Attachment_0023_USAF_DRAFT_QASP.pdf

Quality Assurance Surveillance Plan

FOR

Aircraft Maintenance and

SUPPLY

FORT RUCKER, AL

CONTRACT W9124G-17-R-0002

DRAFT

BY ORDER OF THE 23FTS/FORT RUCKER

COMMANDER 23FTS/COR OI 21-101

13 December 2016

Aircraft Maintenance

Fort Rucker Quality Assurance Surveillance Plan (QASP)

AIRCRAFT MAINTENANCE CONTRACT (W9124G-17-R-0002)

COMPLIANCE WITH THIS INSTRUCTION IS MANDATORY

OPR: 23 FTS/CCOR (Mr. R. Bechard) Certified by: 23 FTS/CC (Lt Col J. Grigson) Supersedes: N/A Pages: 27

Distribution: F

This operating instruction implements the requirements of Air Force Instruction 21-101, Aircraft and Equipment Maintenance Management and AFI 21-101/AETC Supplement 1. The surveillance procedures outlined in this instruction are also based on guidance contained in MP5346.103 Contracting Office Responsibilities (COR), MP5301.602-2(d) Designation, Assignment and Responsibilities of a COR, and the requirements and specifications of the Army and AF Performance Work Statements (PWS). It establishes procedures for surveilling the aircraft maintenance contract for the 23d Flying Training Squadron (FTS). This instruction applies to the 23 FTS/COR section, and is designed to provide COR personnel an effective and systematic surveillance method for fairly evaluating the contractor’s performance.

This Instruction will be coordinated via e-mail from the Chief COR to the Functional Commander (FC), Army Contracting Officer (KO) and HQ AETC/A4PM (PM). The FC will sign the final approved version. The approved version will be e-mailed to HQ AETC/A4PM.

SUMMARY OF REVISION:

This instruction is new.

2 23 FTS/COR_OI 21-101_13 December 2016

Section I --- General Information Page

1. Quality Assurance Surveillance Plan (QASP)

1.1 Contractor’s Responsibility

1.2 Environmental Program

1.3 Revisions

1.4 Contract administration

Section II ---Performance Assessment Planning & Preparation

2. Responsibilities

2.1 Contracting Officer (KO)

2.2 Government Program Office (GPO)

2.3 Functional Commander (FC)

2.4 Chief COR

2.5 COR Superintendent

2.6 Contracting Officer’s Representative (COR)

2.7 COR Training

2.8 Surveillance Methods

2.9 Surveillance Schedule Preparation

2.10 Cost Reimbursable Items

2.11 Proposals

2.12 Contractor Support of Mishap Investigations

2.13 USAF Supply Services

Section III --- Performance Assessment

3. Surveillance/Assessment

3.1 Technical Inspections (TI)

3.2 Program Management Inspections (PMI)

3.3 Foreign Object (FO) Inspections

3.4 Other Surveillance Methods

3.5 Performance Assessment Documentation

3.6 Data Integrity (DI) Overview

Section IV --- Performance Assessment Results Analysis

4. Analysis

4.1 Non-conforming Performance

4.2 Analysis Coordination

23 FTS/COR_OI 21-101_13 December 2016 3

Section V --- Performance Assessment Reporting Page

5. Monthly Summary

5.1 Monthly Summary Content

Section VI --- Performance Assessment Follow-up

6. Follow-up Methods

6.1 QC Follow-up

6.2 Aircraft/Equipment Repair Actions

6.3 Training Records

6.4 AETC Form 447 Reports

6.5 Correction Action Request (CAR)

6.6 Request for Information (RFI)

6.7 Memorandum for Record (MFR)

6.8 Quality Review Meeting (QRM)

6.9 Non-conformance

6.10 Follow-up Corrective Action Evaluation

6.11 Final COR Recommendation

6.12 Monthly Summary Reporting

Section VII ---Performance Assessment Report Closure

7. General

7.1 AETC FORM 447 Reports

7.2 Correction Action Requests (CAR)

7.3 Monthly Summary Reporting

Table 3.1 -- Monthly Technical Inspection Requirements

Table 3.2 -- Monthly Program Management Inspection Evaluation Requirements

4 23 FTS/COR_OI 21-101_13 December 2016

Section I ---General Information

1. Quality Assurance Surveillance Plan (QASP). This QASP has been developed to implement AFI 21-101, Aircraft and Equipment Maintenance Management, AFI 21-101/AETC Supplement 1 and the Performance Work Statement (PWS). It is designed to provide an effective and systematic surveillance method for fairly evaluating the contractor performance during the contract period.

