AMCOM Spares SAR Guidance.docx

Source Approval Request (SAR) Preparation & Submittal Guidance For Restricted Source AMCOM Spare Parts Manufacturers and Distributors

Photo Courtesy of the U.S. Army

TABLE OF CONTENTS

1.0 The AMCOM Spares SAR Process

1.2 Preparing and Submitting a SAR Package

1.3 What Happens After SAR Submission

1.4 Helpful Suggestions for SAR Preparation

2.0 Detailed Manufacturer SAR Preparation Guidance for Parts Manufacturers

2.1 Determining Who Manages the Part

2.2 Determining Whether You Need a SAR

2.3 Determining the SAR Documentation You Must Submit With a SAR Package

2.4 SAR Category Definitions

2.5 SAR Documentation Descriptions and Guidance

3.0 Distributor SAR Guidance for Non-manufacturers

4.0 Obtaining Government Technical Data

5.0 Non-Disclosure Agreement Recommendation

6.0 Appendices

A. General Notes

B. QE-STD-1

C. CAST-STD-1

D. FORG-STD-1

E. TEST-STD-1

F. SARs for FAA/PMA Parts G. Distribution Statements for Technical Documents

H. SAR TYPES

I. Acquisition Method Reason Code (AMRC) Definitions J. Repair Parts Purchase or Borrow (RPPOB) Program

1.0 The AMCOM Spares SAR Process

1.2 Preparing and Submitting a SAR Package (follow Steps 1 through 4 below)

STEP 1 - Prospective manufacturers should first verify the following: 1) That the part they are considering submitting a SAR for is actually an AMCOM managed part (see Section 2.1 Determining Who Manages a Part) and 2) That the part actually requires a SAR submittal (see Section 2.2 Determining Whether You Need a SAR). Parts which are not “restricted source” parts do not require a SAR.

STEP 2 - Once you have confirmed that a SAR is required, e-mail the SD SAR Team (usarmy.redstone.devcom-avmc.mbx.amr-ss-sar@army.mil) a signed letter, on company letterhead, requesting to submit a SAR for a specific part. Non-manufacturers (Distributors) see Section 3.0, Distributor SAR Guidance for Non-manufacturers. The SAR request letter (also referred to in this document as a cover letter) must include:

· The Part Number (and dash number, if applicable), NSN, and nomenclature

· Your firm's name, address, CAGE Code, telephone number, and FAX number

· A description of your quality program (i.e., MIL-I-45208, MIL-Q-9858, ISO-9000, etc.) to include copies of the quality program certifications (if applicable)

· A synopsis outlining your firm's manufacturing capabilities, facilities, experience, and equipment.

· A knowledgeable point of contact, their job title, E-mail, and telephone number

· Signed and dated

Click on the icon below to see an example cover letter. You can use this as a guide or template and customize it to your specific situation.

The Army will evaluate its current and projected needs for the specific part and you will be notified of the additional information needed to review your SAR (note: submit only one part number for each SAR request).

STEP 3 – If your request to submit a SAR is approved, then prepare the SAR package in accordance with Section 2.0 Detailed Manufacturer SAR Preparation Guidance for Parts Manufacturers (Distributors use Section 3.0, Distributor SAR Guidance for Non-manufacturers).

STEP 4 - Submit the completed SAR package to the SD for review.

** The preferred and most expeditious method of SAR document submittal is through secure electronic file submission (PDF format ) via the Web. **

For instructions on submitting your SAR documents securely, via the web, click on the icon below:

1.3 What Happens After SAR Submission

After your company’s letter requesting to submit a SAR (for a specific part) has been approved, you will be requested to send the SAR package, in its entirety, to the SD. Once received by the SD, the SAR package will first be logged into the SRD SAR database. SARs will be processed in accordance with other competing requirements and workload constraints. Processing time for SAR packages varies greatly and is dependent on many variables such as SAR complexity, vendor response time, competing priorities, workload constraints, and testing requirements. Due to time constraints and lead times involved, the Government cannot guarantee expedited processing of SARs submitted in response to a solicitation announcement in the SAM.beta.gov. Once a solicitation appears in the SAM.beta.gov, it is very unlikely that there is enough time to process a SAR for the current solicitation. Pursuant to Federal Acquisition Regulations (FAR) 9.202(e) - The contracting officer need not delay a proposed award in order to provide a potential offeror with an opportunity to demonstrate its ability to meet the standards specified for qualification. In addition, when approved by the head of an agency or designee, a procurement need not be delayed in order to comply with 9.202(a).

During the SRD review of a prospective vendor’s SAR package, corrections and updates to deficient documentation will be requested as required. Any missing documentation will also be identified and requested. The vendor is responsible for providing all of the requested documentation within 60 days after notification. Failure to provide the requested documentation, within the specified timeframe, may result in closure of the SAR. If there is any testing required, all testing must be completed by the prospective vendor, and the results approved by the SRD. Once the SAR is approved, the vendor (and their CAGE) will be added as an AMCOM approved source for the specific part number and NSN and they will be notified of their approval status. However, source approval only grants sources the opportunity to compete for procurement of the specific part; it does not guarantee award of a contract. Should the approved source be awarded a contract, updated manufacturing planning, which includes the current revision of the drawing and STDPs, may be required in accordance with contract requirements.

