SAT Brand Name - 3M Fall Protection Equipment- FINAL - 08-07-24 (signed).pdf

BRAND NAME JUSTIFICATION FOR

ACQUISITIONS UNDER THE SIMPLIFIED ACQUISITION THRESHOLD

1. The U.S. Army Corps of Engineers, St Paul District proposes to solicit and issue a purchase order based on soliciting for a Brand Name product only manufactured by one source (Federal Acquisition Regulation 13.106-1(b)(1)(i).

2. Contracting activity/agency: U. S. Corps of Engineers, 332 Minnesota St., Ste E1500, St.

Paul, MN 55101

3. Description of Action Being Approved: This action is a Brand Name Justification utilizing simplified acquisition procedures under FAR Part 13.106-1(b)(1), and is restricted to the following source:

Company: 3M Company Address: 3833 Sala Way, Red Wing, MN 55066 Company Point of Contact and Phone Number: Thomas Moore, 651-409-6459

4. Description of supplies or services required to meet agency needs: 3M Fall Protection Equipment System components to include davit hoist systems, personal self-retracting lifelines, retrieval safety harnesses, Y-lanyards for confined space shoulder retrieval, mount davit bases and confined space center mount davit bases.

5. Reason for authority cited:

Currently, the majority (90%) of fall protection equipment on hand and throughout the St Paul District is serviceable and 3M equipment. Maintenance and Repair Section (M&R) and Recreation and Natural Resource Branch (RNR) have the largest usable inventory of fall protection equipment due to their unique mission set. All M&R’s equipment has slowly been transferred to 3M equipment because of the larger inventory, more products to address unique fall protection needs, compatibility between equipment, and increased weight range for use (90-420lbs). M&R and RNR have several davits, winches, and anchor point bases that are used on various projects. Lock and Dams Section (L&D) has a specialized 3M portable anchor point base that was customized by 3M to meet the unique needs of L&D.

Engineering (Structural Section) has also procured exclusively 3M products for interchangeability / compatibility throughout the district due to their field use with Operations Division equipment currently on hand.

Fall Tech and Honeywell (Miller Fall Protection products) vendors offer similar yet smaller fall protection equipment inventory. Like 3M, both vendors equipment can only be interchanged with their own equipment in order to maintain safety ratings unless a competent person can verify compatibility.

Changing over to anther system would require replacing existing serviceable 3M equipment throughout the District and procuring all new equipment to maintain standardization would

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cost the government an additional $122,048 over the estimated cost of $249,000 to procure the required 3M fall protection components. Additional costs savings would be seen from reduced training costs and overall management of the fall protection equipment inventory.

Standardizing equipment reduces training requirements, simplifies overall field use, allows for sharing of equipment when needed and allows for easier management of inventory which reduces labor hours keeping track of all items while also reducing the chance of missing any factory recalls / safety warnings on various equipment.

By utilizing 3M for all fall protection equipment throughout Operations Division, this will allow all sites to have the same equipment and therefore reduce overall training requirements for all employees. Instead of training on the specifics of multiple vendors and having to remember the specifics for each, standardization ensures that every site has the proper knowledge and training to effectively use fall protection systems. Standardization also allows for effective sharing / interchangeability of fall protection equipment when one site needs more than the assigned items. Standardization also allows for easier management of all fall protection equipment in the district in that when there is a safety recall / service bulletin / tech information on specific equipment, it will only be from one vendor and specific types of equipment.

ANSI Z359 permits use of components from different manufacturers providing they perform as intended and the competent person (CP) in fall protection is properly trained to understand the differences in equipment. Due to 3M’s increased weight range (90-420lbs) that is above ANSI standards (130-310lbs), it is possible to utilize the wrong equipment that is not rated for each component without careful consideration. To reduce this safety concern, standardization of all fall protection equipment to (1) brand that is rated to all operate efficiently and effectively at the desired weight range (90-420lbs) as intended is vital.

Additionally, standardization reduces the amount of end user training that is required compared to utilizing multiple brands of varying capacities.

The specific characteristics of the 3M Fall Protection Components that limit the availability to a brand name is that the existing fall protection systems in use by the St. Paul District Corps of Engineers are manufactured by 3M and only 3M Fall Protection components are approved by the manufacturer to be interchanged within their fall protection system.

Only this suggested source can furnish the requirements, to the exclusion of other sources, because they are the only manufacturer of components that preserve the fall protection rating of the entire fall protection system.

6. Rationale:

a. Check and fill in all that are applicable:

The material or service must be compatible in all aspects (form, fit, and function) with existing systems presently installed. The current equipment is 3M Fall Protection System Components, and the new item/service must coordinate, connect, or interface with the existing system by being manufactured by 3M and approved as a fall protection system

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component by 3M.

A patent, copyright, proprietary data, or licensing agreement limits competition. The proprietary data are described as follows:

These are "direct replacement" parts/components for existing equipment.

Other information to support a Brand Name buy:

7. Efforts to Obtain Competition: Market research conducted by USACE revealed these items are available in the commercial marketplace as more than three vendors provided capability of providing these items. There is full expectation that adequate price competition will be received in response to a request for quotes.

CERTIFICATION

I certify that statements checked and information provided above are complete and correct to the best of my knowledge. In accordance with FAR 13.106-1(b)(1). The facts of this acquisition preclude the use of full and open competition.

<Insert Name> Date Project Officer

<Insert Name> Date Contracting Officer