical testing and inspection photographs from hardcopy into the MIMS imaging system.

These photos were converted to electronic format and it is anticipated a portion of the block of labor hours procured for this requirement will be utilized to continue the next phase of this project which involves auto-loading and indexing the photographs in the MIMS imaging system.

4. Finally, a project was begun to auto-load and index billing documentation into the MIMS imaging system. It is anticipated a portion of the block of labor hours procured for this requirement will be utilized to complete this project.

b. Estimated Value – the estimated value of this procurement is approximately covering an anticipated base plus two option periods.

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is found at 10 U.S.C.

2304(c)(1) or 41 U.S.C. 3304(a)(1) IAW FAR 6.302-1 – Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

(5) A demonstration that the proposed contractor's unique qualifications or, the nature of the acquisition, requires use of the authority cited.

The rationale for selecting COMPUCOM, Inc. as the sole source for the H/W and S/W maintenance and on-demand, onsite, technical support is demonstrated by the following:

a. As a part of the government-wide initiative to move hardcopy documents to electronic format, examples of support projects consisting of nonseverable deliverables wherein COMPUCOM is assisting the A&CC in streamlining processes and reducing costs include:

Converting an extensive library of engineering drawings from aperture cards to pdf format wherein COMPUCOM created an offline index (i.e. Excel file) of the converted data and included a “pointer” to an image with a link to open that file. This index is anticipated to improve the speed at which these drawings are retrieved and distributed as well as eliminate the need for the aperture card reader/printer itself. An AX application is being designed by COMPUCOM to move these pdf files onto the imaging system for permanent storage.

Scanning historical hardcopy records of legacy drawings and master approval number files for eventual inclusion in the imaging system. These are now available in an offline staging area that COMPUCOM is scheduled to add to the imaging system for permanent storage. This is anticipated to make research and retrieval more efficient. Once the scanned documents are added to the imaging system, the physical filing cabinets will be removed from the A&CC’s workspaces and free up much needed floor space at the A&CC.

Converting historical product approval test photos to pdf format.

COMPUCOM is currently supporting a project currently underway to auto-import these historical product approval test photos into the imaging system for inclusion with the associated approval documentation. This is anticipated to make the test photos available to everyone from their desktops.

COMPUCOM is also designing an AX application to automate the importing of the A&CC product approval and audit invoices. This will eliminate the manual process in use today and will free up time for more critical approval administration tasks.

b. The MIMS system is mission critical and requires robust support. MIMS supports

MSHA’s product approval activities, mine inspector assistance, and accident investigation work. The system houses manufacturers’ engineering drawings, formulations, and other proprietary information, as well as MSHA-generated product approval documentation. This is a production system that supports all of the engineers and technicians – approximately % of the total amount of personnel working at the A&CC ( total) – who utilize the system at the A&CC in their daily work. COMPUCOM’s in-depth knowledge of the system hardware, as well as the structure of the imaging database and its document content, is integral to the daily operations of the A&CC. Switching to another CTR at this point in time requires extensive planning and preparation by the A&CC staff in order for the engineers and technicians to prepare for offline operations during any anticipated transition period (i.e. pulling necessary data from the MIMS needed for daily operations prior to downtime in order to access the information as needed). It is anticipated that even a

% reduction in the daily mission-capability of the MIMS runs the risk of causing serious disruption to the A&CC’s daily mission; i.e. system downtime is not an acceptable state of operations for the A&CC. Disruptive impacts of MIMS downtime include:

Approval Applications: The data housed in MIMS is required by the A&CC engineers in order for them to evaluate new product approval applications. If MIMS is not available, the approval process is directly impacted, causing delays in turnaround. The A&CC approval turnaround times are reported to Congress.

Mine Inspections: Mine inspectors routinely call the A&CC from the field for verification or clarification of approval specifications for products they have found in the mines. Without access to MIMS, A&CC personnel cannot provide this critical information to the inspectors, thus possibly allowing non-approved, dangerous equipment to remain in the mine.

Accident Investigations: The data housed in MIMS is used to evaluate equipment found at accident scenes. This data supports the efforts of the

Accident Investigation Team, the affected MSHA Districts, and the A&CC QA&MTD personnel. These investigations have very high visibility, and any negative impacts to the investigation efforts must be explained to internal management and sometimes to the general public.

(6) A description of the efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was, or will be, publicized as required by FAR Subpart 5.2 and, if not, which exception under Subpart

5.202 applies.

Market Research included requests for information from the following sources in order to determine the extent of the potential sources pool to fulfil this requirement – eBuy (x2) – Schedule 70 and FSSI BPA Holders FBO.gov (x2) – under NAICS codes 541519 and 518210 NASA SEWP V GWAC – Group B (SDVOSB), Group B (HUB-Zone), Group C

(Small), & Group D (Full and Open) NIH NITAAC GWAC (x2) – CIO-CS and CIO-SP3 IDIQ contracts

A notice will not be publicized as required by FAR Subpart 5.2 IAW the exception found at FAR 5.202(a)(13). As this requirement is over , a sole source announcement will be issued with the solicitation when released via FBO.gov.

(7) A determination by the Contracting Officer that the anticipated cost to the

Government will be fair and reasonable.

Historical contract pricing is available for this requirement from previously awarded Purchase Orders for the same/similar requirement(s) dating from FY 2007 to FY 2015. The contract pricing for these awards was deemed fair and reasonable by the signing CO at the time of their award. The current CO has determined it appropriate to use the historical pricing information available for this requirement, as well as the price analysis techniques at 15.404-1, to determine fair and reasonable pricing and price realism for the anticipated contract.

(8) A description of the market research conducted (see FAR Part 10) and the results or, a statement of the reason(s) market research was not conducted.

Market Research included requests for information from the following sources in order to determine the extent of the potential sources pool to fulfill this requirement – eBuy (x2) – Schedule 70 and FSSI BPA Holders FBO.gov (x2) – under NAICS codes 541519 and 518210 NASA SEWP V GWAC – Group B (SDVOSB), Group B (HUB-Zone), Group C

(Small), & Group D (Full and Open) NIH NITAAC GWAC (x2) – CIO-CS and CIO-SP3 IDIQ contracts hardcopy documents to electronic format (e.g., PDF). Any transition by the A&CC to a new CTR will require extensive planning and preparation by the A&CC staff in order for the engineers, technicians, and other “heads-down” daily users of the MIMS to adequately prepare for offline operations during any anticipated transition period (i.e. pulling necessary data from the MIMS needed for daily operations prior to downtime in order to access the information as needed). Again, it is anticipated that even a reduction in the daily mission-capability of the MIMS runs the risk of causing serious disruption to the A&CC’s daily mission.