JA 25-0001 Other Than Full Open.pdf

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J&A No. 25-0001

V1.4, 26 September 2024

JUSTIFICATION AND APPROVAL (J&A)

FOR USE OF OTHER THAN FULL AND OPEN COMPETIION

1. Contracting Activity.

• Contracting Office: Marine Corps Installation West (MCIW) Regional Contracting Office (RCO) Camp Pendleton, CA.

• Requiring Activities: Fire and Emergency Services Departments located at Marine Corps Base Camp Pendleton (MCBCP), Marine Corps Logistics Base (MCLB) Barstow, Marine Corps Air Ground Combat Center (MCAGCC) 29 Palms, and Marine Corps Air Station (MCAS) Miramar.

2. Description of the Action Being Approved.

This Justification and Approval (J&A) supports a proposed sole source award for the provision of comprehensive, on-site advanced cleaning, inspection, and repair services for firefighter turnout gear and Personal Protective Equipment (PPE) across multiple Marine Corps installations.

A. Proposed Contractor: HC Risk Reduction, Inc. (dba Redline Gear Cleaning) B. Estimated Contract Value: $1,787,000.00 C. Contract Type: Firm-Fixed Price (FFP) D. Period of Performance: Base year plus four (4) one-year option periods E. Statutory Authority for Other Than Full and Open Competition: 10 U.S.C. 3204(a)(1) F. FAR Implementation: FAR 13.501(a).

G. Acquisition Procedures: This acquisition will utilize Simplified Acquisition Procedures under

FAR Subpart 13.5, as authorized by 41 U.S.C. 1901 for the acquisition of commercial products and commercial services.

3. Description of the Supplies/Services.

The United States Marine Corps (USMC) F&ES, through a policy letter, requires Marine Corps fire departments to utilize the Center for Public Safety Excellence and the Commission on Fire Accreditation International model to assess and align the department’s operations. This model emphasizes regular inspections, testing, preventive maintenance, and emergency repairs for all fire apparatus and equipment, including firefighter turnout gear and Personal Protective Equipment

(PPE).

Historically, the inspection and repair services for turnout gear have been contracted out, while advanced cleaning services were performed on-site at the respective fire stations by individual firefighters. However, to maintain compliance with the strict regulations outlined in NFPA 1851 Section 7.5 Specialized Cleaning, MCIW F&ES now requires advanced cleaning to be performed

Controlled by: DON, USMC, I&L HCA Controlled by: MCI-W RCO CUI Category(ies): PROCURE Limited Dissemination Control: DL ONLY POC: Corey Slivnik, corey.slivnik@usmc.mil, 760-542-8245 mailto:corey.slivnik@usmc.mil by a third-party Verified Independent Service Provider (ISP). This represents a change from the previous practice of relying on individual firefighters to perform this specialized cleaning.

This change in approach necessitates finding a company that can perform NFPA 1851 compliant, on-site, same-day services to ensure firefighters remain fully operational. The government must find a vendor who has the capability and proven capacity for rapid, same-day turnaround necessary to fulfill this critical requirement without unacceptable compromises to firefighter safety, operational readiness, or logistical efficiency.

Required services:

The contractor shall provide the management, labor, equipment, tools, and supplies necessary to provide twice per year, Advanced Cleaning, Inspection and Repair services for 785 complete sets (a complete set includes helmet, hood, jacket, pant, liner, boots, and gloves), and 30 incomplete sets (an incomplete set includes hood, jacket, pant, liner, and gloves) of PPE per the standards published by the National Fire Protection Association (NFPA) in “NFPA 1851: Standard on Selection, Care, and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting” (hereafter “NAPA 1851”).

The allocation of the equipment sets is broken down by location in the table below:

Camp Pendleton Barstow Miramar 29 Palms

Complete Sets 360 150 125 150 Incomplete Sets 30 0 0 0

All services must be performed on-site at each of the fire stations by a Certified Qualified Technician. All work must comply with National Fire Protection Association (NFPA) standards, Occupational Safety and Health Administration (OSHA), National Institution for Occupational Safety and Health (NIOSH), Underwriters Laboratories (UL) Standards, Department of Transportation (DOT), and Structural Industries SI) Standards, as well as the manufacturer’s recommended guidelines.

The on-site services that will be included in the Performance Work Statement (PWS) are summarized as follows:

Advanced Cleaning Process

The advanced cleaning process shall be in compliance with NFPA 1851 Section 7.5 Specialized Cleaning. The cleaning process shall be performed using the third-party verified Independent Service Provider (ISP) patented MEU that contains an inner and outer shell PPE gear extractor; a tumble dryer for inner shells; a drying cabinet for outer shells; a self-contained water supply and storage; an ultrasonic-cleaning unit; an ozone cleaning station; and a hydrostatic and reflection testing station.

Inspections/Repair Process

All gear including jackets, pants, liners, boots, gloves, and helmets undergoes a rigorous 25-point inspection by trained professionals. Inspections are performed pre and post cleaning. Any and all repairs must first be approved by the customer prior to being performed. Any issues and repairs are documented. Per NFPA 1851 guidelines, the MEU is outfitted with a hydrostatic testing station to inspect inner liners. Redline also conducts reflection testing to ensure that the reflective strips work properly.