1.4 Helpful Suggestions for SAR Preparation

A. This document contains guidance for submission of Manufacturer SARs and Distributor SARs. Note: Novation and M&O (Maintenance and Overhaul) SARs are not covered in this guidance but can be found under separate guidance at https://www.avmc.army.mil/Directorates/SRD/SAR/. A description of the AMCOM SAR types is contained in Appendix H.

B. Click on the icon below and make sure to consider the following key points during SAR document preparation:

2.0 Detailed Manufacturer SAR Preparation Guidance for Parts Manufacturers

Note: This section is for parts Manufacturers. If you are a Distributor (non-manufacturer) see Section 3.0 SAR Guidance for Distributors (Non-manufacturers).

2.3 Determining the SAR Documentation You Must Submit With a Manufacturer SAR Package

In order to determine the required documentation that must be submitted with a Manufacturer SAR package, first determine the appropriate SAR category for a specific part using Table 2.0 below. There are four possible source approval categories from which to select (CATEGORY 1 through CATEGORY 4). Choose the category which accurately describes the part for which you wish to become an approved source. A detailed description of each SAR category is provided in Section 2.5 below. Once you have determined the appropriate SAR category, use Table 2.1 to determine the mandatory documents which must be submitted. During review of the SAR package, the SRD will verify that the correct SAR category was selected and that all mandatory documents have been submitted. If an incomplete SAR is submitted, you will be notified by letter and will be given 60 days to respond. If the remainder of the mandatory documentation requested is not received within 60 days, the SAR may be closed.

Table 2.0 Manufacturer SAR Category Determination

REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK

Table 2.1 Manufacturer SAR Documentation Required

If required, you may request assistance in determining the proper Manufacturer SAR category for a part by e-mailing usarmy.redstone.devcom-avmc.mbx.amr-ss-sar@army.mil.

2.4 Manufacturer SAR Category Definitions

The following paragraphs define, and provide detailed information, for each of the four Manufacturer SAR categories listed in Table 2.0 and Table 2.1.

A. CATEGORY 1 – Actual Part Manufacturer: You are the actual manufacturer of a part which you presently manufacture, or have satisfactorily manufactured in production quantities, in the last three years for: the Original Equipment Manufacturer (OEM), one of its subcontractors, another Department of Defense (DOD) agency, or a civil sector under FAA PMA Identicality; where FAA PMA Identicality does not apply to CSI parts (formerly referred to as Flight Safety Parts (FSP), see Appendix 6.F for more information on FAA/PMA parts). You have legal data rights to possess all of the OEM's Technical Data Package for the Actual Part.

The SRD will evaluate the part’s design, qualification, durability, and fatigue/life limiting factors and determine the extent of qualification testing that may be required. When applicable, testing will be used to verify that the part produced by the prospective new source will provide equal or greater life and performance as compared to OEM parts currently operating in the field. Test results submitted to the SRD for approval must include resubmission of all Table 2.1 documentation that was updated to reflect the part’s final post-test configuration.

B. CATEGORY 2 – Similar Part Manufacturer: You have not previously manufactured the actual part, however, in the last three years, you are the manufacturer of a similar part(s) for: the Original Equipment Manufacturer (OEM), one of its subcontractors, another Department of Defense (DOD) agency, or a civil sector under FAA PMA Identicality; where FAA PMA Identicality does not apply to CSI Parts (formerly referred to as Flight Safety Parts (FSP), see Appendix 6.F for more information on FAA/PMA parts). You have legal data rights to possess all of the OEM's Technical Data Package for the Actual Part. You will need to substantiate your manufacturing capabilities, or verify that you have manufactured production quantities of acceptable similar parts. It is acceptable to submit multiple similar parts to substantiate manufacture by similarity, since a single part may not be sufficient. Similar part(s) must be similar in complexity, design, criticality, materials, and application. In order to prove similarity, a detailed comparative analysis of the differences and similarities between the similar part(s) and the actual part is required. This analysis should include materials, configuration, tolerances, processes, testing, part function, dimensions, etc. The SRD will determine if similarity is applicable based upon evaluation of the SAR. (Figure 2.5 Example Detailed Comparative Analysis of Actual vs. Similar Part).

The SRD will evaluate the part’s design, qualification, durability, and fatigue/life limiting factors and determine if qualification testing is required. When required, testing will be used to verify that the part produced by the prospective new source will provide equal or greater life and performance as compared to OEM parts currently operating in the field. Test results submitted to the SRD for approval must include resubmission of all Table 2.1 documentation that was updated to reflect the part’s final post-test configuration.

C. CATEGORY 3 – New Manufacturer of a Part: You are a new manufacturer, or new prospective source, which does not meet Category 1 or 2 criteria, but legally possesses the OEM’s technical data and intends to manufacture the part using the AMCOM approved technical data package. The SRD will determine if the SAR adequately describes all essential manufacturing processes required to produce the part. This includes, but is not limited to:

1) The prospective supplier’s capabilities to perform and/or control the processes needed to produce the part (e.g., equipment lists, qualified subcontractors, and qualified personnel).

