TE 5.18 QASP.docx

TECHNICAL EXHIBIT 5.18

Quality Assurance Surveillance Plan

(QASP)

DLA Aviation Hazardous Materials Management Services

SP3300-11-R-0006

1. Overview This Quality Assurance Surveillance Plan (QASP) has been developed to supplement quality control efforts and provide a framework for performing quality assurance for the DLA Aviation Hazardous Materials Management Services contract within the DLA enterprise. The responsibility for the administration of the contract is the DLA Distribution, Acquisition Operations (J7) and DLA Aviation. This surveillance plan is intended for DLA-wide implementation and is applicable to the DLA Aviation Cherry Point, Jacksonville, and North Island. Additionally, this QASP has been developed to address DLA Accountability Office, Office of Internal Review, findings and recommendations (Audit Report DAO-09-20).

The Hazardous Materials Management Services is issued as a performance-based solicitation as defined in FAR 37.601. A performance-based contract ensures the required performance quality levels are achieved and the total payment is related to the degree services performed or outcomes achieved meet contract standards.

FAR 37.602-2 requires agencies to develop a QASP when acquiring services through performance-based contracts. The QASP recognizes the responsibility of the Contractor to carry out its quality control (QC) obligations and contains measurable inspection and acceptance criteria corresponding to the performance standards contained in the contract. The QASP focuses on the level of performance required rather than the methodology used by the Contractor to achieve that level of performance.

Contract performance incentives, whether positive, negative, or both, are incorporated into performance-based contracts to the maximum extent possible to encourage Contractors to increase efficiency and maximize performance. The specific performance standards in the QASP must correspond to these incentives and must be capable of objective measurement.

The FAR, including Part 46, Quality Assurance, “prescribes policies and procedures to ensure that supplies and services acquired under Government contract conform to the contract’s quality and quantity requirements. Included are inspection, acceptance, warranty, and other measures associated with quality requirements.”

In order to verify fulfillment of the requirements for performance-based contracting, the contract must use measurable performance standards (e.g., in terms of quality, timeliness, and quantity). The COR/ACOR use the QASP as their guide for the verification process. This QASP, complies with the requirements of FAR Parts 37 and 46 and serves as the COR/ACOR’s guide to monitoring Contractor performance in accordance with (IAW) the contract. It is organized into three major headings: Overview and Organization, Principles of Surveillance, and Surveillance Activities for Specific Tasks. The content outline above identifies further subdivisions of these sections. This outline also serves as the Table of Contents. The various headings and page references are hyperlinked to detailed topical discussions in the QASP.

A well implemented quality program includes two essential elements. The Contractor implements their Quality Control/Customer Satisfaction Plan (QC/CSP) through QC inspections of the services they perform IAW with contract requirements. The COR/ACOR performs Quality Assurance (QA) on the Contractor IAW the QASP to ensure acceptable performance is achieved.

1.1 Contract Quality Requirements

The FAR (46.202) identifies four general categories of contract quality requirements, depending on the extent of QA needed by the Government for the acquisition involved:

Contracts for commercial items.

Government reliance on inspection by the Contractor.

Standard inspection requirements.

Higher-level contract quality requirements.

“Standard inspection requirements” is the primary category of inspection required in this contract. As specified in FAR 46.202-3, standard inspection requirements:

Require the Contractor to provide and maintain an inspection system that is acceptable to the Government.

Give the Government the right to make inspections and tests while work is in process.

Require the Contractor to keep complete, and make available to the Government, records of its inspection work.

Responsibilities for Quality Responsibilities for contract QA are defined in FAR Part 46 for the Contracting Office, DLA Distribution J7, DLA Aviation, and the Contractor. Highlights of responsibilities are included in the following sub-paragraphs.

2.1 DLA Distribution J7

· Develops and applies efficient procedures for performing government QA actions under the contract IAW the written direction of the Contracting Officer.

· Performs all actions necessary to verify whether the supplies or services conform to contract quality requirements.

