CUI

ARKANSAS AIR NATIONAL GUARD

HEADQUARTERS 189TH AIRLIFT WING

LITTLE ROCK AFB, ARKANSAS

21 Sep 2026

Brand Name Justification for Draeger Gas Detection Equipment

Agency and Contracting Activity:

Department of the Air Force, 189th MSC

1. Nature and/or Description of the Action Being Approved:

This justification authorizes the brand name procurement of Draeger gas detection equipment, specifically the X-am 8000 multi-gas detectors and associated X-dock calibration and testing stations.

2. Description of Supplies/Services Required to Meet the Agency’s Needs:

The 189th Maintenance Squadron (MXS) requires a complete atmospheric monitoring solution to ensure the safety of personnel performing maintenance in permit-required confined spaces, specifically C-130 aircraft fuel tanks and fuel systems. This requirement includes multi-gas detectors with specific sensors for volatile organic compounds (PID), lower explosive limits (LEL), and oxygen (O2), along with automated calibration stations, regulators, and sampling equipment.

The total estimated value is between

3. Identification of the Justification Rationale and Demonstration of Contractor’s Unique Qualifications:

This acquisition is restricted to the Draeger brand name in accordance with FAR (RFO) 12.102(a). The Draeger X-am 8000 is the only atmospheric monitoring device authorized by the installation Confined Space Program Team (CSPT) for use by the 189 MXS Aircraft Fuel System In-Tank Repair Team. This authorization, documented in a memorandum dated 4 February 2025 and signed by Bioenvironmental Engineering, is based on the following critical factors:

Operational Suitability and Safety: The CSPT has identified and approved the Draeger X-am 8000 as the technically superior and required solution for mitigating the severe atmospheric hazards present in C-130 fuel tanks. The existing equipment (MultiRae 3000) has been cited for operational discrepancies, and the CSPT has endorsed the immediate implementation of the Draeger system to ensure an adequate level of safety for personnel.

Standardization and Interoperability: The 189 MXS has standardized its confined space safety program on the Draeger platform. This includes established training curricula, maintenance procedures, and existing inventories of compatible equipment. Introducing a different brand would require a complete overhaul of the unit's safety program, including developing new training materials, conducting extensive re-certification for all personnel.

This would introduce unacceptable operational delays, increase the risk of procedural errors, and be cost-prohibitive.

4. Determination by the Ordering Activity Contracting Officer that the Order Represents the Best Value:

A determination has been made that the order placed will represent the best value to the government. Market research has identified multiple small business contractors capable of providing the required brand-name equipment. The requirement will be solicited as a 100% Small Business Set-Aside on SAM.gov to maximize competition among these vendors. By soliciting competitive quotes from multiple authorized distributors, the Government ensures that the award will be made at a fair and reasonable price, representing the best value.

5. Description of Market Research:

Initial market research was conducted by reviewing the GSA eBuy and GSA Advantage! portals, which confirmed that Draeger products appeared to be available from multiple small business GSA contract holders. This preliminary research, combined with three quotes obtained by the end-user from authorized distributors, indicated that sufficient competition should exist among authorized resellers. Based on this, a Request for Quotation (RFQ) was issued on GSA eBuy. However, the quotes received in response to the GSA solicitation were primarily for open market items, meaning the vendors did not have the required Draeger products on their GSA schedule contracts. This outcome demonstrated that adequate competition does not exist via GSA schedule holders for this specific requirement. This finding is the basis for canceling the GSA RFQ and soliciting the requirement on the open market via SAM.gov, where the Government can compete the requirement among the small business vendors who have already proven their capability to source these items.

6. Any Other Facts Supporting the Justification:

Failure to procure the specified Draeger-branded equipment would directly contradict the formal safety authorization from the installation CSPT and Bioenvironmental Engineering. It would force the use of unapproved equipment in a high-risk environment, violating established safety protocols.

7. A Statement of the Actions, if any, the Agency May Take to Remove or

Overcome any Barriers that Led to the Restricted Consideration Before Any Subsequent Acquisition for the Supplies or Services:

The requirement for a standardized atmospheric monitoring system will remain for the foreseeable future due to safety, training, and interoperability mandates.

The government will continue to conduct market research to assess whether other systems are approved by the CSPT for this specific application in future acquisitions. However, for this requirement, no other brand can meet the government's needs.