2) The prospective supplier’s ability to produce the parts with acceptable quality and demonstrate the ability to produce the part to specifications without compromise of the design intent.

The SRD will evaluate the part’s design, qualification, durability, and fatigue/life limiting factors and determine the extent of qualification testing that may be required. When applicable, testing will be used to verify that the part produced by the prospective new source will provide equal or greater life and performance as compared to OEM parts currently operating in the field. Test results submitted to the SRD for approval must include resubmission of all Table 2.1 documentation that was updated to reflect the part’s final post-test configuration.

D. CATEGORY 4 – Alternate Part Manufacturer (Reverse Engineering): In this case, you are a manufacturer who does not meet Category 1, 2, or 3 criteria, do not possess all of the Original Equipment Manufacturer’s (OEM) technical data, and wish to reverse engineer the part at your own expense. Reverse engineering is the process of replicating a part, functionally and dimensionally, by physically examining and measuring already existing parts to develop the technical data (physical and material characteristics) required for competitive procurement. For some parts, it may be possible to borrow an existing part from the Government to support the reverse engineering effort (see Appendix J - Repair Parts Purchase or Borrow (RPPOB) Program. Reverse engineering is only allowed for Non-CSI parts. A manufacturer’s SAR, for a Category 4 part, will not be approved until after successful completion of all required testing. Only after successful completion of all testing (as determined by the SRD), will the manufacturer be allowed to bid on solicitations for the respective part. Note: Your reverse engineering activity may be illegal if you have, or have had access to, any proprietary data for which you do not have adequate legal rights and which would aid reverse engineering, manufacture, or testing of the part.

1) Test Requirements for Category 4 (Reverse Engineered) Parts: Category 4 parts are parts for which AMCOM does not possess sufficient technical data, or data rights, to create a competitive Spares Technical Data Package (STDP) and for which you do not have sufficient data rights for direct sales to the Government, or sufficient data rights to manufacture and test to OEM specifications. In this case, the manufacturer must achieve source approval through demonstrated engineering and manufacturing capabilities (engineering testing), which includes successful manufacture and testing of the part, prior to a contract award. FAA PMA parts approved under “test & computation” fall under this category since the new design must be verified. When a part is developed through reverse engineering, a new part number and/or NSN may be required.

a. As a potential new source, you will demonstrate, prior to becoming approved as a source, that you and your vendors, subcontractors, etc., have adequate engineering expertise and manufacturing/production capabilities to successfully manufacture, inspect, and test the component or part in accordance with all applicable drawings, process specifications, and test specifications. The Government may require inspection of these elements on site. Your entire reverse engineering effort, including all testing, must generally be accomplished at your expense.

b. The vendor must prepare and submit, for SRD review, comment, and approval, a test plan with accept/reject criteria as well as all documentation listed in Table 2.1 (i.e. drawings, manufacturing planning, Reverse Engineering Management Planning, etc.). Once approval is given by the SRD, testing can be performed. The testing will be used to verify that the part produced by the prospective new source will provide equal or greater life and performance as compared to OEM parts currently operating in the field. Testing may include form, fit, and function checks, endurance testing, and/or performance testing, and may require destructively testing and evaluating each part. When required, you must provide the SRD samples of the part (manufactured at your expense).

c. Upon completion of testing, the SRD must be in possession of sufficient data, or be provided sufficient data, to perform a detailed risk assessment on the reverse engineered design. Prior to source approval, The SRD may also require resubmission of Table 2.1 documentation in order to verify that the documentation has been properly updated to reflect the part’s final post-test configuration.

2) Reverse Engineering Management Planning:. A reverse engineered part must have the same form, fit, and function as the original part. The SAR submission must include Reverse Engineering Management Planning which describes the approach used to develop all applicable drawings, process specifications, and test specifications. The planning must describe all aspects of the proposed reverse engineered design, to include:

a. Materials, critical characteristics, critical inspection processes, and critical manufacturing processes and how these were derived.

b. All detailed information about creation of the drawings and the methods used to reverse engineer the part (i.e. what tools were used to determine dimensions, materials, and manufacturing processes) must be submitted for review, comment, and approval prior to any manufacturing.

c. Photographs should be taken of the individual parts with the part number visible (whenever possible) and submitted with the vendor’s Reverse Engineering Management Plan/SAR.

2.5 - Manufacturer SAR Documentation Descriptions and Guidance

The following is a description of the documentation requirements listed in Table 3.0 - SAR DOCUMENTATION REQUIRED FOR AMCOM SPARES MANUFACTURING CATEGORIES. The following requirements do not apply to every category; so refer to Table 3.0 to determine which apply for a specific category.

A. Table of Contents: Provide a listing of your submitted SAR package documents as required by Table 2.1. This will assist the SRD in making certain that all of your documents are accounted for and entered into our database.

