JUSTIFICATION FOR NAME BRAND.pdf

NON COMPETITIVE MEMORANDUM

South Central Regional Office

SCBA Cylinders-Scott Safety

1. REQUIRING AGENCY-

Federal Bureau of Prisons South Central Regional Office 344 Marine Forces Drive Grand Prairie, TX 75051

2. NATURE/DESCRIPTION OF ACTION BEING APPROVED-

Solicitation and award of a contract on a brand-name basis for supplies peculiar to one manufacturer under RFQ 15B50026Q00000002.

3. DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S

NEEDS-

The requirement is for 358 Scott Safety SCBA Cylinders, Part Number 804723-01, to replace existing cylinders at multiple institutions in the South-Central Region.

4. IDENTIFICATION OF STATUTORY AUTHORITY PERMITTING OTHER THAN FULL

AND OPEN COMPETITION-

41 U.S.C. 253. Competition requirements; 41 U.S.C. 1901. Simplified acquisition procedures

5. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF

THE AUTHORITY CITED-

The agency currently fields SCBA systems designed, tested, and certified as integrated life-safely assemblies. These systems include facepieces, regulators, harness assemblies, and high-pressure cylinders engineered as a matched set. Use of non-Scott cylinders would create a break in system certification and void manufacturer interoperability assurance.

Substitution alternate-brand cylinders would require

Complete system requalification testing

Potential redesign or adapter us (not authorized for certified SCBA systems)

Recertification under NIOSH and NFPA standards.

These requirements would introduce unacceptable delay and risk.

Only cylinders produced and certified within the original equipment manufacturer system, 3M Scott Fire & Safety, ensure compliance without invalidating certification. Use of other brand name cylinders could render the entire respiratory protection system non-compliant, exposing personnel to serious safety risks.

Extensive market research confirms that no alternative manufacturer provides SCBA cylinders that are fully interchangeable without system modification and certified under the existing SCBA assembly approval.

Only the brand-name item identified above will satisfy the Government’s requirements.

6. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED

FROM AS MANY POTENTIAL SOURCES AS PRACTICABLE-

Market research was conducted in accordance with FAR Part 10 and included:

A review of available manufacturers and suppliers of SCBA cylinders through industry sources and government procurement databases.

Identification of authorized distributors and resellers of 3M Scott Fire and Safety equipment.

Although the brand-name requirement limits the pool of manufacturers; competition will be obtained among all available authorized distributors. This approach ensures that the Government receives competitive pricing while maintaining compliance with safety, certification, and interoperability requirements.

To promote competition to the maximum extent practicable the requirement will be publicly posted on SAM.gov to provide all interested vendors with the opportunity to respond. Quotes will be accepted from all responsible sources capable of providing the required brand-name items. No restrictions are placed on distributors beyond the requirement to provide compliant OEM-certified products.

7. CONTRACTING OFFICER’S CERTIFICATION

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

Submitted By:

Abigail Arriaga Date Regional Contract Specialist

4/22/2026