PWS - Vessel Loading and Unloading Observation Program (VLUO).pdf

Vessel Loading and Unloading Observation Program (VLUO)

PERFORMANCE WORK STATEMENT

1. General: This is a Performance Based service contract to provide Food Aid Loading Observations and Surveys. The Government shall not exercise any supervision or control over the contract service providers performing the services herein. Such contract service providers shall be accountable solely to the Contractor who, in turn is responsible to the Government.

1.1 Description of Services/Introduction: The contractor shall provide all personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other items and non-personal services necessary to perform observation loading domestically and surveys globally as defined in this Performance Work Statement. Any items not specifically noted, but necessary for performance in accordance with accepted industry standards, shall be furnished under this contract. The contractor shall meet the standards in this contract.

1.2 Background: The Agricultural Marketing Services (AMS) procures staple foods for international food aid programs administered by the responsible agency. These foods, purchased in bulk and packaged forms, are transported overseas by ocean carriers to discharge ports or inland destinations for delivery to Non-Governmental Organizations (NGOs), Private Voluntary Organizations (PVOs), or foreign governments. Due to the nature of long-distance transport, there is a potential for loss or damage. Marine cargo surveys are performed for each food aid shipment during unloading at the foreign destination to address this risk. Products subject to survey include dry staple foods (e.g., rice, peas, beans, lentils), dry blended foods (e.g., wheat-soy blend, corn-soy blend), and vegetable oil products. Packaging typically ranges from 25-50 kg of polypropylene or paper bags, cardboard cartons, 20-liter liquid pails, 6/4-liter containers, and 208-liter drums. Bulk grain and oil cargoes such as wheat, corn, soybeans, soybean meal, and vegetable oil may also be shipped. Shipments occur via containerized, breakbulk, or bulk methods, either port-to-port or on through bills of lading to inland locations.

1.3 Objective: The purpose of the CONUS Vessel Loading and Unloading Observation (VLUO) service is to ensure that all observed cargo lots are loaded onto vessels in a clean and wholesome condition, free from infestation or contamination, and packaged in sound, clean containers. This provides an added measure of security, ensuring the delivery of clean, sound commodities to overseas recipients. The objective is to minimize damaged commodities loaded, enhance the perception of U.S. agricultural commodities, and protect the integrity of foreign food assistance programs. Cargo handling improves under observation, and damages from the dock, port shed, truck, or rail car to the barge, container, or vessel hold are documented and corrected or removed by contractor.

The purpose of the OCONUS Vessel Loading and Unloading Observation (VLUO) service is to address risks inherent with shipping U.S. food aid to overseas destinations, witness, and examine food cargoes, document the count and condition of these food aid shipments and activities related to disposition, and provide a written report. The survey reports issued by the contractors will be used by the Government to fix responsibility for loss and damage to the food aid.

1.4 Scope:

1.5 Period of Performance: The period of performance shall be for a five-year ordering period, for a total contract performance period of five (5) years. The Period of Performance reads as follows:

Base Year: October 1, 2025 – January 31, 20266

Ordering Period 1: February 1, 2026 – January 31, 2027

Ordering Period 2: February 1, 2027 – January 31, 2028

Ordering Period 3: February 1, 2028 – January 31, 2029

Ordering Period 4: February 1, 2029– January 31, 2030

1.7 Quality Control: The contractor shall develop and maintain an effective quality control program to ensure services are performed in accordance with this PWS. The contractor shall develop and implement procedures to identify, prevent, and ensure non-recurrence of defective services. The contractor’s quality control program is the means by which he assures himself that his work complies with the requirement of the contract.

Submit the Quality Control Plan (QCP) with the contractor’s proposal as it will be used as an evaluation criteria for the final award. Three copies of a comprehensive written QCP shall be submitted to the CO and COR within 5 working days when changes are made thereafter. After acceptance of the quality control plan the contractor shall receive the contracting officer’s acceptance in writing of any proposed change to his QCP system.

The contractor shall establish and maintain a QCP to ensure the work performed conforms to the contract requirements. The Performance Requirements Summary establishes performance standards that are the minimum requirements for acceptable performance of required services. The contractor’s QCP shall address methods for remedying poor performance. The Contractor shall develop QCP and submit with proposal package. The Contractor’s QCP includes:

Required services identified in Performance Requirements; brief summary Contractor’s surveillance methodology (methods, principles, and rules for monitoring workers)

Method and timeframe for responding to COR or customer complaints Progress meetings with government stakeholders

1.8 Recognized Holidays: Contractor may have to perform scheduled services on holidays. Contractor must get permission from the COR if work proceeds on the one of these days.

