Fire Bottles JA FAR Part 6_Redacted.pdf

Controlled Unclassified Information

Justification Review Document for Other than Full and Open Competition - FAR Part 6

Program/Equipment: Service to perform twelve-year maintenance on 15 Amerex Model 600K 150# Halon 1211 fire extinguishers.

Authority: 10 United States Code 3204(a)(2) as implemented in Federal Acquisition Regulation 6.302-2(a)(2), Unusual and compelling urgency.

Amount:

Prepared by:

Typed Name: DSN:

Title: Contract Specialist Date: 2 July 2025

E-mail:

Contracting Officer:

Typed Name: DSN:

Date Reviewed: 3 July 2025 E-Mail:

Technical Representative:

Typed Name: DSN:

Title: Flight Chief, 129 AMXS/MXAAC Date: 3 July 2025

(Source Selection information - See FAR 2.101 and 3.104-4)

1 AUG 2022

AUG 2022

Justification and Approval for Other than Full and Open Competition – FAR Part 6

1. Contracting Activity: 129 MSG/MSC, Moffett Field ANGB CA

2. Description of Action: This justification supports a sole source contract award to Safety Control, LLC for services to perform twelve-year maintenance and inspection on 15 Amerex Model 600K 150# Halon 1211 fire extinguishers, ensuring they are fully functional and compliant with applicable technical orders and safety standards. The Government anticipates awarding a firm-fixed-price contract funded using Operation and Maintenance funds.

3. Description of Supplies/Services: Service to perform twelve-year maintenance on 15 Amerex Model 600K 150# Halon 1211 fire extinguishers.

4. Authority Cited: 10 United States Code 3204(a)(2) as implemented in Federal Acquisition Regulation 6.302-2(a)(2), Unusual and compelling urgency.

5. Reason for Authority Cited: The 129 RQW currently possesses fifteen (15) Amerex Model 600K Halon 1211 fire extinguishers that are non-compliant in accordance with DAFMAN91-203 section 15.7.3 and applicable safety standards. This non-compliance presents a serious and immediate risk to mission capability, resulting in a potential complete stoppage of aircraft maintenance operations at Moffett ANGB. This represents a serious injury to the government in terms of degraded operational readiness and potential safety risks.

The 129 RQW currently has 3 extinguishers that were borrowed from NASA; however, the NASA extinguishers must be returned no later than 18 July 2025. Therefore, the required delivery schedule for this maintenance is two weeks. Market research has revealed that few vendors possess the specialized expertise and certifications required for twelve-year maintenance on these specific types of Halon fire extinguishers. Safety Control LLC is the only known contractor capable of meeting the technical requirements and the critical two-week performance period.

Attempting to utilize competitive procedures would inevitably extend the timeline beyond the acceptable two-week period. Therefore, the urgent need to restore the extinguishers to compliance within two weeks necessitates utilizing FAR 6.302-2(a)(2), Unusual and compelling urgency to procure these services from Safety Control LLC on a sole-source basis.

6. Efforts to Obtain Competition: Market research was conducted to identify potential sources capable of providing the required maintenance and inspection services.

However, due to the specialized nature of the Amerex Model 600K Halon 1211 fire extinguishers and the condensed two-week performance period, no other vendors possess the necessary technical knowledge, expertise, or capabilities to meet the government’s requirement. By reviewing available sources in the industry, consulting with technical experts, and analyzing capabilities of potential vendors, this research confirmed that Safety Control LLC, is solely positioned to meet the requirement.

7. Actions to Increase Competition: For future Halon fire extinguisher maintenance requirements, the government will pursue a multi-pronged approach that includes:

(1) Enhanced market research to identify all potential sources, including those outside our immediate geographic area.

(2) Early engagement with potential vendors to discuss future requirements and facilitate their qualification process.

(3) Long-term planning that considers alternative fire extinguisher systems and strategies to maximize competition for future maintenance and inspection services.

8. Market Research: The requiring activity and contract specialist conducted market research within the last month by conducting internet searches, contacting knowledgeable people (Government and Industry) regarding this requirement, and reviewing government contracts. This research revealed that while Halon fire extinguisher maintenance is commercially available, very few vendors possess the specialized expertise and certifications needed for the twelve-year maintenance on the specific type of Halon system used by the 129 RQW. Furthermore, only Safety Control LLC indicated an ability to meet the critical two-week performance deadline. This research confirmed that Safety Control LLC is the only known source capable of meeting both the technical requirements and the urgent delivery schedule necessary to restore the 129 RQW’s mission capability.

9. Interested Sources: Two potential sources were identified during market research:

Safety Control LLC and Ace Fire Equipment & Service Company, Inc. While both companies provide Halon fire extinguisher maintenance services, only Safety Control LLC confirmed the capability to meet the required two-week performance period. Ace Fire Equipment & Service Company, Inc. indicated they could not meet this critical timeline.

10. Other Facts:

a. Procurement history.

(1) Previous Contract Number: W50S8X-21-P-0020

(2) The competitive status of these actions: Full and open competition

(3) Authority previously cited if less than full and open competition was used: Not applicable

(4) If a justification was prepared to support the procurement made before this one, a summary of the contents of paragraph 7 of the justification for that procurement and an explanation of the results: Not applicable

(5) If any prior contract for this requirement was accomplished using full and open competition, include a detailed explanation of the changed circumstances causing this action to now limit the sources: Not applicable

(6) An explanation of any unusual patterns that may be revealed by the history, e.g., several consecutive, urgent buys: Not applicable

(7) If a justification was prepared to support the procurement made before this one, briefly describe the circumstances justifying the procurement and whether there have been any significant changes: Not applicable

b. Other facts. None.

11. Fair and Reasonable Cost Determination:

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. The basis for this determination will be price analysis in accordance with FAR 15.404-1(b). Certified cost or pricing data is not required per FAR 15.403-1(b)(3) because the service being acquired is considered commercial.

12. Contracting Officer Certification:

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Signature:

Typed Na