1.1. Contractor’s Responsibility. This OI is based on the premise that the contractor, not the government, is responsible for management and Quality Control (QC) actions to meet the terms of the contract. Government COR personnel will evaluate the services the contractor is required to furnish and not the details of how the contractor accomplishes the work.

1.2. Environmental Program. The contractor must comply with all EPA, federal, state, and local laws, rules, and regulations governing the generation, handling, storage, treatment, and disposal of hazardous and toxic materials/waste. CORs will monitor general shop, office and flight line practices; however the environmental program is monitored by the Army Aviation Center Logistics Command (ACLC).

1.2.1. As a minimum, CORs will inspect those areas having the potential of generating hazardous waste during the performance of evaluations. CORs will follow the guidance in the Ft Rucker Hazardous Waste Management Plan, applicable OIs, and the PWS.

1.3. Revisions. Revisions to this OI are the joint responsibility of the Chief COR, COR Superintendent, FC, and the KO. Reassignment of Program Management Inspections, primary and alternate COR names and updating guides and/or review dates does not constitute a revision to this OI.

1.4. Contract Administration. Administration of this contract, W58RGZ-12-C-0123, is the responsibility of HQ AETC/A4PM, Randolph AFB TX.

Section II ---Performance Assessment Planning & Preparation

2. Responsibilities. The Chief COR is responsible for the overall surveillance of the contract, keeping the FC and KO informed of contract conformance /non-conformance, quality of maintenance, significant negative trends, and technical order compliance. CORs will meet periodically to exchange information and discuss items of importance. Topics of discussion may include, but are not limited to, information from staff meetings, noted weak/problem areas, inspector problems, and any reported customer complaints.

2.1. Contracting Officer (KO). This contract is managed by an Army and the Contracting Officer is designated as a “KO”.

2.2. Government Program Office (GPO). Government Program Office (GPO) is HQ AETC/A4PM Program Manager (PM) and appointed government representatives. The GPO

23 FTS/COR_OI 21-101_13 December 2016 5

(including the COR, FC) is an inherently governmental activity. The responsibility of this office is to ensure that contractor performance satisfactorily meets the performance standards documented in the QASP and PWS.

2.3. Functional Commander (FC). The 23 FTS Commander is the FC for the Air Force portion of this contract.

2.3.1. The FC may appoint a Deputy FC through the KO for this contract. If appointed, the Deputy FC will assist the FC with all responsibilities delegated by the FC. Note: for the purposes of this instruction an appointed Deputy FC is synonymous with FC.

2.4. Chief COR. The Chief COR is directly responsible to the FC. The Chief COR ensures contractor performance is surveilled IAW criteria outlined in the PWS and QASP and report findings to the FC and KO. Specifically, the Chief COR will ensure the responsibilities identified in AFI 21-101, Chapter 14, AFI 21-101/AETC Sup 1, MP5301.602-2(d), COR appointment letter, this OI, and those delegated by the FC are met to include the following:

2.4.1. Clarifies issues between COR’s and the contractor concerning the validity of documented discrepancies. In the event issues cannot be resolve at local level; the issue will be forwarded to the FC and/or KO. The KO has final resolution authority.

2.4.2. The Chief COR will develop monthly severance schedule based on the requirements of this OI, PWS and AFI 21-101.

2.4.3. The Chief COR will administer the Army contract incentive fee program according to Attachment 0008AF, Supplementary Incentive Fee Determination Criteria. The incentive fee is a quarterly program divided into 4 three four month rating periods. KO may adjust incentive fee rating periods for contract years with less than 12 full months.

2.4.3.1. The contractor must submit requests for reevaluation or consideration to the COR office within 5 days of an incident/inspection/reject. The Chief COR will coordinate with the GPO and provide a written decision by the 20th day from receipt of request. The GPO decision is final.

2.4.4. At the KO’s request, the Chief COR will assist the KO by reviewing, evaluating, and providing comments and recommendations to contractor proposals. All facets of the proposal, within the technical expertise of the COR, will be evaluated to include number of personnel, skill level of personnel, and man-hours proposed. The format for comments and/or recommendations is the KO’s discretion.

2.4.5. Chief COR may designate a COR Superintendent to assist the Chief COR and/or the FC.

In addition, the COR superintendent may be designated to direct the activities of the COR section and assume the duties of the Chief COR as stated in paragraph 2.4.1.