New Year’s Day Labor Day Martin Luther King Jr.’s Birthday Columbus Day President’s Day Veteran’s Day Memorial Day Juneteenth Day Thanksgiving Day Independence Day Christmas Day

1.9 Hours of Operation: The contractor is responsible for conducting services 24 hours a day. The Contractor must at all times maintain an adequate workforce for the uninterrupted performance of all tasks defined within this PWS when the Government facility is not closed for the above reasons. When hiring personnel, the Contractor shall keep in mind that the stability and continuity of the workforce are essential.

1.10 Place of Performance: Reserved

1.11 Type of Contract: The government will award a firm fixed price contract.

Contractor to invoice monthly.

1.12 Physical Security: The contractor shall be responsible for safeguarding all government furnished property provided to the contractor. In addition, the contractor shall be responsible for safeguarding commodities through observation, inspection, and reporting as outlined in this PWS.

1.13 Loss or Damage: Contractor shall be responsible for all damages to persons or properties that occur as a result of a Contractor’s fault or negligence. The Contractor shall take proper health and safety precautions to protect the work, workers, the public and property of others.

Contractor shall repair or replace any portion of building structure, or landscape features, damaged by the Contractor in the performance of this contract. Such damaged areas or materials shall be restored, repaired or replaced by the Contractor to original condition and to satisfaction and as directed by the COR at no expense to the Government.

The Contractor shall be insured in accordance with District of Columbia insurance regulations. The Government is not responsible for damage to Contractor’s equipment, vehicles, tools or materials or their employees and the personal property brought on-site. The Government will not accept any liability due to contractor employee negligence.

Workers Compensation: The contractor shall furnish proof of workers compensation insurance to the Contracting Officer for those employees performing work related to this contract and shall comply with the Workman’s Compensation Laws.

Liability: The Contractor shall maintain a level of insurance that will protect the contractor and the Government from any claims as a result of bodily injury (including death) and property damage which may arise from and during the performance of this contract, and shall submit proof of insurance to the Contracting Officer.

1.14 Special Work Considerations: The contractor may be required to work at locations with heightened security protocols. Contractors shall follow all facility security procedures at task order performance locations.

1.15 Special Qualifications: All workers shall be recognizable as employees of the contractor by wearing distinctive clothing bearing the name of the company or by wearing appropriate badges which show the Contractor's company name and employee name. All equipment must meet all federal OSHA, state and local safety requirements and must be properly licensed. The name or logo of the contractor’s company shall be clearly displayed on all equipment used on the job.

1.16 Post Award Conference/Periodic Progress Meetings: The Contractor agrees to attend any post award conference convened by the contracting activity or contract administration office in accordance with Federal Acquisition Regulation Subpart 42.5.

The contracting officer, Contracting Officers Representative (COR), and other Government personnel, as appropriate, may meet periodically with the contractor to review the contractor's performance. At these meetings the contracting officer will apprise the contractor of how the government views the contractor's performance and the contractor will apprise the Government of problems, if any, being experienced.

Appropriate action shall be taken to resolve outstanding issues. These meetings shall be at no additional cost to the government.

1.17 Contracting Officer Representative (COR): The (COR) will be identified by separate letter. The COR monitors all technical aspects of the contract and assists in contract administration The COR is authorized to perform the following functions: assure that the Contractor performs the technical requirements of the contract: perform inspections necessary in connection with contract performance: maintain written and oral communications with the Contractor concerning technical aspects of the contract:

issue written interpretations of technical requirements, including Government drawings, designs, specifications: monitor Contractor's performance and notifies both the

Contracting Officer and Contractor of any deficiencies; coordinate availability of government furnished property, and provide site entry of Contractor personnel. A letter of designation issued to the COR, a copy of which is sent to the Contractor, states the responsibilities and limitations of the COR, especially with regard to changes in cost or price, estimates or changes in delivery dates. The COR is not authorized to change any of the terms and conditions of the resulting order.