B. Cover Letter: Provide a cover letter stating that you wish to become an approved source under the appropriate Category (see Table 2.0) for a particular part number. The letter should include:

1) The Part Number (and dash number, if applicable), NSN, and nomenclature

2) Your firm's name, address, CAGE Code, telephone number, and FAX number

3) A description of your quality program (i.e., MIL-I-45208, MIL-Q-9858, ISO-9000, etc.) to include copies of the quality program certifications (if applicable)

4) Point of contact, their job title, E-mail, and telephone number

5) Quality Manual (as an attachment): Provide a current copy of your quality control manual must be submitted initially (pdf file format is preferred); subsequently, if any major changes occur, a current quality control manual should be resubmitted

6) Company Brochures (as an attachment): Brochures should be sent with first SAR submission only. These should include a synopsis outlining your firm's capabilities, facilities, experience, and equipment list. All equipment used in the manufacture of the actual part, with accuracy, size, capability, and precision of the outlined equipment. If any major changes occur in your firm's capabilities, facilities, experience, or equipment list, submit the changes or the new brochure

C. Actual Part TDP (Technical Data Package): Provide a complete and current copy of the technical data package required to manufacture the part. Note: Some technical data might be available through the Government’s EDMS system (see Section 4.0 Obtaining Government Technical Data).

1) The Technical Data Package for a part includes, but is not limited to, the following documentation:

a. Drawings: Provide copies of drawings, Spares Technical Data Package (STDP), Source of Supply (SS) drawings/documents, Parts List (PL), etc., for the part’s most current configuration. Note: Not all parts will have all of these document types.

b. Specifications: Provide copies of the top sheet of all applicable specifications necessary to completely manufacture the actual (OEM) part (SAE, AMS, MIL Standards, NAS, MS, NASM documents, etc.). Also provide a full copy of any of your company’s internal specifications (i.e. specifications created and controlled by your company) that are referenced in the part’s manufacturing planning (traveler, operations sheets, inspection sheets, technique sheets, etc.).

D. Actual Part Detailed Manufacturing Planning – Provide a copy of your manufacturing panning for the part. For the purpose of this guidance, the term “manufacturing planning” is the complete set of technical documents, utilized by a vendor’s manufacturing and inspection personnel, to completely produce a part or assembly. Review of a part’s manufacturing planning is required for source approval. In addition, a key component of the manufacturing planning is the part’s “manufacturing process plan”, referred to in this guidance as the “manufacturing plan.”

1) Manufacturing planning for a part includes, but is not limited to, the following documentation:

a. Manufacturing Plan: A part’s manufacturing process plan (i.e. traveler, router, shop order, work instruction, operations sheet, process sheet, etc.) is referred to as the “manufacturing plan.” A part’s manufacturing plan is a key component of the part’s “manufacturing planning” documentation and must contain all manufacturing and inspection processes in a step-by-step sequence. For detailed manufacturing plan requirements, see Section 2.6.D.2 Detailed manufacturing plan requirements.

b. Technique Sheets or Process Control Documents: Provides detailed information for in-house processes such as heat treat, shot peen, magnetic particle inspection (MPI), fluorescent particle inspection (FPI), etc.

c. Inspection sheets or quality control verification sheets: Inspection documentation associated with the part’s manufacturing process.

d. Subcontractor manufacturing plan: When applicable (such as for CSI subcomponents with CC’s), (i.e. traveler, router, shop order, work instruction, process sheet). This could apply to Magnetic Particle Inspection (MPI), Fluorescent Particle Inspection (FPI), hat treat, shot peen, etc.

e. Sketches, photographs, and/or charts: When applicable, the submitted planning should include sketches, photographs, and/or charts to increase clarity.

f. Bill of Material (BOM) or Parts List (PL) must be current, complete, and accurate and identify all proposed vendors of restricted source subcomponents (for an assembly). The BOM could be in the form of a separate Approved Vendor List (AVL) or equivalent documentation. Additional traceability and document control data demonstrating how the manufacturer controls their suppliers may be required during the SRD planning review. All proposed suppliers of restricted source subcomponents must be AMCOM approved.

g. Castings and Forgings: If a part requires a casting or forging, the casting or forging must be obtained from an AMCOM approved source. Approved sources are specified in the appropriate STDP. If an additional source wishes to be approved, it must be done in accordance with FORG-STD-1 for forgings or in accordance with CAST-STD-1 for castings. This qualification must be completed prior to contract award. (See Appendix C. CAST-STD-1 and Appendix D. FORG-STD-1).

h. Spiral Bevel Gears: Spiral bevel gears require that sources must have in their possession the required working and silver control master gears necessary for acceptance of production spiral bevel gears, or written documentation giving them access to those master gears. Development of "equivalent" master gears that are not coordinated/calibrated to the golden master gear held by the prime contractor is not allowed. This is necessary to ensure interchangeability with all mating gears.

i. Acceptance Test Plan (ATP): If an acceptance test plan is used in the manufacture of the part, this must be provided along with any other documents referenced in the ATP.

2) Manufacturing Plan detailed requirements: The manufacturing plan (i.e. traveler/shop router, etc.) must contain all manufacturing and inspection processes in a step-by-step sequence. This must be the actual documentation used by the company’s manufacturing and inspection personnel during the production of the part.

a. To see a summary of the key items looked for during SRD’s manufacturing plan review, click on the icon below:

b.