A full inspection report is provided at the completion of the process and outlines all findings.

Should gear need to be repaired, RedLine will ensure proper repair of gear.

Estimated Dollar Value

FY25 FY26 FY27 FY28 FY29 Grand Total O&M $357,400.00 $357,400.00 $357,400.00 $357,400.00 $357,400.00 $1,787,000.00

The period of performance will be as follows:

Base Year: 1 September 2025 – 31 August 2026 Option Year One (1): 1 September 2026 – 31 August 2027 Option Year Two (2): 1 September 2027 – 31 August 2028 Option Year Three (3): 1 September 2028 – 31 August 2029 Option Year Four (4): 1 September 2029 – 31 August 2030 6-Month Extension: 1 September 2030 – 31 March 2031

4. Statutory Authority Permitting Other Than Full and Open Competition.

1 0 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

FAR Subpart 13.5 procedures are being utilized for this acquisition in accordance with 41 U.S.C.

1901.

5. Rationale Justifying Use of Cited Statutory Authority.

The use of 10 U.S.C. 3204(a)(1) is justified by the agency's unique and non-negotiable requirement for an on-site, comprehensive (NFPA 1851 and OEM-compliant cleaning, inspection, and repair), high-volume (up to 40 sets per day throughput) turnout gear and PPE maintenance service, delivered efficiently on base across multiple geographically dispersed Marine Corps installations.

Same day service allows fire department to remain fully operational during the process. Firefighters are not waiting days or weeks, sometimes longer, for a set of PPE to be returned because it was shipped off-site to be cleaned, inspected, and/or repaired.

Extensive market research has conclusively demonstrated that only one responsible source, HC Risk Reduction, Inc. (dba Redline Gear Cleaning), possesses the precise combination of specialized capabilities—including patented mobile units, specific certifications, an integrated service model, and the proven capacity for rapid, same-day turnaround—necessary to fulfill this critical

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V1.4, 26 September 2024 requirement. No other available supplies or services can meet these stringent agency needs without unacceptable compromises to firefighter safety, operational readiness, or logistical efficiency.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

A. Market research was conducted in accordance with FAR Part 10 and revealed that there are multiple vendors in the commercial market capable of providing the required services at their business locations; however, none of the vendors identified provided on-site services.

B. Methods Used:

1. Searches of System for Award Management (SAM.gov) for relevant NAICS codes (e.g., 812322 – Industrial Launders) generated twenty-eight (28) results as follows:

a. Municipal Emergency Services, Inc. (MES) was listed eleven (11) times due to the various locations they service. MES does not provide any of the services required for this effort.

b. Fire-Dex GW, LLC dba Gear Wash - Gear Wash, can only perform services at their facility – turnout gear would have to be sent to Ventura (the closest local facility) for services. Ventura is more than 150 miles from Camp Pendleton (closest) and over than 220 miles from 29 Palms (farthest). This does not meet the requirements of this effort.

c. Redline Gear Cleaning, LLC. - perform services on-site at the customer’s location via their Mobile Extraction Unit (MEU).

d. BioMedX, Inc. – specializes in the maintenance and repair of hospital systems.

e. D'Ray Public Speaking & More, LP – motivational public speaker

f. Fire & Life Safety Consultants LLC, and Semper Fi Stachurski LLC – Fire and safety consultants for fire protections solutions. These companies do not provide any of the requirements needed for this effort.

g. Lakeyland, Inc dba Northwest Safety Clean - can only perform services at their facility – turnout gear would have to be sent out of state to Oregon.

h. ITM4G, LLC - provides Fire Protection, Facilities Management, O&M, Engineering, Construction, Installation, Inspection, Testing and Maintenance services. They do not provide any of the requirements needed for this effort.

i. MGHeath Advisory LLC, Bauarana Consulting LLC, Stefan Consulting Group LLC, USA Government Contracting, LLC – All three (3) vendors are consulting groups. They do not provide any of the requirements needed for this effort.

j. StellarEdgeFS Industries LLC - specializing in comprehensive facility management, general construction, and professional service delivery.

k. THELYNE, LLC - services include snow plowing, salting, and sanding for roads, parking lots, sidewalks, and military equipment parking lots.

l. Words Warriors LLC – Language Translators.

m. Native Hawaiian Veterans, LLC - professional services and solutions support in the areas IT Modernization, C6ISR (Command, Control, Communications, Computers, Cyber-defense, Combat Systems, Intelligence, Surveillance and Reconnaissance), and Next Generation Analytics.

n. No Sweat Gear - Gear Wash, can only perform services at their facility – turnout gear would have to be sent Fairbanks, Alaska, more than 3,000 miles from bases requiring service.

