47QSSC-25-R-3040_Redacted JOFOC.pdf

Subject: 47QSSC-25-R-3040

General Services Administration Facilities and Hardware Supply Chain Management Contracting Division

Justification and Approval for Other Than Full and Open Competition

47QSSC-25-R-3040

Security Containers Program

1. IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY:

The contracting activity is the General Services Administration, Facilities and Hardware Supply Chain Management Contracting Division, at 2300 Main Street, Kansas City, MO 64108.

The requesting activity is the Department of Defense (DoD) which has eight sponsoring agencies for the DoD Lock Program. The sponsoring agencies includes the following:

Commander Naval Installations Command (CNIC), Naval Facilities Engineering Command (NAVFAC), DoD Physical Security Equipment Action Group (PSEAG), United States Army, Defense Logistics Agency (DLA), Central Intelligence Agency (CIA), Directory of National Intelligence (DNI), and the General Services Administration (GSA). The DoD Lock Program is designated as the DoD technical authority for locks, safes, vaults, seals, and containers used to protect national security information (NSI) including arms, ammunition, and explosives (AA&E).

The authority for the GSA Security Equipment program was established in Executive Order (EO) 13526 – Classified National Security Information, Sec 5.1, Subparts A, B. This EO establishes the Information Security Oversight Office (ISOO) as the agency responsible for issuing directives related to safeguarding classified information. ISOO published the implementing directive in the Code of Federal Regulations (CFR), Title 32, Subtitle B, Chapter XX, Part 2001, Subpart E, Section 2001.42 and 2001.43 – Standards For Security Equipment. The CFR directive states:

§ 2001.42 Standards for security equipment.

(a) Storage. The Administrator of the General Services Administration (GSA) shall, in coordination with agency heads originating classified information, establish and publish uniform standards, specifications, qualified product lists or databases, and supply schedules for security equipment designed to provide secure storage for classified information. Whenever new secure storage equipment is procured, it shall be in conformance with the standards and specifications established by the Administrator of the GSA, and shall, to the maximum extent possible, be of the type available through the Federal Supply System. GSA, in its assigned role of coordinating with agency heads originating classified information, has established an Interagency Advisory Committee on QuSecurity Equipment (IACSE).

As a result, the Information Security Oversight Office (ISOO) issued a notice requiring federal agencies to purchase GSA Approved containers using National Stock Numbers through GSA Global Supply. Please see Procurement of Security Equipment ISOO Notice 2014-02 and Additional Guidance on Standards for Security Equipment ISOO Notice 2012-04 for more information. These notices are intended for a wide federal audience, to ensure consistency in the protection of classified material.

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GSA in complying with the CFR has developed performance Federal Specifications to establish the requirements for the GSA Approved security equipment that include operational and security requirements and testing by the DoD Lock Program Testing Laboratory (US Navy, NAVFAC/EXWC). The testing is very rigorous where manufacturers have their products evaluated and tested against those requirements and acceptable products are placed on a Qualified Products List (QPL) . Additionally, the Testing Laboratory conducts regular/recurring 1 quality assurance (QA) testing of all GSA approved equipment, maintains drawings, specifications, and library samples of all GSA approved equipment, and responds to all reported operational/security deficiencies in GSA approved equipment.

The Federal Specifications associated with every QPL allow for differences or tolerances in dimensions, internal parts, and operational characteristics for qualifying products. Therefore, all the Original Equipment Manufacturer (OEM) products placed on a QPL meet the Federal Specifications as required; however, that does not mean that every OEM product is exactly the same or interchangeable. For example, outer and inner dimensions may be unique to a certain OEM, as well as, shelving configurations (or other accessory components) and brackets used to adhere the containers to walls, ships, etc. Each OEMs product has a unique and mechanically different design and manufacturing process which includes specified bolts, framework, repair, maintenance, and unique configuration, exclusive to the manufacturer where parts such as nuts and bolts are not interchangeable among other brands.

2. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED:

As designated in the above ISOO guidance, procurement of security containers including vault doors and locks must go through GSA Global Supply. As a result, the Facilities and Hardware Supply Chain Management Contracting Division will put single award Indefinite Delivery Indefinite Quantity (IDIQ) contract vehicles in place (for every responsive and responsible QPL OEM) as identified in Federal Acquisition Regulation (FAR) Subpart 16.504 for five years (with a two year base and three - one year options). The Security Container Program is to be made up of approximately 1,032 brand name NSNs which are unique to the OEMs approved under each 2

QPL as listed below. Each NSN will have a single OEM. Awards will be made on an item-by-item (CLIN) basis; therefore, a single award will be made by NSN per CLIN to the brand name designated OEM.

1. Filing Cabinets – Federal Specification AA-F-358, Qualified Products List - QPL-AA-F-358

2. Cabinet, Security Information Processing AA-C-2786, Qualified Products List -

QPL-AA-C-2786

3. Cabinet, Map & Plan AA-F-363, Qualified Products List - QPL-AA-F-363

4. Vault Doors AA-D-600 (Class 5V & 5B), Qualified Products List - QPL-AA-D-600

5. Cabinets, Security, Weapons Storage AA-C-2859, Qualified Products List - QPL-AA-C-2859

2 It is expected that GSA Cataloging/Engineering will establish approximately 1,032 NSNs for the Security Container Program;

however, that number is subject to change until the project is complete. Once the number is finalized, if the number differs from 1,032, an addendum will be made to this J&A to clarify the actual number of NSNs that will be issued in the solicitation.

1 41 CFR § 101-29.207 Qualified products list (QPL). A qualified products list is a list of products that have met the qualification requirements stated in the applicable specification, including appropriate product identification and test or qualification reference number, with the name and plant address of the manufacturer and distributor, as applicable. Documents that contain QPL requirements are listed in the GSA “Index of Federal Specifications, Standards and Commercial Item Descriptions.” See also QPL defined in 9.203.

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In many instances General Services Administration and Interagency Advisory Committee on Security Equipment (GSA/IACSE) members require the ability to procure specific security equipment by brand name for multiple specific reasons, not all of which can be explained in this letter. Per Executive Order 13526, the protection of classified information is the responsibility of each agency head or senior agency official and per Federal Regulation 32 CFR 2001.42 (a), it is the responsibility of GSA to coordinate with these Agencies and Department officials (GSA/IACSE) who originate classified information to support this requirement from a procurement perspective.

Each CLIN will specify a particular brand name product peculiar to their specific manufacturers.

This document will demonstrate that the use of such descriptions is essential to the Government’s requirements; thereby each CLIN precludes consideration of products manufactured by any other company.

3. DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S

NEEDS (INCLUDING THE ESTIMATED VALUE):

Under the Security Container Program there are two classes of containers, Class 5 and Class 6 security containers. GSA maintains the Federal Specifications and the QPLs covering Security Filing Cabinets for storage of classified items. Per FAR 9.203, qualification and listings in a QPL is a process by which products are examined and tested for compliance with the Government’s specification requirements. The manufacturers listed on the QPL have demonstrated that their products meet the standards specified in the Government’s specifications. Generally, qualifications are approved in advance and independently of any specific acquisition action.

After qualification, the products, manufacturers, or potential offerors are included in a Federal or Military QPL.

Class 5 containers:

Class 5 containers are typically used for storage of classified information where there is a requirement for forced entry protection such as classified information located in high-risk locations and for the storage of weapons. Class 5 containers may also be used for storage of classified components, materials, and equipment. They provide the same protection as Class 6 containers plus ten minutes against forced entry attack. Class 5 containers come in several types: file cabinets, map and plan, weapon storage, and Information Processing System (IPS) containers. There are Class 5-W containers used solely for weapons storage. These containers are not intended to store classified materials.

See the catalog pages attached for the product details for Class 5 containers, including legacy NSNs, color options, and dimensions:

● Class 5 Filing Cabinets (for legal size 2 and 4-drawer)

● Class 5 Map and Plan General Purpose

● Class 5-W Weapons Containers

Class 6 Containers:

Class 6 containers are typically used for storage of classified information such as documents, Docusign Envelope ID: 8F -4Docusign Envelope ID: -Docusign Envelope ID: 98F15DB1-899E-48DC-877A-C94C5F2F1763 maps, drawings and plans to be used in lower risk facilities with Security-In-Depth (per 32 3

CFR 2001.43 (b), (C). They come in file cabinets and map and plan styles. There are Class 6-S containers which are specifically designed for installation and use aboard DoD ships to protect classified information.