1.18 Key Personnel: The following personnel are considered key personnel by the government: Contract manager and Alternate contract manager, The contractor shall provide a contract manager who shall be responsible for the performance of the work.

The name of this person and an alternate who shall act for the contractor when the manager is absent shall be designated in writing to the contracting officer. The contract manager or alternate shall have full authority to act for the contractor on all contract matters relating to daily operation of this contract. The contract manager or alternate shall be available between 8:00 a.m. to 4:30p.m central standard time Monday thru Friday except Federal holidays or when the government facility is closed for administrative reasons.

1.18.1 Qualifications for all key personnel: [Insert the qualifications for all key personnel, Contract Manager and Alternate, The Contract Manager and Alternate must have 24 semester hours in mathematical, engineering, and/or quantitative analysis courses; 15 or more years cost analysis experience; and familiarity with Defense Department Data Sources (e.g. cost and software data reporting, EVM, Minimum of Bachelor’s Degree in Business Administration.] Add note for 4 Contractor to inform CO in changes of key personnel. Also, the more qualifications you include, the more restrictive the requirement. Limit the qualifications related to work experiences and not to the number of years or degrees if able to do so.

1.19 Organizational Conflict of Interest: Contractor and subcontractor personnel performing work under this contract may receive, have access to or participate in the development of proprietary or source selection information (e.g., cost or pricing information, budget information or analyses, specifications or work statements, etc.) or perform evaluation services which may create a current or subsequent Organizational Conflict of Interests (OCI) as defined in FAR Subpart 9.5. The Contractor shall notify the Contracting Officer immediately whenever it becomes aware that such access or participation may result in any actual or potential OCI and shall promptly submit a plan to the Contracting Officer to avoid or mitigate any such OCI. The Contractor’s mitigation plan will be determined to be acceptable solely at the discretion of the Contracting Officer and in the event the Contracting Officer unilaterally determines that any such OCI cannot be satisfactorily avoided or mitigated, the Contracting Officer may effect other remedies as he or she deems necessary, including prohibiting the Contractor from participation in subsequent contracted requirements which may be affected by the OCI.

1.20 Phase in/Phase out Period: To minimize any decreases in productivity and to prevent possible negative impacts on additional services, the Contractor shall on board personnel in a timely manner. The phase in period will consist of a 60 day on board period where the Contractor shall become familiar with performance requirements in order to commence full performance of services. Key Personnel shall be in place within 14 days after contract award, transition sufficient for USDA to issue task orders within the continental United States must be completed within 30 days, and full transition of the contractor for all task orders must be completed within 60 days. The Contractor shall additionally facilitate a phase out period within 30 days of contract completion.

2. PERFORMANCE REQUIREMENTS

2.1. General Requirements

2.1.1. The contractor shall attend and report on all food aid deliveries to the country covered by the contract.

2.1.2. The contractor shall serve as the Government’s representative at the loading location, working with the port/terminal, ocean carrier, freight forwarder, and/or the cargo owner’s representative to promptly identify, document, and communicate any deficiencies observed.

2.1.3. The contractor shall notify the COR within 2 hours by telephone or email in the event of detrimental or unsanitary conditions unacceptable for loading, including barge interiors. Examples include bags or cartons contaminated with hydraulic fluid, water, paint, grease, rodent or bird droppings, dust, dirt, or inferior packaging. Laboratory analysis may be required to detect possible contamination, including microbiological and chemical testing, as well as assessment of moisture content and fitness for human consumption.

2.1.4. The contractor shall notify the COR within 2 hours by telephone or email of any commingling of bags/cartons with different markings, identified by Commodity Purchase Order number.

2.1.5. If rodent excrement contamination is found, black lighting may be required for loaded and remaining commodities to determine the extent of contamination.

2.1.6. The contractor shall issue a letter of protest to the ocean carrier when directed by the Contracting Officer (CO) or Contracting Officer Representative (COR). Digital photographs documenting discrepancies must be emailed to the CO or COR within 2 hours if a protest letter is issued.

2.1.7. The contractor shall provide certification of witnessing the entire vessel/barge loading process by signing and submitting Form KC-44. False accreditation will result in contract termination and may lead to potential suspension or debarment.

2.1.8. The contractor shall observe the condition of the hold(s) or containers before, during, and after loading, recording observations, and noting any deficiencies on the worksheet. Deficiencies of other previously loaded government cargo, such as leaking vegetable oil cans or spilled cargo, must also be recorded.