2.5. COR Superintendent. If designate, the COR Superintendent must be appointed by the FC.

COR Superintendent is directly responsible to the Chief COR and will ensure the complete implementation of AFI 21-101 & AETC Sup 1, MP5301.602-2(d), COR appointment letter and this OI. The COR Superintendent will:

6 23 FTS/COR_OI 21-101_13 December 2016

2.5.1.1. Assist the Chief COR with tasks associated with responsibilities delineated in paragraphs 2.4.1 – 2.4.3

2.5.1.2. Assist the Chief COR with administration of the Army contract incentive fee program.

2.5.1.3. Perform the duties of the Chief COR in his/her absence.

2.5.1.4. Assist the Chief COR, FC and KO with clarification of issues between CORs and the contractor concerning the validity of documented discrepancies.

2.5.1.5. Meet requirements as stated in paragraph 2.6 and 2.7 of this OI.

2.6. Contracting Officer’s Representative (COR). CORs are the "eyes and ears" of the FC and KO relative to the actual application of the contract. However, they are not a quality control function. CORs WILL NOT DIRECT WORK, REACCOMPLISHMENT OF WORK, CHANGE THE CONTRACT, AND/OR FORMALLY INTERPRET THE CONTRACT. The KO is the only person with the authority to direct the contractor in the performance of their duties under the contract and to make interpretations of and changes to the contract. COR responsibilities are detailed in AFI 21-101 chapter 14 and AFI 21-101 AETC Sup 1, MP5301.602-2(d), COR appointment letter and this OI . Individual areas of responsibility are identified in this OI and/or appointment letters.

2.6.1. CORs will maintain technical competency in their functional areas, maintain proficiency in contract surveillance techniques, and assist with formulating the PWS and evaluation guides.

CORs will attain qualification in the appropriate areas before performing evaluations, inspections, or surveillance duties unsupervised. CORs will accomplish contract surveillance by observing and documenting contractor performance and inform the Chief COR, FC, and KO when contractor performance does not meet performance thresholds. All qualifications will be document in Training Business Area (TBA) electronic data base.

2.6.2. CORs will review and brief the contractor leadership and/or QC on previous day COR discovered discrepancies contained in the AETC Form 447 control log. The contractor QC will brief their previous day’s inspection data. This brief will normally take place during the contractor daily production meeting unless mission, manning or personnel availability dictates an alternate time or day. Open discussion is highly encouraged on all discrepancies, concerns, issues and/or comments.

2.6.3. COR Office Duty Hours: Normal duty hours are from 0500-1700; however, early morning and late night shifts will be surveilled on a periodic basis to ensure all contractor “duty hours” are covered during each quarter. NOTE: There may be additional COR coverage on non-duty days and special events when requested/authorized by the 23 FTS/CC or DO.

2.6.4. COR personnel will review contractor Technical Assistance Requests (TAR) for technical accuracy and make appropriate recommendations to the contractor. The contractor will submit the TAR into the AIRCAT system.

23 FTS/COR_OI 21-101_13 December 2016 7

2.7. COR Training. Training will be conducted IAW the COR training plan and consist of the mandatory requirements identified in IAW AFI 21-101 & AETC Sup and requirements locally determined by the KO, FC and Chief COR. Individual training records will be maintained IAW AFI 21-101 & AETC Sup.

2.7.1. Newly assigned CORs must complete Phase I and II training prior to performing surveillance.

2.7.2. The AETC QAE School (Course 393AETC0066-002) will be scheduled for newly assigned COR as soon as possible and must be successfully completed no later than 90 calendar days after assignment to COR duties

2.7.3. On the job training (OJT) will be utilized to the maximum extent necessary to train and qualify CORs in areas outside their career field to ensure all contract requirements are surveyed.

AF, AETC instructions and technical orders will be used to complete on-the-job training (OJT) in areas where the individual COR lacks extensive knowledge. All CORs will maintain currency in primary and alternate functional areas.

2.7.4. All assigned CORs will complete periodic refresher and recurring training as prescribed by AFI 21-101 & AETC Sup. The Chief COR/FC will ensure required TDY funding is projected in the unit budget when required.

2.7.5. As required by the KO, Army nominated CORs will complete training requirements listed in ACC Pam 70-1 prior to being appointed as Army CORs.

2.8. Surveillance Methods. CORs will evaluate contractor performance using the basic periodic surveillance method, augmented with guidance contained in AFI 21-101 AFI 21- 101/AETC Sup I, terms contained in the PWS, contractor’s Quality Management System (QMS)/Quality Control Plan (QCP) and this OI. This method provides periodic evaluation of selected task (services) performed by the contractor. These tasks include actual aircraft/equipment maintenance task (Technical Inspections) and management of organizational work-centers (Program Management Inspection). Minimum task and frequency of evaluations are identified in AFI 21-101, AFI 21-101/AETC Sup I and this OI. Note: Performance Assessment (surveillance) procedures/processes are further addressed in Section III.