See the catalog pages attached for product details for Class 6 containers, including legacy NSNs, color options, and dimensions:

● Class 6 Filing Cabinets (for legal and letter size 2, 4, or 5 drawer and special size 1 drawer)

● Class 6 General Purpose

● Class 6-S Shipboard Containers (for legal and Letter Size 2, 4, and 5 drawer filing cabinets)

All of the above, both classes 5 & 6, security containers meet one of the following relevant federal specifications:

● AA-F-358J – Filing Cabinet, Legal and Letter Size, Uninsulated, Security

● AA-F-363D – Filing Cabinet, Security, Maps and Plans, General Filing and

Storage

● AA-C-2859A – Cabinet, Security, Weapons Storage

● AA-D-600D – Door, Vault, Security

The DoD Lock Program’s website provides access to the Federal Specifications and Qualified 4

Products List for the latest version of the specifications which includes a link to ASSIST to view the QPLs. All specifications are available to the public. The assortment of security equipment within this requirement is considered commercial in nature.

The demand for the Security Container Program, including vault doors, over the three years is as follows (reviewing spend under NSNs* in Cognos by date range):

Year 1 Spend:

(April 1, 2022 - March 31, 2023

$25,232,648.01

Year 2 Spend:

(April 1, 2023 - March 31, 2024)

$30,894,868.93

Year 3 Spend:

(April 1, 2024 - March 31, 2025)

$34,748,358.77

Total Three Year Spend: $90,875,875.71 *Legacy NSNs were used to calculate these figures. IGCE report attached.

Due to the historically high demand of Security Container Program NSNs as demonstrated above, as well as the unpredictable nature of IDIQ contract vehicles, the estimated value of this

4 Dod Lock Program website: https://exwc.navfac.navy.mil/DoD-Lock-Program/

3 Security In Depth refers to a layered approach to security controls to deter, detect, delay, and deny unauthorized access or movement within a facility.

Docusign Envelope ID: 8F -4Docusign Envelope ID: -Docusign Envelope ID: 98F15DB1-899E-48DC-877A-C94C5F2F1763 new contract vehicle is being set at $300 million. Additional revenue considerations were given due to adding the vault door NSNs to the contract. If awarded, this would be the first year for the vault doors to be on a GSA contract; therefore, the expected revenue from those NSNs is unknown. The contract vehicle being established to fill this requirement is anticipated to be awarded on or after October 1, 2025 and will be in effect from November 1, 2025 to October 31, 2030, pending the exercise of all options.

4. IDENTIFICATION OF STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND

OPEN COMPETITION:

The authority for other than full and open competition for the acquisition for these supplies will be awarded pursuant to the authority of 41 United States Code (U.S.C.) 3304 as implemented by FAR 6.302-1(c)(1) and 11.105(a)(1). See below.

FAR 6.302-1(c)(1): Application for brand-name descriptions.

(1) An acquisition or portion of an acquisition that uses a brand-name description or other purchase description to specify a particular brand-name, product, or feature of a product, peculiar to one manufacturer—

(i) Does not provide for full and open competition, regardless of the number of sources solicited; and

(ii) Shall be justified and approved in accordance with 6.303 and 6.304.

(A) If only a portion of the acquisition is for a brand-name product or item peculiar to one manufacturer, the justification and approval is to cover only the portion of the acquisition which is brand-name or peculiar to one manufacturer. The justification should state it is covering only the portion of the acquisition which is brand-name or peculiar to one manufacturer, and the approval level requirements will then only apply to that portion;

(B) The justification should indicate that the use of such descriptions in the acquisition or portion of an acquisition is essential to the Government’s requirements, thereby precluding consideration of a product manufactured by another company; and

(C) The justification shall be posted with the solicitation (see 5.102(a)(6)).

FAR 11.105: Items peculiar to one manufacturer.

Agency requirements shall not be written so as to require a particular brand name, product, or a feature of a product, peculiar to one manufacturer, thereby precluding consideration of a product manufactured by another company, unless-

(a)(1) The particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs.

5. A DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE

AUTHORITY CITED:

IAW FAR 6.302-1(c)(1)(ii)(B), the use of brand name descriptions in this acquisition is essential to the Government’s requirements.