2.1.9. The contractor shall verify the correct container markings and document the findings on the worksheet. If incorrect markings are found, digital pictures must be taken immediately, and the issue reported to the ocean carrier representative and COR within 2 hours.

2.1.10. The contractor shall report any deficiencies found to the ocean carrier representative within 2 hours. If the ocean carrier representative is unresponsive or unavailable, the contractor shall report this to the applicable freight forwarder and COR within 2 hours, documenting the situation on the worksheet.

2.1.11. If severe detrimental conditions are found, digital pictures must be taken immediately, findings documented, and reported to the ocean carrier representative and COR within 2 hours.

2.1.12. The contractor shall issue a letter of protest to the ocean carrier as directed by the COR. A copy of the letter, worksheet, and certificate must be provided to the appropriate freight forwarder and the COR.

2.1.13. If desiccants are required for containers with bagged beans and whole grain corn shipped to certain countries, the contractor shall observe and report their application on the KC-41. The COR must be informed by telephone or email within 2 hours if the desiccant application does not conform to protocol.

2.1.14. The worksheet must include all uncorrected deficiencies and the number of units involved.

2.1.15. The ocean carrier representative’s/loading stevedore’s signature is required after each day’s loading to confirm the number of bags/cartons not loaded (including damaged ones removed) and the total number of damaged packages loaded and not removed. All efforts should be made by the carrier to remove damaged commodities.

The COR must be notified within two hours if the ocean carrier fails to remove damaged commodities.

2.1.16. The ocean carrier representative’s signature is required after loading completion.

2.1.17. The location of containers placed in barges must be noted.

2.1.18. If a vessel stops loading food-aid cargo to load other cargo and then resumes food-aid loading, the hold condition must be checked before resumption.

2.1.19. If subsequent loading appears to have damaged previously inspected cargo, a statement to that effect, with digital photos, must be included in the report and sent to the COR via email within 2 hours.

2.1.20. If the effect of loading on previously loaded cargo cannot be determined, a statement must be included in the report indicating that cargo not requiring inspection was loaded on top of previously inspected cargo.

2.1.21. If no damage appears, certify observation results on the appropriate VLUO Certificate (KC-44) using information from KC-41 or KC-43.

2.1.22. The contractor shall distribute Forms KC-41, KC-43, and KC-44 within 24 hours of loading completion to the ocean carrier or its agent, the applicable freight forwarder, and the COR. The template must be uploaded into WBSCM, with forms attached if applicable.

2.1.23. Completion of VLUO for all applicable purchase order line items must be uploaded and forwarded to the COR via email, including the cost per unit, certificate cost, invoice number, commodity PO number, line-item number, and containerization confirmation.

2.1.24. The contractor shall witness and record that steamship lines handle damaged commodities according to EOD-110 guidance and procedures. Recouped commodities are not considered recouped unless the contractor has seen the process and certified compliance with EOD-110. If the commodity is recouped without a VLUO inspector witness, it will be reported as damaged/not loaded on the appropriate KC-41/44.

2.2. Task Orders

2.2.1. Task orders will be issued electronically, with the Government reserving the right to issue them orally if necessary.

2.2.2. A task order will be issued for each originating vessel/voyage with the exact discharge/ETA, and a survey will be required for every Ocean Bill of Lading (OBL).

2.2.3. Multiple surveys may be required per task order. The minimum time between task order issuance and survey shall be 24 hours.

2.2.4. Each task order will contain one type of conveyance (bulk, breakbulk, or containerized) and one booking type (e.g., through bill of lading, discharge only, devan at port).

2.2.5. Price for each task order is based on the total quantity (number of containers or MT) for the entire order.

2.2.6. Once cargo has been lifted from the U.S. port, the Government will provide the contractor with a task order detailing the cargo to be surveyed, including:

Vessel Conveyance type Booking terms Destination Commodity Estimated time of arrival Ocean bill of lading Tonnage

2.3. Reporting Requirements

2.3.1. For each ocean bill of lading, the contractor shall provide a written survey report and supporting documentation, in English or with translation, with sufficient detail to fix responsibility for losses occurring while cargo is under the care, custody, and control of the steamship company.