· Develops, tests, and fields automated Quality Management Tool (QMT) to facilitate enterprise-wide collection and reporting of quality related operational information.

· Monitors COR/ACOR work products to ensure non-conformances are identified.

· Establishes the significance of a nonconformance when considering the acceptability of supplies or services which do not meet contract requirements.

· Maintains, as part of the performance records of the contract, suitable records including:

· The nature of Government contract QA actions, including, when appropriate, the number of observations made and the number and types of non-conformances.

· Decisions regarding the acceptability of the products, the processes, and the requirements, as well as actions taken to correct nonconforming items.

· Implements any specific written instructions from the Contracting Officer.

· Recommends any changes necessary to the contract, specifications, instructions, or other requirements that will improve effective operations or eliminate unnecessary costs

· Develops and provides specifications for inspection, testing, and other contract quality requirements essential to ensure the integrity of the supplies or services

· Prescribes contract quality requirements, such as inspection and testing requirements, or, for service contracts, a QASP.

2.2 Contractor

The Contractor is responsible for carrying out its responsibilities under the contract by:

Controlling the quality of supplies or services.

Tendering to the Government for acceptance only those supplies or services which conform to contract requirements.

Ensuring vendors or suppliers of raw materials, parts, components, subassemblies, and others have an acceptable QC system.

Maintaining substantiating evidence, when required by the contract, that the supplies or services conform to contract quality requirements, and furnishing such information to the Government, as required.

The Contractor provides and maintains an inspection system or program for the control of quality that is acceptable to the Government (See QC/CSP requirements in SOW).

The control of quality by the Contractor may relate to, but is not limited to:

Fabrication and delivery of products to ensure only conforming products are tendered to the Government.

Technical documentation, including drawings, specifications, handbooks, manuals and other technical publications.

Procedures and processes for services to ensure services meet contract performance requirements.

Training all appropriate personnel in the purpose, use, and implementation of the QC/CSP.

The Contractor is responsible for performing all inspections and tests required by the contract except those specifically reserved for performance by the Government.

2.3 Contracting Officer’s Representative (COR)/Alternate COR (ACOR) The Contracting Officer’s Representative (COR)/Alternate Contracting Officer’s Representative (ACOR) quality responsibilities include:

· The COR/ACOR has reporting responsibility to the Contracting Officer. The COR is responsible for assuring the QASP is implemented.

Ensure all appropriate personnel attend training in the purpose, use, and implementation of the QASP.

Implement the QASP, to include developing surveillance schedules, performing surveillance, and documenting and reporting results.

Monitor and review the QASP for effectiveness.

Report to the contracting office any non-conformances observed in design or technical requirements including contract quality requirements based on escalation guidance and the Surveillance Action Selection Tool (SAST).

Principles of Surveillance The inspection and acceptance clauses contained within the contract allow the COR/ACOR to implement QA procedures. Other contract clauses require the COR/ACOR to implement a QC/CSP, resulting in the Contractor being responsible for quality control assessments of goods and services produced. The Government is responsible for QA, surveillance, monitoring, and evaluation of the Contractor’s quality performance. This concept, defined in FAR 46.101, says Government contract QA means “the various functions, including inspection, performed by the Government to determine whether a Contractor has fulfilled the contract obligations pertaining to quality and quantity” (emphasis added).

The QASP focuses on corroborating the quality and timeliness of the products and services received from the Contractor and the fulfillment of contract requirements including both APLs and 'non-APLs' – those mandatory requirements commonly referred to as “Contractor Shalls”.

3.1 QASP Implementation and Execution

Successful implementation of the QASP is based upon careful planning and targeted use of the following:

Surveillance planning and scheduling.

Performing surveillance, including complete documentation.

Data analysis of surveillance results.

Reporting the results of surveillance.

The following three objectives are the cornerstones for the COR/ACOR’s daily surveillance activities and remain critical to QASP implementation:

Monitor the Contractor compliance status to established APL and non-APL requirements.

Verify the Contractor’s compliance with their QC/CSP.

Document surveillance observations and findings.