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The assigned DoD testing lab reviews the products annually, based on the lab’s discretion, testing is performed annually on selected items.

Additionally, a Request for Information (RFI) was posted to SAM.gov in January 2025 and will be discussed further under Item 8 below.

7. A DEMONSTRATION BY THE CONTRACTING OFFICER THAT ANTICIPATED COST TO

THE GOVERNMENT WILL BE FAIR AND REASONABLE:

Since competition for this requirement is restricted to brand name NSNs, the Government will be utilizing at least two (2) price analysis techniques outlined in FAR 15.404-1(b) by which to determine pricing submitted by offerors to be fair and reasonable. These techniques include, but are not limited to, the following:

I. Comparison of proposed prices received in response to the solicitation II. Comparison of the proposed prices to historical prices paid III. Comparison with competitive published price lists IV. Comparison of proposed prices with Independent Government cost estimates V. Comparison of proposed prices with prices obtained through market research for the same or similar items.

Certified cost or pricing data will not be required for submission as these items have been determined to be commercial.

Since fair opportunity is realized at the individual NSN level and multiple NSNs could be competitive for a particular order there’s opportunity for price competition at the QPL level. We intend to negotiate pricing at the time of solicitation with consideration to pricing being given during option periods.

8. A DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE RESULTS, OR

A STATEMENT OF THE REASON MARKET RESEARCH WAS NOT CONDUCTED:

Currently there are 216 GSA Approved Security Container ‘spec’ or generic National Stock Numbers (NSNs) awarded on 51 multiple award, open market, Blanket Purchase Agreements (BPAs). All BPAs have different contract numbers and are not total small business set-asides IAW FAR 19.502-5(c), partial set-asides IAW FAR 19.502-4(a)(3), or reserves IAW FAR 19.503(a); instead are award allocation percentage terms and conditions.

All BPAs have differing start dates, ending dates, ceilings, estimated values, and allocation percentages of award are also applied at the individual order level for all orders without further competition. These 216 NSNs do not include armory and vault doors. The BPAs are awarded to six Original Equipment Manufacturers (OEMs) listed on the Federal Qualified Products Lists (QPLs). The vault doors are currently being sold to GSA Customers by the OEMs/Contractors listed on the QPLs through GSA approved Direct Purchase Authority (DPA). After evaluation of the current procurement method it was determined that streamlining the number of contracts being administered and maximizing efficiency by eliminating manual processing of orders on the next contract would be paramount. Having multiple, single award IDIQ contracts allows for

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The RFI consisted of a questionnaire and a spreadsheet requesting information on the below topics. Both documents were requested to be returned for review and analysis.

● Confirmation of SAM registration

● Item Fulfillment Projection

● Schedule (MAS) Availability

● Schedule (MAS) Availability - for accessories

● Direct Purchase Authority

● Interest in being added to the QPL

● Mil-Std-129 Compliance

● Delivery Lead-time Compliance with GSA ON 16-02 (Operational Notice)

● Manufacturer Warranty

● Approved Carriers

● FOB Destination Pricing

● IT Components

● Buy American Act Compliance

● EDI or Vendor Portal Compliance

● Section 889 Part B Requirements

● Industry Day Interest

● General Comments

● Spreadsheet - Manufacturer Name, Manufacturer Part Number, Statement of Interest in

Quoting, Estimated Pricing (Destination), Country of Origin, Warranty Terms, Your Company’s Yearly Demand, Your Company’s Historical Yearly Demand, and General Comments.

Industry was encouraged to provide a reply for the Security Container Program RFI including vault doors and locks to help shape and form the solicitation. Based on submissions to the RFI there are three categories of product: 1) Security Containers 2) Vault Doors, and 3) Locks.

Based on submissions to the RFI under each of the three categories:

1) Security Containers - Three small businesses, two woman-owned small businesses, and one other than small business submitted information for review in regards to the RFI. All noted their interest in quoting for the next solicitation.

2) Vault Doors - One small business and one other than small business submitted information for review in regards to the RFI. Both noted their interest in quoting for the next solicitation.

3) Locks - Two other than small businesses submitted information for review in regards to the RFI. These are the only two lock manufacturers on GSA approved QPLs. Kaba Mas and S&G;

however, noted they do business through distributors.