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2. Dynamic Small Business Search (DSBS) – generated eleven (11) results. Of these results, four (4) vendors were determined capable of providing similar services:

a. Dry Gear Solutions, Inc. – services provided only in their facility. This does not meet the requirements of this effort.

b. Turnout Rental, LLC - services provided only in their facility. This does not meet the requirements of this effort.

c. Steamatic of Southern Nevada - services provided only in their facility. This does not meet the requirements of this effort.

d. Turnout Uniforms, Inc. – only performs sewing services.

e. Redline Gear Cleaning, LLC. - performs all services on-site at the customer’s location via their Mobile Extraction Unit (MEU).

3. Source Sought M33120FY25FIRE-PPE via SAM.gov was issued on 11 June 2025 to identify potential vendors. Five (5) vendors expressed interest as follows:

a. BHPE, LLC – Vendor regularly sends an email of interest to all Sources Sought, however never provides a capabilities statement or requested information.

b. Fire-Dex dba Gear Wash can only perform services at their facility – turnout gear would have to be sent to Ventura (the closest local facility) for services, over average over 190 miles from any of the fire house location requiring service.

c. RV Global solutions, Inc., primary past performance in IT, facility support services. A follow-up email was sent to this vendor for more specific information relating to relevant experience in regard to the required services. No response was received by this Vendor.

d. AOS Services, Inc – they provided capabilities statement that reflected similar services along with references. An email was sent to the three (3) provided references to confirm that similar services were provided and if they were provided on-site at their locations. Two responses were received – one response indicated these services were not provided under their contract and the second response stated that the services were performed off-site at a subcontractor’s facility. AOS did have a previous contract at Camp Pendleton for inspection and repair services for turnout gear and PPE at MCB Camp Pendleton and MCLB Barstow. It was confirmed by the fire chiefs that these services were performed off-site at the subcontractor’s facility.

e. HC Risk Reduction, Inc. (dba Redline Gear Cleaning) – this Contractor’s capability statement reflects that they perform on-site services via their Mobile Extraction Unit (MEU). They are the patent holder and Sole Source of the MEU TM (Patent# 11,578,455 B2 dated 23 January 2024). This unit is required to perform ISP function onsite. They are the only company who can provide full ISP services including advanced cleaning, inspection, and repair services at each of the fire house locations.

4. Consultations with Marine Corps Installations East Regional Contracting Office (MCI-E RCO), and Naval Facilities Engineering Systems Command Southwest (NAVFAC SW) with similar requirements.

a. Ms. Regina Hartley, Contracting Officer, MCI-E RCO Camp Lejeune, confirms that the market research completed by their office reflects that Redline Gear Cleaning is the only vendor that performs the required on-site services. Redline is currently performing these services for MCI-E under Contract No.

M6700124P1141.

5. No additional market research was conducted

7. Determination of Fair and Reasonable Cost.

A. The Contracting Officer has determined that the anticipated price to the Government of the supplies/services covered by this J&A will be fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

A. The agency is committed to fostering full and open competition wherever practicable. While the current requirement for comprehensive, NFPA 1851- and OEM-compliant, high-volume, onsite PPE cleaning, inspection, and repair services across multiple, dispersed military installations limits competition to a single source due to its unique capabilities and the vendor's patented technology, the agency will undertake the following actions to remove barriers to future competition:

1. Continuous Market Surveillance: The Contracting Officer will actively monitor the commercial marketplace for new or emerging technologies and service providers that develop similar self-contained mobile units (like the Mobile Extraction Unit (MEU) TM) capable of delivering integrated, on-site, high-volume PPE maintenance services. This includes tracking advancements in equipment, processes, and certifications that could lead to alternative solutions.

2. Targeted Industry Engagement: During future acquisition planning, the agency will conduct specific outreach, such as targeted Requests for Information (RFIs) or industry days, to identify and encourage vendors to develop the unique combination of capabilities required. This engagement will specifically inquire about the ability to:

a. Possess the capability to deliver on-site, comprehensive (advanced cleaning, inspection, and repair), NFPA 1851 compliant, and OEM-certified PPE maintenance services.

b. Operate self-contained mobile units capable of delivering these services directly on-site at multiple, geographically dispersed installations.

c. Demonstrate a daily processing capacity for high-volume throughput (e.g., 40 sets per day).

3. Requirement Review and Optimization: The agency will periodically reassess the requirement to identify any opportunities for unbundling services, modifying technical specifications, or adjusting delivery models that could potentially broaden the competitive base, without compromising the critical mission requirements for firefighter safety, operational readiness, and logistical efficiency that necessitate the current comprehensive onsite approach.

4. Leveraging Lessons Learned: The agency will continue to consult with other DoD and federal agencies (such as MCI-E RCO, NAVFAC SW, NAVSUP, Dept. of Forestry) to share best practices and lessons learned regarding unique PPE maintenance solutions and efforts to promote competition in this specialized area.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical Cognizance:

Signature Name (Printed) Phone No. Date

LEGAL SUFFICIENCY REVIEW

I have determined that this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

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

COMPETITION ADVOCATE APPROVAL

Upon the basis of the above justification, I hereby approve as Competition Advocate, the solicitation of the proposed procurement(s) described herein using brand name or equal descriptions or proprietary specifications and standards.