Analyze and report surveillance results to the Contractor and DLA Aviation.

3.2 Surveillance Planning and Scheduling

An annual Surveillance Plan identifies the surveillance activities, frequencies, priorities, and Points of Contact (POCs) for monitoring the Contractor’s performance requirements, and documents the COR/ACOR’s inspection objectives for the year. This plan is created by the COR/ACOR, the DLA Aviation, and the Contracting Officer for acceptance. Based on the accepted annual surveillance plan requirements, the COR/ACOR updates the monthly surveillance schedule in the QMT to identify required monthly surveillance events and frequencies. The COR/ACOR update surveillance records to identify the surveillance activities and results for each surveillance activity performed during the month. The COR/ACOR adjusts the monthly surveillance schedules as required to achieve targeted surveillance objectives. The COR/ACOR incorporates time to validate user complaint items into the surveillance schedule to the extent possible. Key among the COR/ACOR’s responsibilities are scheduling surveillance and tracking, analyzing, and reporting surveillance results.

During all periods of the Contractor’s performance, the COR/ACOR retains a copy of all surveillance schedules, Surveillance Reports (SRs), User Complaint Records (UCRs), and other performance documentation. The COR/ACOR either retains these records or forwards them to the KO at the end of the contract for inclusion in the contract file.

3.3 Quality Checklists

The quality assurance and surveillance relies on using standardized template checklists within QMT to conduct most surveillance activities. These template checklists are designed to document QA activities so that the COR/ACOR and the Contractor can better focus on issues, respond in a timely manner, develop best business practices to improve customer service, and consistently document performance.

The DLA Distribution’s policies and procedures for using checklists and for helping a COR/ACOR implement its QA surveillance responsibilities are in the DLA Distribution Handbook for Oversight of Depot Operations (hereinafter referred to as “the Handbook”).

QA surveillance checklists within the QMT are modified and/or updated as approved modifications or changes are made to performance requirements. Every effort is made to standardize surveillance requirements across the distribution enterprise.

3.4 Documentation

Documentation of the Contractor performance provides, if needed, a legal basis for the Government to make decisions and take action. Informal or anecdotal evidence does not provide sufficient justification to reward (i.e., award/incentive fee) the Contractor or to initiate corrective actions. Properly completed surveillance documentation is objective: it is equally important to document both conforming and nonconforming performance. The vast majority of surveillance generally results in documenting conforming performance. Documentation of nonconforming performance identifies areas where the Contractor’s performance does not meet contract requirements and where re-performance of nonconforming services or corrective action may be needed.

It is critically important the COR/ACOR regularly documents and reports on the Contractor’s performance as required by the surveillance schedules. If there is a pattern of forbearance[footnoteRef:1] or letting substandard performance go without the Government taking action, then the Government may lose its legal right to enforce contract performance provisions. [1: ]

3.5 Modifications

The DLA Distribution J7 Contracting Office and DLA Aviation may unilaterally modify surveillance requirements (i.e., input from the contractor is neither needed nor required). Such modifications are not subject to the modification clauses in the contract and are not grounds for the Contractor to increase the cost of performance. Conversely, bi-lateral modifications involve a negotiated approach and may or may not increase the cost of performance. In either case, modifications or changes to service requirements will be evaluated and changes to the surveillance requirements and/or QA template checklists in the QMT made accordingly by DLA Aviation and DLA Distribution J7 through the changes request process.

While modifications refer to changes in the surveillance requirements, typically driven by contracts operational performance requirements, modifications do not refer to monthly adjustments in surveillance schedules by COR/ACOR personnel or other representatives. The Handbook provides more detailed information on specific roles and responsibilities.

Quality Policies, Procedures, and Helpful Aids The Handbook provides the COR/ACOR with specific policies, procedures, tools, and aids to help implement their QA responsibilities. This paragraph, the Handbook, and the QMT are the key tools and references the COR/ACOR uses to conduct and document its QA surveillance activities.