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Both sets of industry meetings followed the same format where the first day included a GSA Acquisition Team presentation via slide deck to the OEMs in attendance followed by an open questions and answers session. Individual meetings were conducted with the OEMs in attendance on subsequent days.

This procurement will be awarded on an item-by-item basis and qualified vendors are eligible only if they are listed on the QPL noted for the NSN. As such, this procurement can not be a total set-aside IAW 19.502-5(c) as it states, “(c) …a total small business set-aside shall not be made if the list [QPL] contains the products of large businesses unless none of the large businesses desire to participate in the acquisition. As stated in the RFI responses, the large business in each category has provided an official response stating their interest in quoting.

Additionally, partial set-asides IAW FAR 19.502-3(c) and reserves IAW FAR 19.503 are not permitted for this requirement. The solicitation cannot be broken into distinct portions because all QPLs have an interested large business.

This requirement will be submitted IAW GSAM 519.502-70(e)(2) through the Small Business Administration (SBA) requesting Other Than Full and Open competition via the Office of Small and Disadvantaged Business Utilization (OSDBU) clearance form (GSA Form 2689) seeking approval by both the SBA Small Business Technical Advisor (SBTA) and the SBA Procurement Center Representative (PCR).

IAW FAR 9.203(a) Engineering issues Federal Specifications updates in the Assist Database system which is managed by DLA. When updates are made, registered QPL vendors and anyone who has registered in the system gets notification of the updates. Engineering also sends out communications to the QPL vendors as Federal Specifications are updated.

In addition, in previous procurements and current solicitation procurement, non-QPL approved vendors have shown interest quoting on QPL items. To date none of these vendors expressed interest in having their items tested to receive approval to be placed on the QPL.

9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION:

All facts supporting the use of other than full and open competition are stated above in sections 1-8.

10. A LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST

IN THE ACQUISITION:

All OEMs that responded to the RFI, found in the Section 8 chart of this document, have expressed an interest in this acquisition.

11. A STATEMENT OF ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR

OVERCOME BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION

FOR THE SUPPLIES OR SERVICES REQUIRED:

There are no restrictions for a manufacturer requesting their product be tested for placement on

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The IACSE committee re-issued a Final Ruling for the Security Container Program NSNs titled, “Sale of New GSA-Approved Containers” renewed on February 10, 2025. This document prohibits any OEM listed on any security container or vault door QPLs from selling through 3rd party distributors. As such, only the OEMs can quote and be evaluated for award. However, as discussed above, there are multiple OEM products that meet the requirements of the Federal Specification per QPL. This facilitates competition among OEMs listed on the QPL by allowing end-users to requisition for NSNs that best meet their requirements (i.e., price, warranty, delivery, configuration, etc.)

As the IACSE committee approves additional product specifications, this gives the existing OEMs on the QPL an opportunity to compete for new items, as well as encourage new entrants into the QPL program.

Ongoing efforts to increase competition will include the potential of adding “Onboarding” terms and conditions to future procurements including but not limited to a “Special Notice” on Sam.gov for additional exposure to the QPL program in the efforts to enhance manufacturer product testing. This is in addition to the Assist Database notifications mentioned above in Section 8.

12. CONTRACTING OFFICER’S CERTIFICATION:

This Justification for Other Than Full and Open Competition is accurate and complete to the best of the contracting officer’s knowledge and belief (FAR 6.303-2(1)(c)).

PREPARED BY:

Amanda B. Foley Contracting Officer

U.S. General Services Administration

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5/14/2025

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13. TECHNICAL REQUIREMENTS CERTIFICATION:

Evidence that any supporting data that is the responsibility of technical requirements personnel (e.g. verifying the Government’s minimum needs or schedule requirements or other rationale for other than full and open competition) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

The supporting data that I have provided which helped to form the basis for this justification is complete and accurate to the best of my knowledge.

