Sole Source Justification - SSMD - CO Signed.pdf

PURCHASE REQUEST NO.: F2MT026188A001

MEMORANDUM FOR RECORD

FOR

SOLE SOURCE JUSTIFICATION

Data Security, Inc. SSMD-2mm Solid State Media Disintegrator

Company Name: Data Security, Inc.

Street Number/Box Number: 300 S. 7th Street

City, State, Zip Code: Lincoln, NE 68508

Cage Code: 0B8L1

1. Description of action being approved: The 433d Force Support Squadron Communications

Flight (433 FSS/SCO) at Bldg. 817, 312 Oscar Westover Rd., JBSA-Lackland, San Antonio, Texas 78236, requires the procurement and delivery of one (1) Data Security, Inc. SSMD-2mm

Solid State Media Disintegrator (Manufacturer Part Number: 972-0001). The Contractor shall provide all equipment, tools, and associated freight/shipping necessary to deliver the

SSMD-2mm to the destination. The disintegrator will reside within the unit's configuration and issue warehouse to perform secure physical destruction of Controlled Unclassified

Information (CUI) on solid-state drives (SSDs), USB drives, smartphones, tablets, and

SIM/smart cards during upcoming life-cycle technology refreshes.

2. Statute and/or Regulation supporting determination: Pursuant to Revolutionary Federal

Acquisition Regulation Overhaul (RFO) 8.103, RFO 8.104 and RFO 538.7104-3(a)

Federal Supply Schedule Ordering Procedures; allows for restricting competition for acquisitions at or below the SAT with this document justifying the use of a sole source specification. This justification is based on a review of the acquisition history, an assessment of government risk, and a determination of the most logical and suitable solution that serves the best interest of the government.

a. Agency and Nature/Description of the action being approved: The 433 FSS/SCO requires the purchase and delivery of a Solid-State Media Disintegrator (SSMD-2mm) in accordance with NSA/CSS 9-12 Storage Device Sanitization and Destruction guidelines. The equipment will be housed and operated within the 433 FSS configuration and issue warehouse located at Building 817, JBSA-Lackland, TX 78236.

The disintegrator must be listed on the National Security Agency (NSA) Evaluated

Products List (EPL) for Solid State Destruction Devices to ensure complete compliance with DoD and Air Force security regulations for proper CUI media disposal.

b. Description of supplies/services required to meet agency needs: The Data Security, Inc. SSMD-2mm is a commercial-off-the-shelf (COTS) dual-stage physical disintegration system designed to reduce solid-state storage media to a final waste particle size of 2mm x 2mm or smaller. Traditional magnetic degaussers and standard mechanical paper shredders are entirely ineffective against solid-state media because data is stored on high-density silicon microchips rather than magnetic platters. To satisfy the strict security mandates of NSA/CSS 9-12, the unit must physically disintegrate solid-state form factors down to a microscopic level so that the silicon memory dies are destroyed beyond recovery. The Data Security, Inc. SSMD-2mm is the brand-name requirement that satisfies these rigorous technical destruction capabilities while conforming to existing JBSA warehouse facility constraints.

3. Rationale: The activity's unique facility, electrical, and security parameters restrict acceptable solutions solely to Data Security, Inc. SSMD-2mm based on the following technical justifications:

a. Physical Mobility and Space Constraints: The SSMD-2mm is built on heavy-duty casters and has a compact physical footprint (27.5” L x 42.5” W) designed to pass through standard 36-inch-wide office and warehouse doorways. This physical mobility is critical to allow operators to move the device between secure configuration rooms and warehouse storage areas as needed (Attach 8).

b. Standalone Operational Design: The SSMD-2mm is a completely standalone physical destruction device with no network, cellular, or IT connectivity requirements.