To see an example of a CSI or Non-CSI manufacturing plan, click either of the icons below:

3) The manufacturing plan must have the company’s name, address, and CAGE code at the top of the first page (preferably every page), as well as revision identifier with revision date. There must be enough space to allow the inspection personnel to record the dimensions, serial numbers, and/or any other applicable information such as acceptability limits, special instructions, inspection tooling, frequency, and the inspector’s stamp. Your plan must clearly show which parts are being manufactured in-house and which are being purchased, including from whom the parts will be purchased. Processes performed by outside vendors must be clearly identified. Also, for purchased subcomponents, or outside processes, the vendor must be identified in the applicable operational steps by Name, address, and CAGE code.

4) The manufacturing plan must provide a complete description of all manufacturing processes, materials, tolerances, testing, part function, overall dimensions, and detailed inspection criteria utilized to manufacture the part. The plan must also provide clear definition of operating parameters with tolerances of any processes not verified by subsequent non-destructive inspection, such as:

a. Exposures to heat, such as stress relief, hydrogen embrittlement bake relief, use of heat lamps, drying ovens, etc. shall be identified in separate operational steps.

b. Surface treatments, such as shot peening, plating, painting, etc. shall also be identified in separate operational steps.

c. De-burring and breaking sharp edges shall be identified in separate operational steps.

5) Processes that require unique “process/technique” sheets shall reflect the requirements in the applicable process specifications. For example, stating "shot peening per SAE AMS 2430" is not considered a detailed procedure and shall be further elaborated upon with process/technique sheets showing set-up and control requirements.

6) The plan shall identify, where applicable, the revision(s) of the Spares Technical Data Packages (STDP), engineering drawing(s), parts list(s), and any Engineering Orders or Advanced Drawing Change Notices, etc. used in its generation.

7) Documentation from the subcontractor(s) must be included which indicates a willingness to perform the identified tasks. This information is required for the actual part and, if you apply under Category 2 (similarity), it is also required for the similar part.

8) For all serialized items, in-process and final inspections must be traceable to specific serial numbers (S/N). The inspection sheets/plans/ records etc., must contain sufficient space to accommodate the necessary serial numbers.

9) Manufacturing plans for parts that are classified as CSIs must also include the following:

a. For parts that are CSIs, the top page of the manufacturing plan must provide a statement very similar to, and containing all key elements of, the following example statement: “This part is a Critical Safety Item (CSI) manufactured in accordance with QE-STD-1. Critical Characteristics (CC) must be 100% inspected and AMCOM/Engineering Support Activity (ESA) approval must be granted prior to implementing any change that would affect a Critical Characteristic.” Although it is required that you place this statement on the first page of your plan, it is preferred that you provide this statement on all pages. This statement is also required on any subcontractor planning that affects a Critical Characteristic (CC). (See Appendix B. QE-STD-1).

b. Clear identification within the plan of all CCs so as to draw attention to them (i.e. <<C>>, **CC**, , etc.) and a statement requiring 100% inspection of all CCs.

c. A location on the manufacturing plan to document the measured/inspected value of each CC by S/N; e.g., hardness, critical dimension, torque, and the S/N of tool, machine, or fixture used must be included. If CCs are recorded on separate inspection method sheets, those sheets shall be included with the planning and conform to all CSI (formerly referred to as Flight Safety Parts) planning requirements.

d. Subcontractors performing CSI critical characteristic processes must be AMCOM approved sources. In addition, the source of any subcontracted special process (i.e. Heat Treat, Shot Peening, Cad Plating, etc.) that affects a CC must be identified by CAGE Code, name, address and phone number. Only one special process subcontractor shall be listed per outsourced operation unless otherwise approved by the Government. If CCs or some process that affects a CC are being performed by an outside vendor, then that subcontractor planning is considered part of the manufacturing plan and must be submitted for review. In addition, this planning must meet the requirements of paragraphs 8b and 8c above.

e. Frozen Planning – An approved CSI part manufacturer has submitted their manufacturing planning to the AMCOM/Engineering Support Activity (ESA) and received approval. Once an approved manufacturer has been awarded a contract for a CSI part, their manufacturing planning is “frozen” in accordance with QE-STD-1 (See Appendix B. QE-STD-1). As a condition of contract award, the approved manufacturer will be required to resubmit their planning. This requires a copy of the frozen planning be maintained onsite with the SRD. From this point forward, it is the approved source’s responsibility to notify AMCOM, and obtain approval, for any intended changes to the manufacturing planning that affect a critical characteristic. This will require resubmission of the frozen planning containing the proposed changes. Submit the planning update to the DoD SAFE site (click the icon below to open the instructions):

10) Sixty (60) Day On-hold Letter – During the SAR process, if required, the SRD will request additional information and/or corrections by sending a 60 day on-hold letter containing a description of the additional information and/or corrections required to continue the SAR process. If the prospective manufacturer or distributor does not respond within 60 days, the SAR may be closed due to non-compliance with the SAR process. However, dependent upon the Army’s current and projected needs for the specific part, the SRD may restart the SAR process if the prospective manufacturer provides the required information at a later time.

E. Master Tooling Certification: Provide certification of possession of, or access to, any required master tooling, master gears, proof of calibration, and/or special tooling/test equipment current to latest drawing revision. Please state if no master tooling is required. This certification must be on company letterhead, signed by a company officer, and dated.

