Swagelok Limiting Competition under SAT 6-8-2026_Redacted.pdf

This is a Memorandum for Record documenting a justification for limiting competition at or below the simplified acquisition threshold for a federal purchase order.

The Army Test and Evaluation Command at West Desert Test Center (ATEC-WDTC) Dugway Proving Ground requires 159 line items for various Swagelok brand name fittings through the Mission Installation Contracting Command (MICC) at their Dugway, Utah facility. This is a new procurement using a fixed-price purchase order contract vehicle funded with FY26-27 RTDE funds. The procurement authority is FAR 12.201-1 for commercial acquisitions valued at or below the simplified acquisition threshold, with a brand name limitation on Swagelok products. The contracting officer determined the anticipated price to be fair and reasonable based on competition and historical pricing.

The justification for the brand name restriction centers on Swagelok's unique capabilities in the gas/liquid flow meter and tubing connection industry. The memorandum emphasizes Swagelok's demonstrated performance record in critical applications for Dugway's dissemination equipment, superior safety standards, rigorous testing and certification processes, proven non-leaking hardware record, tailored engineering support for chemical and biological dissemination testing, lower total cost of ownership through durability and reduced maintenance, and enhanced operational efficiency. Market research identified no viable GSA Schedule holders capable of providing all required parts and only one capable small business, precluding a small business set-aside. A 2025 comparison study showed small businesses charged an average 33% markup premium compared to full and open competition with the brand name exception. The acquisition strategy is full and open competition using a brand name exception from an authorized Swagelok dealer. The memorandum is dated June 3, 2026, and signed by Supervisory Chemist Robert A. Rogers and Contracting Officer Paul E. Frailey.