All portions of the report must be sent as original documents.

A copy of the report should be sent to the receiver.

The contractor shall attend the loading of vessels, barges, and/or containers, documenting observations using Forms KC-41 (Container/Barge Observation Worksheet), KC-43 (Breakbulk Vessel Observation Worksheet), and KC-44 (Breakbulk Vessel Loading Observation Certificate), and the Web Based Supply Chain Management (WBSCM) application. The Government uses WBSCM for tracking shipments.

VLUO loss and damage data will be captured in WBSCM via data entry or an Excel template.

The contractor shall state damage occurring during vessel/container/barge loading on the KC-41 or KC-43, as appropriate. Details of damage/shortage and probable causes must be provided.

2.3.2. Any discrepancies in the general condition of cargo observed before loading must be reported in the remarks section of the KC-41 or KC-43. Any letter of protest and digital photos must be included and sent via email within 2 hours to the COR.

2.3.3. Observations of commodity loading must utilize Form KC-41 or KC-43 and WBSCM as appropriate.

2.4. Place of Performance

2.4.1. Task Orders will be issued when shipment information is made available by the State Department.

2.4.2. Shipments where title transfers at the discharge port will be awarded under the discharge port country survey contract.

2.4.3. Shipments considered by USDA on a through bill of lading, requiring attendance at both the discharge port and inland location(s), will be awarded under the survey country contract of the inland area.

2.4.4. All attendance requirements and locations will be listed in the task order.

2.4.5. The contractor may be required to perform multiple task orders simultaneously at numerous locations.

2.4.6. The contractor will attend the discharge and delivery of all food aid cargoes covered by this contract, including the discharge port (which may be in a different country than the contract country) and applicable delivery location(s).

2.4.7. For port-to-port bills of lading, surveys must be performed at the quay, warehouse, or container place of rest as determined by the booking note/charter party or port allowance.

2.4.8. Additional attendance may be required at other locations based on shipment type:

2.4.9. Containerized Shipments: Surveys are also required at customs locations where containers are opened, the discharge port, and the final destination(s) for through bill-of-lading shipments.

2.4.10. Breakbulk Shipments: For through bill-of-lading shipments, surveys are also required at the loading point of land conveyance and the ultimate destination(s).

2.4.11. Bulk Shipments:

For bulk shipments requiring bagging, surveys are also needed for the bagging operation location, loading of land conveyance, and final destination(s) for through bill-of-lading shipments.

For bulk shipments requiring a draft survey, additional performance may be necessary onboard the mother vessel and lightering vessel(s).

2.5. Ancillary Services

2.5.1. Under certain circumstances, AMS may require ancillary services. Examples include commodity black lighting in port warehouses following rodent contamination discovery, or a full load count of a containerized shipment for verification.

2.5.2. Additional examples to mitigate damages include secondary observation of vessel loading and/or containerization.

2.6. Observation Procedures

2.61. Minimum Observers:

2.61.1. Containers/Railcars/Barge: 1 observer for every container or railcar/barge being loaded.

2.61.2. Breakbulk-Conventional Loaded: 1 observer for each hold on the ship and one observer on the ground.

2.62. Upon arrival at the loading berth or terminal, the observer shall notify the vessel and stevedoring representatives of the Government's request for loading observation.

2.63. The individual designated by the ocean carrier to address deficiencies must be located. If no representative is provided, contact the applicable freight forwarder and record this information on the worksheet.

2.64. Conduct a visual observation of the general condition of the cargo to be loaded, where it is at rest in the port warehouse, conveyance, or on the dock. This procedure should be repeated daily before loading begins.

PART 2

DEFINITIONS & ACRONYMS

(This section includes all appropriate terms and phrases for this PWS. The definition must be clear and concise, not ambiguous. Carefully consider each definition because they will be binding for the duration of this contract, unless modified. In addition, include a complete listing of all acronyms and words or phrases they represent.)

DEFINITIONS AND ACRONYMS:

DEFINITIONS: [List any terms used within the PWS that require further definition. At a minimum, insert the definitions provided below.]

CONTRACTOR. A supplier or vendor having a contract to provide specific supplies or service to the government. The term used in this contract refers to the prime.

CONTRACTING OFFICER. A person with authority to enter into, administer, and or terminate contracts, and make related determinations and findings on behalf of the government. Note: The only individual who can legally bind the government.

