CJA_KabaMas GPMO_13Feb2025_Redacted.pdf

DEPARTMENT OF THE NAVY

NAVAL FACILITIES ENGINEERING SYSTEMS

COMMAND PACIFIC 258 MAKALAPA DR STE 100

JBPHH HI 96860-3134

J&A No. 25-004

CLASS JUSTIFICATION AND APPROVAL FOR

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity:

Department of the Navy, Naval Facilities Engineering Systems Command, Pacific (NAVFAC Pacific), Joint Base Pearl Harbor-Hickam, Hawaii.

2. Description Of The Action Being Approved:

This Class Justification and Approval (CJ&A) authorizes and approves, on a brand-name basis, the use of Kaba-Mas X-10 dial combination locks, for the Marine Corps’ Defense Policy Review Initiative (DPRI) Program, which will not provide for full and open competition.

All Kaba-Mas dial combination locks, as specified under Paragraph 3 below, are authorized under this CJ&A regardless of method of execution or procurement strategy (i.e., contracted, in-house shop forces, base operating support contracts, or materials supply chain contractors).

The authority to act under this CJ&A expires on 31 January 2030.

3. Description Of Supplies/Services:

Throughout the DPRI build-up, hundreds of building systems and facilities will be constructed, resulting in the acquisition of many similar components that are common across each facility. A GSA combination-compliant dial combination lock will be one of those common components. It has already become a maintenance challenge to maintain different types of manufacturer systems that perform the same function but in their respective proprietary way. Training to support the operations and maintenance of these different systems is very specialized. Parts warehousing is cumbersome. The large number of different systems, associated training requirements, and volume of replacement component result in high operation and maintenance costs.

Construction planning determined the most appropriate course of action is to use GSA-approved dial combination locks on pedestrian doors and doors to secure spaces in accordance with DOD Manual 5200.01, and OPNAVINST 5530.13D. The necessary locks will exclusively be used with pedestrian door deadbolt devices in accordance with Federal Specification FF-L 2890B Types I-VI. The quantity of locks is estimated to be 25 at a cost of per lock. A non-exhaustive list of projected projects that will utilize this dial combination lock is provided in Attachment A.

DESCRIPTION QTY UNIT UNIT

COST

TOTAL

Kaba Mas Dial Combination Lock (most current model)

25 EA

TOTAL FOR DPRI Program

*Unit Cost data obtained from price list.

4. Statutory Authority Permitting Other Than Full And Open Competition:

The statutory authority permitting other than full and open competition is Title 10 U.S.C.

3204(a)(1) and (b)(B)(i) and (ii), as implemented by the Federal Acquisition Regulation (FAR) 6.302-1, “Only one responsible source and no other supplies or services will satisfy agency requirements”.

5. Rationale Justifying Use Of Cited Statutory Authority:

DoD Manual 5100.76 (April 17, 2012, Incorporating Change 2, Effective October 5, 2020)) and DoD Manual 5200.01, Volume 3 (February 24, 2012 Incorporating Change 3, July 28, 2020) specifies the use of GSA-approved dial combination locks that meet Federal Specification FF-L- 2740 Locks, Combination, current edition. OPNAVINST 5530.13D (May 28, 2021) specifies the use of GSA-approved dial combination locks that meet Federal Specification FF-L-2740B Locks, Combination, Electromechanical. Additionally, Kaba-Mas locks have unique self-powered characteristics essential to US Marine Corps Forces Pacific (MFP) Critical Infrastructure Program requirements. These unique characteristics preclude consideration of a product manufactured by any other company.

This dial combination lock is available from only one responsible source and no other dial combination lock will satisfy MFP Critical Infrastructure Program requirements.

The MFP Critical Infrastructure Program requires a dependable, maintenance-free dial combination lock to support the USMC mission. The Kaba Mas dial combination lock utilizes a proprietary kinetic energy design, which does not require a battery to operate, hence requiring little maintenance for continued operations. Other manufacturers that provide Federal Specification FF-L-2740B-compliant dial combination locks require internal batteries to operate the dial combination lock. These batteries require recurring replacement and most of the batteries are proprietary items furnished through the manufacturer.

The US Marine Corps III Marine Expeditionary Force (IIIMEF) in Okinawa concluded replacement of proprietary batteries to ensure continuous operation of dial combination locks has negatively affected the IIIMEF operational mission. First, the proprietary batteries are not readily available. Second, dial combination locks require training from manufacturers, which is typically conducted at the manufacturer offices - none of which are located in Guam – and is costly to attend. Use of the brand name product will enhance operations by ensuring better serviceability due to familiarity with components, standard maintenance procedures in case of emergencies, and streamlined training for PWD personnel responsible for operations and maintenance.

Obtaining dial combination locks from Kaba-Mas will provide consistency, ease of maintenance and training, avoid significant cost and delay in procuring batteries, and will be more cost-effective long-term for the DPRI Program.

Training Costs:

Multiple component manufacturers create increased operations and maintenance training costs to maintain operability. If DPRI utilizes FF-L-2740B-compliant dial combination locks from multiple manufacturers, PWD personnel responsible for operations and maintenance will be required to learn how to maintain each different system. For each manufacturer, PWD must contract for vendor-provided required annual training of government personnel. The government has estimated an amount of (includes off-island manufacturer trainer) for a single annual training session. Hiring of new PWD personnel may necessitate scheduling additional training during the year. Over the duration of the DPRI Program, estimated to continue until 2040, the required minimal training costs per manufacturer would be .

DESCRIPTION QTY UNIT UNIT COST TOTAL

Annual On Site Training Provided by manufacturer

Total training cost until DPRI Program completion

6. Description Of Efforts Made To Solicit Offers From As Many Offerors As Practicable:

In accordance with FAR 6.302-1, research was conducted via website seeking any and all sources that could provide for FF-L-2740B Dial Combination Locks that incorporate kinetic energy design instead of batteries. Currently, no other manufacturer except Kaba Mass is able to provide FF-L-2740B Dial Combination Locks that meet the USMC DPRI Program security requirements.

On 20 November 2024, an announcement was published on the System for Award Management (SAM) website, in accordance with DFARS 206.302-1 to identify other potential responsible sources of supply that can provide a dial combination lock with equal performance and listing/approval requirements compatible to the Kaba-Mas X-10 dial combination lock. The announcement closed on 5 December 2024 with two (2) responses received:

a) responded that they were an interested vendor. The firm stated that they were working on the requested information and would share it with the Government soon. No further responses were received.

b) provided a Capability Statement and a long term plan to replace locks under the DPRI program with . Based on the information provided, appears to be a construction company, not a lock manufacturer, which proposes to create a distributorship arrangement with .

The model specified however is not self-powered and therefore does not meet the salient characteristics of the Kaba-Mas X-10 dial combination lock.

Based on the market research performed and the responses to the Sources Sought Notice, the Kaba Mas X-10 is the only combination lock that meets the Government's requirements.

7. Determination Of Fair And Reasonable Cost:

The Contracting Officer has determined the anticipated cost to the Government for the Kaba Mas dial combination locks covered by this CJ&A will be fair and reasonable.

8. Actions to Remove Barriers to Future Competition:

For the reasons set forth in Paragraph 5, the government does not intend to compete future contracts for the types of supplies/services covered by this document. The government will continue to monitor the dial combination lock industry to determine if a dial combination lock being self-powered with no batteries to maintain itself becomes available and if another potential source emerges, the government will assess whether competition for future requirements is feasible.