It will not touch the Air Force network, which completely negates the need for

CIPS/Communications Squadron coordination or cybersecurity accreditations (Attach

7-9)

c. Facility Electrical Infrastructure Constraints: As certified by the Facility Manager, the 433 FSS configuration warehouse operates on standard facility electrical configurations and has one dedicated 220/240V 20 AMP outlet. The Data Security, Inc. SSMD-2mm (200-240V, 1 phase, 6A) operates safely on a standard 220V / 20

Amp circuit. Other commercial high-throughput disintegrators on the NSA EPL (such as the Kobra SSD and MX-10 requires 200-240V, 3-Phase, 30 Amps) require industrial-grade high-voltage electrical setups. Procuring an alternative system would require a Civil Engineering Form 332 (TRIREGA) coordination and costly electrical facility remediation (Attach 1 and 8).

d. Cost Duplication Avoidance: Selecting any other brand of solid-state disintegrator would result in an immediate duplication of costs (exceeding $15,000 in facility electrical and structural upgrades) and significant delays in the technology refresh timeline (Attach 1.)

4. Efforts to Obtain Competition: To maximize competition for this sole source requirement, market research was conducted by analyzing published commercial catalogs, internet pricing, GSA Federal Supply Schedules (MAS), a SAM.gov Sources Sought posting, and a Request for Information to Data Security, Inc. regarding potential authorized resellers. In accordance with RFO 8.103, mandatory Government supply sources— including AbilityOne and Federal Prison Industries (FPI/UNICOR)—were evaluated and determined to be unable to satisfy the technical requirements or physical/electrical parameters of this acquisition (Refer to File Element 143 - Market Research Report and

Attachments 13–14). Because technical specifications and facility constraints restrict the purchase to the Data Security, Inc. SSMD-2mm, and in accordance with RFO 538.7104-

3(a) and RFO 8.104, the Government will fulfill this sole-source requirement by placing an order directly off of GSA Advantage to the vendor Data Security, Inc. (Attach 13–17).

5. Determination of Fair and Reasonable Cost: The CO anticipates that the resulting price for the vendor Data Security, Inc., SSMD-2mm will be fair and reasonable. This determination is based on the Independent Government Cost Estimate (Attach 5-6), current

GSA Advantage Pricing (Attach 2-4) and a comparison CPI Report of an identical product being procured on a previous contract. This determination is documented on the contract folders price fair and reasonable memo (Attach 10-12).

6. Action taken to Preclude Future Brand Name Awards: To preclude the need for future sole source restrictions, the 502 CONS and the requiring activity will continuously monitor the commercial marketplace for emerging solid-state media sanitization and destruction technologies. Prior to subsequent acquisitions, the team will conduct updated market research to determine if other manufacturers have developed non-proprietary or alternative open-architecture disintegrators that meet the NSA EPL-SS 2mm standard, operate on standard 220V / 20 Amp power, and conform to the physical footprint and mobility constraints of the unit's warehouse facility without causing a substantial duplication of costs. Until such compatible alternatives become available, the Government will directly solicit the requirement with the vendor Data Security, Inc.

7. Contracting Officer’s Cerification that the Justification is accurate and complete: As determined by my acquisition approach following procedures outlined in RFO 8.103, RFO

8.104, and RFO 538.7104-3(a), an order will be issued directly off GSA Advantage to Data

Security, Inc. My signature below certifies that the justification is accurate and complete to the best of my knowledge and belief.

CHRISTOPHER MAIER, GS-12, DAF

Contracting Officer

List of Attachments

1. Gen AI Electrical Price Analysis

2. Data Security

3. Kobra

4. MX-10

5. 3 Quotes with shipping

6. IGCE MFR

7. NSA EPL Solid State Sanitization

8. NSA Solid State Comparison Chart

9. NSA CSS 9-12 Storage Device Manual

10. SSMD - CPI Report - FA301619FA503

11. SSMD - CPI Report - FA301623F0533

12. Price FR SSMD - 2mm

13. AbilityOne Confirmation

14. FPI UNICOR confirmation

15. Sources Sought Post on SAM

16. MFR - Sources Sought Findings - FA301626Q0232

17. Data Security, Inc confirmed no authorized resellers email