4.1 The 8-Step Surveillance Process

The 8-Step surveillance process described in the Handbook is the mandated framework outlining the process by which the COR/ACOR will implement all surveillance activities. The 8-Step Surveillance Process is as follows:

Identify the APL/non-APL criteria for surveillance activity.

Review all relevant documentation.

Complete the pre-surveillance sections of the SR.

Conduct surveillance.

Document observations in the post surveillance sections of the SR.

Analyze the results.

Make recommendations and report findings.

File SR, with all supporting documentation.

4.2 Surveillance Methods

The surveillance methods described in the Handbook, apply to surveillance/monitoring of all contract requirements. DLA Distribution J7 has recommended an appropriate method(s) to employ for each requirement. The following is a list of the recognized methods of surveillance:

Direct Observation.

Random Visual Inspection.

Hazardous Materials Management System (HMMS).

One Hundred Percent (100%) Inspection.

Validated Customer Complaints.

Random Sampling.

4.3 Surveillance Tools

Two tools are provided to the COR/ACOR in order to help schedule surveillance activities and enforce Contractor compliance. The tools are described in detail in the Handbook. The tools are also available electronically in the QMT. The following sections describe the purpose of each tool.

4.3.1 Surveillance Method Selection Tool (SMST)

The SMST is used by the COR/ACOR to determine how surveillance should be conducted on a contract requirement. The SMST guides the COR/ACOR through a series of questions about the surveillance activity ranging from whether or not the surveillance activity was scheduled to the significance level of the activity. The SMST recommends a list of surveillance methods that are available to be applied to the surveillance activity.

4.3.2 Surveillance Action Selection Tool (SAST)

The SAST is used by the COR/ACOR to determine the appropriate course of action following the documentation of the Contractor non-compliance. The SAST relies upon surveillance frequency, number of nonconforming surveillance reports, and requirement significance to recommend the appropriate Government course of action. The course of action will range from filling out a nonconforming surveillance report to notifying the KO and suggesting a Contractor Discrepancy Report (CDR).

Surveillance results of chance discoveries will not be used to determine follow-on actions as recommended by the SAST.

Quality Assurance Surveillance Plan

(QASP)

Surveillance Activities for Specific Tasks The following are approaches that the COR/ACOR uses to conduct surveillance activities for specific tasks IAW contract requirements:

5.1 Acceptable Performance Level (APL) Surveillance

5.1.1 APL Category Definitions

APLs are segregated into two categories; timeliness and quality. Distribution functions may have one or both types of APLs associated with them. The following provides definitions for the APL categories:

Timeliness – The APL standard is measured by whether the requirement or function is met in a pre-determined period of time.

Quality – The APL standard is measured by whether the requirement or function meets a pre-determined quality standard.

5.1.2 Monitoring APLs

The DLA Aviation is responsible for providing rationale for significant instances of non-conformance as they track each APL throughout the month. No later than (NLT) the 7th workday of each month, the DLA Aviation will submit a detailed APL report, to the KO, covering conformance/non-conformance for the preceding month. For all non-conformances, a detailed explanation including potential causes for the non-conformance and corrective actions being taken to resolve or mitigate the non-conformance is required.

5.2 Non-APL Surveillance Requirements

The COR/ACOR will conduct surveillance processes utilizing the QMT application. Each functional area has associated surveillance templates and checklists to be used during surveillance events. The COR/ACOR utilizes a Surveillance Report (SR) to record and document individual surveillance events IAW DLA Distribution QMS Policy and COR/ACOR training guidance.

6 Performance Requirement Summary (PRS) The acceptable performance levels (AP) located in TE 5.17, Performance Requirements Summary (PRS), for contractor performance, are structured to allow the contractor to manage how the work is performed while providing negative incentives for performance shortfalls. For six (6) of the APLs, the desired performance level is established at one hundred percent (100%). The other levels of performance are established at percentages less than 100%. All are keyed to the relative importance of the task to the overall mission performance. The Contractor’s performance will be measured by individual site and deductions for non-performance will be withheld IAW Section F of the contract.

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