F. Technical Data Rights Certification Letter: Certification of rights to use technical data must be presented in the format provided below (see Figure 2.4), signed by someone within the company who has the appropriate signature authority to sign a legally binding document. If proprietary data is involved, you must supply a statement from the owner of that data that gives you the legal rights to use that specific data. NOTE: This also applies to the use of data the Government possesses but does not have the right to use in competitive manufacturing. The format provided in Figure 2.4 below has been approved by the AMCOM legal department. Any changes to the format or language will need to be approved by AMCOM legal.

YOUR COMPANY’S LETTER HEAD

0. TECHNICAL DATA RIGHTS CERTIFICATION

I am an officer and employee of the above named legal entity with the responsibility for investigating the facts upon which this certification is made. To the best of my knowledge and information obtained from my recent investigation:

1. I believe and certify that the technical data (hereinafter to include software) submitted to the U.S. Army Aviation and Missile Command (AMCOM), Huntsville, Alabama, as a part of my company's request for approval as a potential source for the purpose of obtaining a contract, was obtained by legal means by my company, its current or recent employees; and

1. I believe and certify that my company, its current or recent employees, did not obtain or receive any technical data marked with a company's proprietary rights legend or a government limited/restricted rights legend from any U.S. Government agency or employee or other third parties that were used in the preparation of or incorporated into the request for source approval or its supporting technical data other than as described herein; and

1. I certify that my company has the legal right to use said technical data to manufacture the below identified part for the United States Government. To the extent that said technical data are marked with a company's proprietary rights or a Government limited/restricted rights legend or are otherwise believed to be or have in the past been the proprietary data of another company, the following documents which are attached hereto and made a part of this certification form the basis for my company’s claim to use said technical data. Such documentation must show an unbroken chain of authorization from the owner of the proprietary or limited/restricted rights data to the certifying company and must clearly cover the data necessary for source approval.

0. THIS CERTIFICATION CONCERNS A MATTER WITHIN THE JURISDICTION OF AN AGENCY OF THE UNITED STATES AND THE MAKING OF A FALSE, FICTITIOUS, OR FRAUDULENT CERTIFICATION MAY RENDER THE MAKER SUBJECT TO PROSECUTION UNDER TITLE 18, UNITED STATES CODE, SECTION 1001.

THIS CERTIFICATION APPLIES TO

NSN______________________ P/N__________________

(for multiple parts attach NSN / P/N list)

(Signature)_______________________________ (typed or printed name & title)

(Date)____________________________

Figure 2.4 Technical Data Rights Certification Letter

1) TECHNICAL DATA RIGHTS CERTIFICATION INSTRUCTIONS:

a. Place certification on company stationery.

b. List and attach documents pertaining to certification.

c. Date, sign, and state signer's title.

2) POLICY CONCERNING USE OF TECHNICAL DATA BY CONTRACTORS

a. It is U.S. Department of Defense (DOD) policy that limited/restricted rights technical data or a company's proprietary data generally should not be released outside the Government without the written consent of the owner.

b. If a potential source submits technical data to AMCOM for source approval purposes, or to an AMCOM contracting officer for the purposes of meeting responsibility, qualification, or performance requirements, the technical data will be reviewed for ownership and the right to use as set forth below.

c. The Technical Data Rights Certification must be executed prior to source approval. The SRD Source Approval Office has the responsibility to review the certification and ensure that the certification and any documents attached thereto support the contractor's legal right to use all technical data required.

G. Actual Part Subcontractor/Vendor List: A list must be provided containing full company names, telephone numbers, CAGE codes, and addresses of all subcontractors/vendors to be used, as well as the subcontractor/vendor part numbers being procured. Note: Subcontractors/vendors used for castings, forgings, machining, and exotic materials, as well as for special processes/operations designated as critical characteristics, must be AMCOM approved sources. See Figure 2.5 Example Subcontractor/Vendor List.

Figure 2.5 Example Subcontractor/Vendor List

H. Actual Part Shipping & Acceptance Documents: Provide copies of Purchase Orders or shipping documents, and proof of acceptance of production quantities for the actual part(s) from the AMCOM or another DOD agency in the last three years.

I. Similar Part TDP (Technical Data Package): Provide a complete copy of the technical data package required to manufacture the part(s). Note: multiple parts can be submitted to demonstrate and provide evidence of similar part manufacturing capability.

2) The Technical Data Package for a part includes, but is not limited to, the following documentation:

a. Drawings: Provide copies of drawings, Spares Technical Data Package (STDP), Source of Supply (SS) drawings/documents, Parts List (PL), etc., for the part’s most current configuration. Note: Not all parts will have all of these document types.

b. Specifications: Provide copies of the top sheet of all applicable specifications necessary to completely manufacture the similar part (SAE, AMS, MIL Standards, NAS, MS, NASM documents, etc.). Also provide a full copy of any of your company’s internal specifications (i.e. specifications created and controlled by your company) that are referenced in the part’s manufacturing planning (traveler, operations sheets, inspection sheets, technique sheets, etc.).

J. Similar Part Shipping & Acceptance Documents: Provide copies of Purchase Orders or shipping documents and proof of acceptance of production quantities for the similar part(s) from the OEM or another DOD agency in the last three years must be submitted.

