Attachment 3 - JA for Under SAT.pdf

United States Department of Agriculture Decision to Restrict Competition under the Simplified Acquisition Threshold

Identification Number: 1232SA26Q1012

Rev. 3/4/26

In accordance with the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) FAR 12.102(a), the following documents the decision to restrict competition for this acquisition.

(1) Mission Area and Contracting Activity

Requisition Number: 1174258

Requesting Activity Agency: USDA-ARS Agricultural Water Efficiency and Salinity Research Unit (129156)

Contracting Activity: USDA-ARS Acquisition and Property Division (1232SA)

(3) Brief Description of Supplies or Services

The acquisition involves procuring a laboratory-grade microwave digestion system, the Milestone Ethos UP with its MAXI-44 rotor. This system is needed to perform closed-vessel acid digestion of plant and soil samples prior to elemental analysis on the ICP-OES. Microwave digestion is a critical preparatory step in producing fully digested plant and soil materials in solution suitable for macronutrient and micronutrient quantification. It provides controlled microwave heating through precise pressure and temperature management. This results in reproducible digestion conditions across large sample batches to ensure the efficient and uniform breakdown of these environmental samples. The analytes must be fully in solution prior to analysis for nutrient cycling studies, water efficiency assessments, and soil chemistry research conducted by the laboratory.

(1) Suggested Source

The suggested contractor is:

Milestone Inc.

25 Controls Drive Shelton, CT 06484

UEI: VJ19GM8NHHT7

(4) Justification for Restricting Competition and the Basis for that Decision.

A. Explain the unique qualifications/characteristics of the proposed contractor or product and why no other contractor or product/service can meet the Government's need.

The acquisition of the microwave digestion system must be restricted to the Milestone Ethos UP due to several unique qualifications and characteristics exclusive to their product. The USDA-ARS Salinity Laboratory currently operates the Milestone Ethos EZ microwave digestion system, which has supported years of validated digestion protocols and established methods for plant and soil materials. However, the Ethos EZ is an aging system with essential parts becoming obsolete and serviceability diminishing. Upgrading to the Ethos UP will allow the laboratory to preserve existing digestion workflows, maintain compatibility with our existing analyzer, improve operational reliability, and ensure continued production of high quality digested needed for ongoing research and analytical projects. All plant and soil digestion methods, including reagent volumes, temperature ramps, pressure profiles, and power input/output, are built around

United States Department of Agriculture Decision to Restrict Competition under the Simplified Acquisition Threshold

Identification Number: 1232SA26Q1012

Rev. 3/4/26

Milestone’s hardware design. These methods were optimized specifically for Milestone vessel geometry, rotor configuration, and microwave distribution. Switching to another contractor or product will invalidate all current digestion protocols. This will require the development, testing, and validation of new digestion programs. Different systems will also alter the digestion kinetics and have varying microwave energy delivery, vessel materials, pressure mechanisms, and temperature feedback system. This will introduce the risk of error during the method development process and will disrupt the workflow of essential salinity and nutrient analysis research. The final data produced on the ICP-OES from the digested products will also be impacted due to a change in the microwave contractor. Calibration standards, detection limits, quality control/quality assurance, and method accuracy have all been evaluated and calibration in tandem with Milestone’s system.

The Ethos UP provides a spacious stainless-steel cavity for corrosion resistance and acid gas containment. The rotating microwave diffuser ensures uniform energy distribution. This in combination with the contactless temperature control allows the temperature of all vessels to be monitored simultaneously. The PTFE-TFM vessels with vent and reseal safety technology allows for the controlled release of excess vessel pressure and resealing after pressure relief. Alternative systems rely on other safety features that pose more risk compared to the Ethos UP. Milestone’s design preserves vessel integrity and minimizes the loss of volatiles which is essential for trace element analysis. Only the Milestone MAXI-44 rotor can handle 44-100 mL vessels positioned in a single rotor. This design allows for the ability to digest a high number of samples in one batch without downsizing the vessels, splitting batches, or performing multiple runs. Being able to simultaneously digest 44 samples under identical chemical and thermal conditions is incredibly efficient and accelerates sample turnaround. There will also be less variability between samples.

Overall, Milestone provides a direct upgrade path to ensure continuity and maintain workflow with unique and specific engineering features that are not available in other models on the market. The Ethos UP is the only microwave digestion system that meets every one of the USDA-ARS Salinity Laboratory’s technical, operational, and safety requirements in a single integrated platform while preserving full compatibility with existing Milestone digestion methods. No other system on the market provides this complete suite of capabilities simultaneously without compromising other features such as vessel volume, batch size, and temperature monitoring precision.

B. Describe market research conducted and the results or the reason why no market research was conducted.

Market research was conducted to determine whether comparable microwave digestion systems available from other vendors would meet the laboratory’s minimum technical and operational requirements. This included reviewing commercially available rotor-based digestion platforms, analyzing vendor specifications, and closely examining competing systems’ vessel materials, pressure and temperature management designs, vessel temperature monitoring capabilities, and batch throughput configurations. The findings confirmed that no other microwave digestion systems could provide all required specifications simultaneously without compromising vessel volume, the temperature control system, and existing validated digestion methods.

Certifications & Approvals

(5) Technical / Requirements Personnel Certification I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.