Response to PAP Concerns.docx

Performance Assessment Plan Concerns In response to some recent questions/concerns that we have received in regards to our recent posting of the Performance Assessment Plan we have elected to post our response for everyone to see. It is vital that everyone understand that there is a significant change in the government’s approach to Quality Assurance on this solicitation.

A concern was expressed about our performance threshold o f “zero major nonconformance.”

It is important to understand that the government is transitioning from a surveillance based on quality control to one based on quality assurance. In PMEL terms, we are all familiar with critical and non-critical non-conformities as they relate to T.O. 00-20-14. In our view, those are quality control measurements of individual items and processes. What the government is transitioning to is that our provider is responsible for quality control; the government is going to perform surveillance in order to assure that a contractor’s processes are in fact controlling their quality. Our definition, as identified in both our PWS and PAP, of a major non-conformance is the same definition that we have on all of our aircraft maintenance contracts and has served us very well in terms of quality assurance. We are not looking at individual items and the individual results of either a process or product review. Instead we are using those results as data points when we evaluate if the contractor’s performance adversely affects or has the potential to adversely affect mission, safety of personnel or equipment, performance (quality), schedule (delivery), cost, and increases the Government’s risk. An item that is out of tolerance, in and of itself will typically not result in a major non-conformance. That item does not by itself increase our risk in terms of contractor performance. Systemic issues however increases risk, individual issues do not, so how a contractor handles these individual data points is of greater interest in assuring quality.

Another concern was expressed in inclusion of the phrase, key processes. We have added the requirement of compliance with ISO 9001:2008. Within ISO 9001:2008 it is inherent for an operation to identify their key processes to insure the quality of their operation. Continuous improvement is another aspect of ISO 9001:2008 that was included within the PAP. The contractor’s QMS will be evaluated against all of the requirements, and after acceptance, performance will be then viewed in terms of the QMS.

There was also a question/concern that we plan to surveil quality assurance, corrective actions, and training among others. All of these items are requirements with our PWS and also have specific requirements within ISO 9001. As mentioned earlier, our surveillance is going to be based on quality assurance and each of these areas play a significant piece in assuring the quality of the products that are produced. If our surveillance was going to concentrate on quality control, then we would have continued only looking at the end of calibration results. A contractor’s internal quality program does that, the government has elected not to merely duplicate that program but instead look at all areas that assure quality.