K. Comparative Analysis: Provide a detailed comparative analysis of the differences and similarities between your similar part, and the actual part for which you are requesting approval, must be submitted (see Figure 2.6). Note: Your similar part must be a part that you have manufactured within the last three years for: the Original Equipment Manufacturer (OEM), one of its subcontractors, another Department of Defense (DOD) agency, or a civil sector under FAA PMA Identicality. It is acceptable to submit multiple similar parts to substantiate manufacture by similarity, since a single part may not be sufficient. In order to prove similarity, a detailed comparative analysis of the differences and similarities between your similar part(s) and the actual part is required. This analysis should include materials, configuration, tolerances, processes, testing, part function, dimensions, etc. A vague analysis is not adequate.

Note: The “Similar Part” must be a part which you have manufactured during the last three years.

Note: The “Actual Part” is the OEM part.

Figure 2.6 Detailed Comparative Analysis of Actual vs. Similar Part

L. Similar Part Detailed Manufacturing Planning: Provide detailed manufacturing planning for the similar part, including processes, materials, configuration, tolerances, testing, part function, and overall dimensions, must be submitted. This should include an existing stamped off manufacturing plan used to produce the similar part. Manufacturing plans must list all processes in the proper sequence.

M. Similar Part Subcontractor/Vendor List: Provide a subcontractor/vendor list which contains names, telephone numbers, CAGE codes, and addresses of all subcontractors/vendors used (including castings, forgings, exotic materials, machining, special processes, etc.), and subcontractor/vendor part numbers, if applicable.

N. Reverse Engineering Management Planning: Provide reverse engineering management planning which describes all aspects of the proposed reverse engineered design, specifications, materials, critical characteristics, critical inspection processes, and critical manufacturing processes to satisfy requirements and how these were derived. Photographs should be taken of the individual parts with the part number visible (whenever possible) and submitted with the vendor’s SAR. All detailed information about creation of the drawings and the methods used to reverse engineer the part (i.e. what tools were used to determine dimensions, materials, and manufacturing processes) must be submitted for review, comment, and approval.

O. Test Plans: All proposed test plans must be submitted for SRD approval prior to beginning testing.

P. FAA/PMA Certification: Provide an FAA/PMA Certification, based upon Identicality, for the part that you have received from the FAA/PMA (see Appendix 6.F).

Q. Test Data to Validate Performance: Provide test data to validate the performance of the part. Testing is done to validate the performance of the part after the test plans have been approved. Test requirements are part specific and are included in the Spares Technical Data Package (STDP) and/or provided by the SRD who will evaluate part design, qualification, durability, and fatigue/life limiting factors and determine the extent of qualification testing that may be required. Testing will be used to verify that the part manufactured by the prospective new source will provide equal or greater life and performance as compared to the OEM parts currently operating in the field.

Once test requirements/parameters have been determined, you will develop the test plan and submit it to SRD for review and approval. Once the test plan is approved, you will demonstrate that you and your vendors, subcontractors, etc., have adequate engineering expertise and manufacturing or production capabilities to manufacture, inspect, and test the component or part in accordance with all applicable drawings, process specifications, and test specifications. The Government may require inspection of these elements on site. Testing must generally be accomplished at your expense.

The U.S. Army's policy is to procure CSI parts requiring engineering testing only from sources whose parts have satisfied the engineering test requirement. To become an eligible source for a CSI part requiring engineering testing, a vendor must provide written documentation that it has met the engineering test requirement.

Photo Courtesy of the U.S. Army

3.0 Distributor SAR Guidance for Non-manufacturers

A. If you would like to become an AMCOM approved distributor for a restricted source part (or parts) currently being manufactured by an AMCOM approved source, you must first submit a Distributor SAR, consisting of two letters, to the SRD for review and approval: 1) a letter from the prospective distributor (you) and 2) a letter from the AMCOM approved manufacturer (see Section 3.D below). The letters must be written on company letterhead, signed by an officer of the company, and dated. An “officer of the company” could be anyone employed within the company who has the appropriate signature authority to sign a legally binding document.

B. Should you wish to become a distributor for a manufacturer of a part for which the manufacturer is not an AMCOM approved source, a Manufacturer SAR package must be submitted for each part (See Section 3.B below). It is preferable to receive the Manufacturer SAR package directly from the part(s) manufacturer. However, a prospective distributor may submit the Manufacturer SAR package on behalf of the unapproved manufacturer provided they have an agreement in place to do so.

C. Due to time constraints and lead times involved, the Government cannot guarantee expedited processing of SARs submitted in response to a solicitation announcement in the SAM.beta.gov. Once a solicitation appears in the SAM.beta.gov, there is not normally enough time to process a SAR for the current solicitation. Pursuant to Federal Acquisition Regulations (FAR) 9.202(e) - The contracting officer need not delay a proposed award in order to provide a potential offeror with an opportunity to demonstrate its ability to meet the standards specified for qualification. In addition, when approved by the head of an agency or designee, a procurement need not be delayed in order to comply with 9.202(a).