Christopher Pollock Chairman Interagency Committee for Security Equipment (IACSE) General Services Administration 1800 F Street, NW Washington, DC 20405

Roy Jusino Chairman Security Equipment and Locking Systems (SEALS) Sub-committee

NAVFAC EXWC

1100 23RD Avenue Port Hueneme, CA 93043-4370

14. ADDITIONAL APPROVALS/REVIEWS:

Katie Norton Section Chief

Stephen Kinsella Branch Chief

5/14/2025

5/14/2025

5/15/2025

5/15/2025

Tyler Sikes Director

Reviewed by:

Michael Cullis Operation Guidance Branch Subject Matter Expert

James Van Biber Office of General Counsel

Janet Schweer Acting Competition Advocate

Concurrence by:

Jeffrey Lau Head of Contracting Activity (HCA) Assistant Commissioner, General Supplies and Services

5/15/2025

5/15/2025

5/15/2025

5/15/2025

5/19/2025

I have reviewed this contract action and I have determined to the best of my knowledge and belief, based on the information contained herein, that it complies with all applicable policies and regulations.

Mark Lee Office of Policy and Compliance Assistant Commissioner

15. SENIOR PROCUREMENT EXECUTIVE APPROVAL:

Jeffrey Koses Senior Procurement Executive

Enclosures:

Enclosure A: Executive Order (EO) 13526 – Classified National Security Information, Sec 5.1, Subparts A, B Enclosure B: ISOO Notice 2014-02 Enclosure C: ISOO Notice 2012-04 Enclosure D: Class 5 Filing Cabinets (for legal size 2 and 4-drawer) Enclosure E: Class 5 Map and Plan General Purpose Enclosure F: Class 5-W Weapons Containers Enclosure G: Class 6 Filing Cabinets (for legal and letter size 2, 4, or 5 drawer and special size 1 drawer) Enclosure H: Class 6 General Purpose Enclosure I: Class 6-S Shipboard Containers (for legal and Letter Size 2, 4, and 5 drawer filing cabinets) Enclosure J: Federal Specification: AA-F-358J – Filing Cabinet, Legal and Letter Size, Uninsulated, Security Enclosure K: Federal Specification: AA-D-600D – Door, Vault, Security Enclosure L: Federal Specification: AA-C-2859A – Cabinet, Security, Weapons Storage Enclosure M: Federal Specification: AA-F-363D – Filing Cabinet, Security, Maps and Plans, General Filing and Storage Enclosure N: Federal Specifications and Qualified Products List Website via DoDs Locks and Safe website

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5/27/2025

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5/30/2025

Certificate Of Completion Envelope Id: 08F0EE73-116D-4A70-B803-3E06AAE0E326 Status: Completed

Subject: Complete with Docusign: 47QSSC-25-R-3040_T04_(BN) Brand Name J&A (1).pdf

Source Envelope:

Document Pages: 15 Signatures: 10 Envelope Originator:

Certificate Pages: 5 Initials: 0 Amanda Foley

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Time Zone: (UTC) Dublin, Edinburgh, Lisbon, London

1800F F St NW

Washington DC, DC 20405 amanda.foley@gsa.gov

IP Address: 136.226.12.81

Record Tracking Status: Original

5/14/2025 10:01:05 PM

Holder: Amanda Foley amanda.foley@gsa.gov

Location: DocuSign

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Storage Appliance Status: Connected Pool: US General Services Administration Location: Docusign

Signer Events Signature Timestamp Amanda Foley amanda.foley@gsa.gov

Contract Specialist

US General Services Administration

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Christopher Pollock christopher.pollock@gsa.gov

US General Services Administration

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Roy Jusino roy.jusino.civ@us.navy.mil

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Katie L Norton katie.norton@gsa.gov

US General Services Administration

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Signer Events Signature Timestamp Stephen Kinsella

Steve.kinsella@gsa.gov

US General Services Administration

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Tyler Sikes tyler.sikes@gsa.gov

US General Services Administration

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Michael Cullis michael.cullis@gsa.gov

US General Services Administration

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James Van Biber james.vanbiber@gsa.gov

US General Services Administration

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JANET SCHWEER

janet.schweer@gsa.gov

Deputy Regional Commissioner

US General Services Administration

Security Level: Email, Account Authentication (None)

Signature Adoption: Drawn on Device

Using IP Address: 136.33.73.232

Sent: 5/15/2025 7:38:42 PM

Viewed: 5/15/2025 7:42:44 PM

Signed: 5/15/2025 7:43:59 PM

Electronic Record and Signature Disclosure:

Not Offered via Docusign

Jeff Lau jeffrey.lau@gsa.gov

Regional Commissioner, R2 FAS

US General Services Administration

Security Level: Email, Account Authentication (None)

Signature Adoption: Pre-selected Style

Using IP Address: 192.226.86.26

Sent: 5/19/2025 4:05:16 AM

Viewed: 5/19/2025 12:04:27 PM

Signed: 5/19/2025 12:30:21 PM

Electronic Record and Signature Disclosure:

Not Offered via Docusign

In Person Signer Events Signature Timestamp

Editor Delivery Events Status Timestamp

Agent Delivery Events Status Timestamp

Intermediary Delivery Events Status Timestamp

Certified Delivery Events Status Timestamp Wendy Johnston wendy.johnston@gsa.gov

GSS Chief of Staff

US General Services Administration

Security Level: Email, Account Authentication (None)

Using IP Address: 107.205.0.245

Sent: 5/15/2025 7:44:02 PM

Viewed: 5/19/2025 4:05:16 AM

Electronic Record and Signature Disclosure:

Not Offered via Docusign

Carbon Copy Events Status Timestamp

Witness Events Signature Timestamp

Notary Events Signature Timestamp

Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 5/14/2025 10:40:15 PM

Certified Delivered Security Checked 5/19/2025 12:04:27 PM

Signing Complete Security Checked 5/19/2025 12:30:21 PM

Completed Security Checked 5/19/2025 12:30:21 PM

Payment Events Status Timestamps

Electronic Record and Signature Disclosure

ESIGN DISCLOSURES AND CONSENT

It is required by law to provide you with certain disclosures and information about the products, services or accounts you may receive or access in connection with your relationship with us

('Required Information'). With your consent, we can deliver Required Information to you by a) displaying or delivering the Required Information electronically; and b) requesting that you print or download the Required Information and retain it for your records.

This notice contains important information that you are entitled to receive before you consent to electronic delivery of Required Information. Your consent also permits the general use of electronic records and electronic signatures in connection with the Required Information.

In accordance with the Electronic Signatures in Global and National Commerce Act (E-Sign

Act), I recognize that my eSignature (Electronic or Digital Signature) shall be given the same legal status as a signature made with a pen. I further recognize that the eSignature may not be denied legal effect, validity, or enforceability solely because it is in electronic form. I hereby consent to the use of eSignature.

After you have read this information, if you agree to receive Required Information from us electronically, and if you agree to the general use of electronic records and electronic signatures in connection with our relationship, please click the 'I ACCEPT' button below.

Statement of electronic disclosures:

You may request to receive Required Information on paper, but if you do not consent to electronic delivery of Required Information, we cannot proceed with the acceptance and processing to create a relationship with you in connection to the products, services or account.

If you consent to electronic delivery of Required Information, you may withdraw that consent at any time. However, if you withdraw your consent we will not be able to continue processing to create a relationship with you in connection to the products, services or account.

If you consent to electronic disclosures, that consent applies to all Required Information we give you or receive from you in connection with our relationship and the associated notices, disclosures, and other documents.

You agree to print out or download Required Information when we advise you to do so and keep it for your records. If you are unable to print or download any Required Information, you may call us and request paper copies. If you need to update your e-mail address or other contact information with us, you may do so by calling us and requesting the necessary updates.

If you wish to withdraw your consent to electronic disclosures, you may do so by calling us and requesting withdrawal of consent. After consenting to receive and deliver Required Information electronically, you may request a paper copy of the Required Information by calling us.

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Parties agreed to: Roy Jusino

If you do not have the required software and/or hardware, or if you do not wish to use electronic records and signatures for any other reason, you can request paper copies of the Required

Information to be sent to you by calling us.

Your consent does not mean that we must provide the Required Information electronically. We may to, at our option, deliver Required Information on paper. We may also require that certain communications from you be delivered to us on paper at a specified address.

I have read the information about the use of electronic records, disclosures, notices, and e--mail, and consent to the use of electronic records for the delivery of Required Information in connection with our relationship. I have been able to view this information using my computer and software. I have an account with an internet service provider, and I am able to send e-mail and receive e-mail with hyperlinks to websites and attached files. I also consent to the use of electronic records and electronic signatures in place of written documents and handwritten signatures.