Sole Source-Brand Name Over SAT (Pallet Rack) (1).pdf
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- Attached to
- Equipment Racks -19CABS
- Solicitation number
- FA446026Q0026
About this file
This is a Sole Source (Including Brand Name) Justification document for simplified procedures on certain commercial items submitted by the 19 Contracting Squadron at Little Rock Air Force Base.
The acquisition covers equipment racks for a warehouse reconfiguration project totaling an estimated contract cost of $201,168.00. The project requires layout of a new warehouse configuration to accommodate installation of 4 additional pallet rack rows to OSHA standards, including labor for installation of new pallet racks, guide rails, and bollards, plus disassembly and reassembly of current pallet racks with floor repair and new anchor installation. The materials requirement specifies welded Husky brand pallet racks in three different height levels (22', 16', and 12'). The justification for sole source procurement centers on safety compliance: mixing pallet rack components from different manufacturers compromises structural integrity and load ratings in violation of OSHA General Duty Clause standards (29 CFR 1910.176(b)) and Rack Manufacturers Institute (RMI) and American National Standards Institute (ANSI) standards. The existing warehouse pallet rack system is Husky brand, and because adjustable shelves will be cross-utilized depending on storage needs, only Husky brand units can be procured to prevent loose connections, unstable frames, and potential catastrophic structural failure. The contracting officer determined the anticipated cost to be fair and reasonable based on independent Government Cost Estimate and vendor quotes. Market research identified multiple distributors of Husky brand racks, and All Storage Products Inc (ASPI) expressed written interest in the acquisition. The requirement is being solicited via SAM.gov. The document was digitally signed by Contracting Officer Kelly, Richard SSgt AMC on October 10, 2026, and requires approval from the Chief of the Contracting Office.
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Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items
CONTROLLED UNCLASSIFIED INFORMATION
April 2021 CONTROLLED UNCLASSIFIED INFORMATION Page 1 of 4April 2021 CONTROLLED UNCLASSIFIED INFORMATION Page 1 of 4
NOTE: If a Justification was approved for the preceding acquisition, a copy of the approved Justification for the predecessor action must be included in the staff package for approval of the instant Justification. This applies to Justification staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor Justification will be used as a reference document by the approving official.
Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )
Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan? Yes No
Funding level for this acquisition: >SAT and < $750K > $750K and < $15M
Contracting Activity: 19 CONS/PKA, 642 THOMAS AVENUE, LITTLE ROCK AFB AR 72099
Purchase Request / Local ID Number: N/A
Program / Project (and PE, if applicable): Equipment Racks - 19CABS
Program Type (PEO or Other Contracting): Other contracting
Authority: AFFARS 5313.501 - 10 U.S.C. 2302b, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901)
AFFARS 5313.501 - 10 U.S.C. 2304a, Special Emergency Procurement Authority (41 U.S.C. 1903)
Estimated Contract Cost (including options): $201.168.00 Justification Type: Class Individual
COORDINATION ( AFFARS 5306.304(a))
Date Project Lead / Program Mgr / Requiring Activity Jeremy Grider, GS-12, DAF
19 LRS/LGRM, (501-987-5040)
jeremy.grider.1@us.af.mil
Signature
Date Contracting Officer Kelly, Richard SSgt AMC
19CABS, 501-987-6807
richard.kelly.32@us.af.mil
Signature
APPROVAL (AFFARS 5306.304(a) )
Date Chief of the Contracting Office (COCO) [ Official Signature Block ]
Signature
Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items
April 2021 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 4April 2021 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 4
I. Contracting Activity.
19 Contracting Squadron
II. Nature and/or description of the action being processed.
1. LAYOUT new warehouse configuration to accommodate the installation of 4 additional Pallet Rack Rows to OSHA standards. 2. LABOR includes installation of new Pallet racks, guide rails, and bollards and the disassembly of current pallet racks, removing anchors, relocating and the reassembly of current pallet racks, relocation of safety guide railing, and bollards. All anchors must be removed and floor repaired as needed and new anchors installed. 3. MATERIALS: Welded HUSKY BRAND (OSHA requirement to match existing system) Pallet Racks. 3 different height levels of pallet racks (22', 16', and 12')
III. Description of supplies/services required to meet agency needs.
SAFETY: Mixing parts voids original manufacturer load ratings and will not meet safety requirements. Catastrophic structural failure of the Pallet Rack system could result from weaknesses created by mixing manufactures and may cause serious injury or death to personnel.