2.8.1. Inspections (technical or program management) may be scheduled, unscheduled, or as observed; however, only scheduled inspections may be used to determine or apply a performance rating to the contractor for conforming to the performance thresholds stated in the performance monthly thresholds PWS 3.16.3. Unscheduled/as observed inspections are specific inspections CORs perform outside or above the inspections listed in the schedule. See paragraphs 2.8.1.3 &

3.4.1 for applications.

2.8.1.1. Technical Inspections (TI). Any maintenance task accomplished in accordance with technical guidance (TO, TM, work-card, checklist, etc.) qualifies for COR surveillance under the TI concept. Inspections may be performed while maintenance is being performed (concurrently) or after the fact. CORs perform TIs on all aircraft, engines, support equipment, associated forms documentation and Maintenance Information Systems (MIS). Inspections will be accomplished

8 23 FTS/COR_OI 21-101_13 December 2016 as specified in AFI 21-101, AFI 21-101/AETC Sup 1, this OI, contract and the monthly schedule.

CORs will perform scheduled TIs at the first available opportunity, taking into consideration COR workload, and are responsible for ensuring that the scheduled rated inspections are completed no later than the last day of the month.

2.8.1.2. Program Management Inspection (PMI). PMIs are similar to IG inspections, where CORs assess the contractor’s work centers/areas ability to manage program areas they are contractually responsible for. Minimum PMI surveillance requirements are established in AFI 21-101 & AETC Sup, and this OI. To ensure complete and comprehensive surveillance, each PMI is covered by a work center specific evaluation guide and a general evaluation guide.

2.8.1.2.1. Evaluation Guides (EG). EGs are simply tools for COR use during PMIs and are intended to provide the starting point for a systematic approach when evaluating contractor’s areas of contractual responsibilities. EGs are not all encompassing and PMI’s are not limited to just EG items; all contractual requirements (to include, but not limited to all applicable PWS, AFI, TO, Fort Rucker/Army Regs and contractor’s accepted maintenance instruction requirements) are subject to evaluation and deficiencies will be rated against the respective areas.

EGs will be marked “Area inspected is not limited to the content of Evaluation Guide". Master EGs will be stored on the “I” drive and have documented annual reviews.

2.8.1.2.2. Work center specific EGs and Acceptable Quality Levels (AQL) for PMIs will be developed in accordance with the PWS, AFI 21-101, AFI 21-101/AETC Sup 1, this OI and are included in Table 3.2. Work center specific areas of responsibility will be assigned to CORs by letter and approved by the Chief COR.

2.8.1.2.3. General EG. The general EG contains the minimum requirements listed in AFI 21- 101 and AFI 21-101/AETC Sup 1, and applies to most work centers. They include requirements to regularly, yet randomly, sample supply management aids for evidence of proper supply discipline and effectively monitor compliance with the contractor’s training plan. The General EG also establishes procedures to effectively monitor the contractor’s compliance with federal, state, and local laws as well as DOD and Air Force directives, the installation’s applicable environmental plans and programs and vehicle condition. The General EG will contain those Work Area Inspection Critical Items prescribed by AFI 21-101 and AFI 21-101/AETC Sup 1.

2.8.1.2.4. Changes to EGs. EGs should be considered “living documents” and changes additions and deletions may be accomplished as needed to assist the CORs when preforming surveillance duties. CORs may add personalized comments/notes to the master EGs to assist with evaluations. Sources of material for changes are current directives, The Inspector General (TIG) Briefs, noted weak/problem areas, incoming correspondence, IG reports, accepted responses to AETS Form 447s, etc. The Chief COR will approve all changes to the master OGs.

Updated master copies of guides will be provided to the KO and contractor.

2.8.1.3. As-Observed Inspections. These inspections are considered unscheduled inspections and are not rated. They are discrepancies that are observed by COR and are not part of the specific inspection performed, whether scheduled or unscheduled. They occur when discrepancies or deficiencies are observed or discovered that are not directly associated with another inspection.

As-Observed identified discrepancies do not determine levels of performance of the contractor, but are used to identify an existing concern/problematic issue.

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2.8.1.4. Customer Complaints. This method provides customer feedback (complaints). CORs validate the complaint against contract requirements; valid complaints are routed to the contractor for resolution. These customer complaints become a permanent part of the COR surveillance records.

2.9. Surveillance Schedule Preparation. TI and PMI surveillance will be programmed into a monthly surveillance schedule to meet the minimum inspection requirements established in AFI 21-101, AFI 21-101/AETC Sup 1, and this OI.