CONTRACTING OFFICER'S REPRESENTATIVE (COR). An employee of the U.S.

Government appointed by the contracting officer to administer the contract. Such appointment shall be in writing and shall state the scope of authority and limitations.

This individual has authority to provide technical direction to the Contractor as long as that direction is within the scope of the contract, does not constitute a change, and has no funding implications. This individual does NOT have authority to change the terms and conditions of the contract.

DEFECTIVE SERVICE. A service output that does not meet the standard of performance associated with the Performance Work Statement.

DELIVERABLE. Anything that can be physically delivered but may include non-physical things such as meeting minutes.

KEY PERSONNEL. Contractor personnel that are evaluated in a source selection process and that may be required to be used in the performance of a contract by the Key Personnel listed in the PWS. When key personnel are used as an evaluation factor in best value procurement, an offer can be rejected if it does not have a firm commitment from the persons that are listed in the proposal.

PHYSICAL SECURITY. Actions that prevent the loss or damage of Government property.

QUALITY ASSURANCE. The government procedures to verify that services being performed by the Contractor are performed according to acceptable standards.

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP). An organized written document specifying the surveillance methodology to be used for surveillance of contractor performance.

QUALITY CONTROL. All necessary measures taken by the Contractor to assure that the quality of an end product or service shall meet contract requirements.

SUBCONTRACTOR. One that enters into a contract with a prime contractor. The Government does not have privity of contract with the subcontractor.

WORK DAY. The number of hours per day the Contractor provides services in accordance with the contract.

2.7 WORK WEEK. Is defined as Monday through Friday, unless specified otherwise.

ACRONYMS: [List all acronyms used in the PWS and what they represent. At a minimum, insert the acronyms provided below.]

CONUS Continental United States (excludes Alaska and Hawaii)

COR Contracting Officer Representative

FAR Federal Acquisition Regulation

OCI Organizational Conflict of Interest

ODC Other Direct Costs

PIPO Phase In/Phase Out

POC Point of Contact

PRS Performance Requirements Summary

PWS Performance Work Statement

SOW Statement of Work

QA Quality Assurance

QAP Quality Assurance Program

QASP Quality Assurance Surveillance Plan

QC Quality Control

QCP Quality Control Program

TE Technical Exhibit

PART 3

CONTRACTOR FURNISHED ITEMS AND SERVICES

(This section is used to identify the materials and equipment that the contractor must provide. Exaples provided below.)

3. CONTRACTOR FURNISHED ITEMS AND RESPONSIBILITIES:

General (If applicable): The Contractor shall furnish all supplies, equipment, facilities and services required to perform work under this contract that are not listed under Section 3 of this PWS.

TECHNICAL EXHIBIT 1

Performance Requirements Summary (Sample)

The contractor service requirements are summarized into performance objectives that relate directly to mission essential items. The performance threshold briefly describes the minimum acceptable levels of service required for each requirement. These thresholds are critical to mission success.

Performance Objective

(The Service required—usually a shall statement)

Standard Performance Threshold (This is the maximum error rate. It could possibly be “Zero deviation from standard”)

Method of Surveillance

Incentive (Positive and/or Negative)

PRS # 1

The Contractor shall attend the loading of the vessel, barges, and/or containers, and document loss and damage data observations using the form KC-41 or KC-43 and KC-44.

See section 2.1 of the PWS

SOW will provide dates and locations for attendance.

Contractor will need to be at location at time of loading

0% deviation from the standard

COR monitoring

SOW,

paperwork reviewing

Positive:

Continued issuance of Schedules of Work.

PRS # 2

The contractor shall provide a written survey report and supporting documentation, in English or with translation, with sufficient detail and documentation to fix responsibility for losses occurring while cargo is under the care, custody, and control of the steamship company transporting the cargo.

See section 2.2 of the PWS

SOW will provide dates and locations for attendance.

The contractor will need to be at location at time of unloading.

0% deviation from the standard

COR monitoring

SOW,

paperwork reviewing

Positive:

Continued issuance of

PRS #3

The contractor shall use the WBSCM application to submit invoices electronically for payment.

Invoices will need to be uploaded upon completion of

SOW.

0% deviation from the standard

COR monitoring

SOW,

paperwork reviewing

Positive:

Continued issuance of