Current Pallet Rack system in place is HUSKY BRAND. Due to safety requirements we must stay with the same type due to adjustable shelves will be cross-utilized depending on size of items stored.
Do Not Mix Brands: Avoid combining parts from different manufacturers within the same bay or upright frame to prevent collapse.
OSHA General Duty Clause OSHA Warehouse and general storage standards 29 CFR 1910.176(b), Warehousing hazards are addressed in specific standards for general industry (29 CFR 1910) Because mixing components from different manufacturers compromises structural integrity and load ratings, OSHA inspectors cite employers for violating these general provisions.
Why Mixing Shelving is an OSHA Hazard
• Mismatched Tolerances: Uprights, beams, and safety pins have slight variances in size between brands. Mixing them creates loose connections and unstable frames.
• Altered Load Capacities: An entire system's weight capacity is determined by its weakest individual part. Mixing parts voids original manufacturer load ratings.
How to Stay Compliant
To ensure your facility is safe and compliant with OSHA's General Duty Clause OSHA Warehouse, you should rely on industry standards set by the Rack Manufacturers Institute (RMI) and the American National Standards Institute (ANSI) Storage rack safety:
These racks will be installed in a location with other racks of the same brand. The nature of these racks is four supporting pylons allowing the horizontal shelving to be placed and removed to support varying sizes of items requiring storage as needed. To refrain from the safety concerns involving mixing of shelving, it is imperative to only accept Husky brand units.
Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items
April 2021 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 4April 2021 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 4
IV. Statutory authority permitting other than full and open competition.
FAR 6.103-1(c) - Supplies and services may be deemed as available from only one source under this authority under the following circumstances—
(1) When an unsolicited research proposal shows a unique and innovative concept (see definition at 2.101) the substance of which is not otherwise available to the Federal Government and does not resemble the substance of a pending competitive acquisition. For DoD, NASA, and the Coast Guard, this authority extends to situations where a source demonstrates a unique capability to provide the particular research services proposed.
(2) When awarding a follow-on contract for the continued development or production of a major system or highly specialized equipment and, for DoD, NASA, and the Coast Guard, for the continued provision of highly specialized services, would result in—
(i) Substantial duplication of cost to the Government that is not expected to be recovered through competition; or
(ii) Unacceptable delays in fulfilling the agency's requirements.
V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).
Is the authorized HUSKY dealer in the Area. any Husky brand item will meet this need and can be competed on SAM or
GSA.
VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.
The requirement is being solicited via SAM.gov
VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.
Based on the independent Government Cost Estimate (IGCE) and the vendor-provided quote, the proposed price is anticipated to be fair and reasonable.
VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.
Additional market research has been conducted to identify sources. More than one distributor of Husky brand racks exist.
IX. Any other facts supporting the use of Other Than Full and Open Competition.
Due to safety requirements we must stay with the same type due to adjustable shelves will be crossed-utilized depending on size of items stored.
X. List of any sources that expressed, in writing, an interest in the acquisition.
All Storage Products Inc (ASPI) expressed,in writing,an interest in the acquisition. Please see market research for additional details.
Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items
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XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.
Will allow sufficient lead time for vendors to prepare and submit offers.
XII. Certification by the Contracting Officer.
As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.
XIII. Certification by the technical/requirements personnel.
As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.
| 2026-07-10T09:54:33-0500 | |
| KELLY.RICHARD.THOMAS.1528102740 |
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