Release Date: 2 July 2024

D. How to Become a Distributor for an AMCOM approved manufacturer: Submit the following two letters to the SRD for review and approval:

1) A letter from the distributor - written on company letterhead, signed by an officer of the company (Example Letter from the Prospective Distributor), which includes the following:

a. The manufacturer and distributor name, address, and CAGE code.

b. A statement requesting to become an AMCOM approved distributor for a restricted source part, or list of parts (including NSNs), which identifies your company as an authorized distributor of the AMCOM approved manufacturer.

c. A statement that the restricted source part(s) are certified as new (never used), and meet all technical data requirements.

d. A statement that the parts will only be received directly from the AMCOM approved manufacturer and will not be removed from their packaging. It is highly preferred that parts are not removed from the AMCOM approved manufacturer’s packaging. However, if parts need to be removed from the approved manufacturer’s packaging, provide an explanation justifying the removal, describe any actions performed on the parts after removal (measurements, weighing, visual inspection, cleaning, etc.), and provide a detailed description of the repackaging process. The SRD will review distributor requests to repackage parts on a case by case basis.

e. A statement that the part(s) are not surplus parts and the manufacturer’s parts will not be delivered from a source other than the AMCOM approved manufacturer (i.e. Magnificent Manufacturing).

f. The original documentation, from the AMCOM approved manufacturer, will be delivered with the restricted source parts and will not, in any way, be altered by the distributor.

g. A statement identifying which party (either the distributor or the AMCOM approved manufacturer) is responsible for final packaging to the specific contract requirements. In addition to all other marking requirements, the packaging for each individual part must include contract number, distributor’s CAGE Code, manufacturer’s CAGE Code and any serial number (if applicable).

h. In the case of CSIs, a statement that all CSI Requirements (QE-STD-1, etc.) will be (or have been) flowed down to the actual manufacturer of the part.

i. A statement providing a telephone number with a point of contact to resolve any discrepancies found with any distributor delivered parts.

2) A letter from the AMCOM approved manufacturer - written on company letterhead, signed by an officer of the company (Example Letter from the AMCOM Approved Manufacturer) which includes the following:

a. The manufacturer and distributor name, address, and CAGE code.

b. A statement identifying the authorized distributor for the part (or list of parts).

c. A statement regarding any limitation of the distributor, if applicable (for example, “Use distributor for all procurements less than $XX”, etc.).

d. A statement that all parts are certified as new (never-used) and that they meet all technical data requirements.

e. A statement providing a telephone number with a point of contact to resolve any discrepancies found with any distributor delivered parts.

f. In the case of CSIs, a statement that the part (or list of parts) will be manufactured to all CSI Requirements (QE-STD-1, etc.) applicable to these parts.

E. How to Become a Distributor for an Unapproved Manufacturer:

1) An unapproved manufacturer is a manufacturer that is not an AMCOM approved source for the restricted source part (or parts) for which you wish to become a distributor. If a distributor wishes to represent a manufacturer who is not an approved source for the restricted source part (or parts), the following documentation is required and must be submitted:

a. A complete Manufacturer SAR package for each of the manufacturer’s restricted source parts must be submitted to the SRD for review and approval (see Section 2.0 Detailed SAR Preparation Guidance for Parts Manufacturers). It is preferable to receive the Manufacturer SAR package directly from the part manufacturer; however, a prospective distributor may submit a Manufacturer SAR package on behalf of the unapproved manufacturer, provided they have an agreement in place to do so. In this case, the manufacturer must provide a letter to the SRD which clearly explains the intent of the proposed manufacturer to be represented by the proposed distributor and should describe the manufacturer/distributor business relationship.

b. The Manufacturer SAR package must first be approved by the SRD before the distributor can be approved to supply the manufacturer's part. After the manufacturer becomes an AMCOM approved source for the restricted source part(s), the prospective distributor must then submit a Distributor SAR, as required by Section 3.A above. Any questions you may have regarding submission of a SAR may be e-mailed to usarmy.redstone.devcom-avmc.mbx.amr-ss-sar@army.mil or call the SAR Team at 256-313-8978, 256-313-6389 or 256-313-8975.

F. More stringent Distributor SAR requirements may be levied at SRD's discretion depending on part complexity, application, or criticality (i.e. Critical Safety Items [CSIs], etc.). Any questions you may have regarding submission of a SAR may be e-mailed to usarmy.redstone.devcom-avmc.mbx.amr-ss-sar@army.mil or call the SAR Team at 256-313-8978, 256-313-6389 or 256-313-8975. Distributor SAR submissions can be e-mailed to usarmy.redstone.devcom-avmc.mbx.amr-ss-sar@army.mil.

Example Letter from the Prospective Distributor

YOUR COMPANY LETTERHEAD Four Corners Distributing

123 Anywhere Boulevard Anytown, State 12345 Phone: (123) 456-7890 Fax: (123) 456-7891

DEVCOM, Sustainment Division Quality Requirements Branch Attn: FCDD-AMR-SS, Mr. Lee Drake 5400 Fowler Road Redstone Arsenal Huntsville, AL 35898-5000

To Whom It May Concern:

Four Corners Distributing, CAGE 6YXXX, is requesting to become an AMCOM approved distributor of NSN 1680-01-563-XXXX, Part Number 111abc-1XXX for Magnificent Manufacturing, CAGE 9TXXX, located at 456 Somewhere Drive, Somecity, State 98765.

All parts delivered by Four Corners Distributing are new (never used) and meet all…