2.9.1. Table 3.1 Monthly Technical Inspection Requirements in Attachments 1, and Table 3.2 Monthly Program Management Inspection Evaluation Requirements in Attachments 2 to this OI are the basic requirements for developing the surveillance schedule. Inspections requirements may be adjusted, added to or removed from Attachments 1 & 2 without constituting a revision to this OI. If requirements are added or removed; provide a brief justification for the changes to the FC and KO no later than 30 days prior to the changes taking effect. Update the applicable attachment during the next QASP revision.

2.9.2. Schedule development. The Chief COR is responsible for development and coordination of a monthly surveillance schedule in accordance with time lines specified in AFI 21-101 & AETC Sup and this OI. To minimize schedule deviations; TIs and PMIs will be considered open and will be accomplished in the applicable month and will not have dates entered. A tentative semi-annual schedule for PMIs will be formulated to assess and prevent predictability.

2.9.2.1. Schedule a minimum of 10% of TIs as QC follow-up inspections. QC follow-up TIs will be identified on the monthly surveillance schedule and may be performed concurrently or after the fact. Example: Phase inspection. If the scheduled follow-up TI is not available with the contractor QC, substitute any open scheduled TI to achieve the 10% minimum follow-up requirement. QC TIs may be performed in conjunction with the other scheduled inspections but documented independently.

2.9.2.2. During development of the schedule, contractor functional areas and/or inspections receiving non-conforms ratings in previous surveillance periods, has areas of concerns, problematic/repeat issues or has a continuing record of conforming performance may have surveillance activities adjusted with the approval of the FC and KO. According to AFI 21-101 and AFI 21-101/AETC Sup 1, paragraph 18.10.2 and 18.10.2.1, the Chief COR identifies, through analysis, that contractor performance in a particular function is less than satisfactory, surveillance of that function should be adjusted (increased) commensurate with contractor’s performance and level of risk to the government should the contractor not perform in an conforming manner. Adjustments will be annotated in the monthly surveillance schedule. Note:

It is discouraged to accomplish 100 percent surveillance of any area unless it is a critical safety issue and should not be scheduled for an extended period of time.

2.9.2.3. Final Schedule. The Chief COR will perform a final review of the schedule to ensure it is complete and forward to the FC no later than five duty days prior to the beginning of the period it covers. The FC must review and return the approved schedule to the COR no later than the

24 23 FTS/COR_OI 21-101_13 December 2016 last day of the month preceding the scheduled month. After receipt of approved/signed schedule, a copy will be forwarded to the KO before the start of the surveillance period.

2.9.2.3. Proposed changes to the approved monthly surveillance schedule will be coordinated as they occur, with the Chief COR, FC and forwarded to the KO for review and concurrence.

If approved, manual changes will be made on the signed monthly schedule and will include a brief justification and be addressed in the monthly summaries. Use this process when TCTOs and AETC Special Inspection are issued or aircraft are Transferred/Accepted after the monthly schedule is finalized. This process may also be used to increase surveillance in areas of poor performance or concern after the monthly schedule is finalized and being executed.

2.10. Cost Reimbursable Items. The KO retains authority over cost reimbursable items and generation of required documentation to include the Material Inspection and Receiving report (DD250). At the request of the KO, the Chief COR and COR will conduct appropriate research and validation of contractor claims/vouchers, travel expenses or other cost reimbursable items.

2.11. Contractor Proposals. When tasked by the HQ AETC Program Manager, Chief COR will evaluate all contractor proposals and when required, will formulate a "Government Estimate" for contractor proposal comparison/evaluation. CORs will assist with evaluation of contractor proposals affecting their assigned area. The Chief COR will forward the estimates/evaluations to the FC, KO and Program Manager.

2.12. Contractor Support of Mishap Investigations. The COR will monitor and evaluate the contractor’s compliance with the PWS, AFI 91-204, local requirements, contractor OIs and checklist during mishap investigations. Emphasis will be placed on actions taken during the initial phase of securing aircraft/equipment data. Discrepancies will be recorded on AETC Form 447 as an “As Observed”.

2.13. USAF Supply Services. Government oversight of the supply portion of the PWS, Section 4 is provided by 23 FTS/LGS COR. The supply requirements of the PWS are surveilled under the guidance of an independent OI.

III. Performance Assessment

3. Surveillance/Assessment. According to FAR 52.246-4 Inspection of Services - Fixed-Price. C.

“The Government has the right to inspect and test all services called for by the contract, to the extent practicable, at all times and places during the term of the contract. The Government shall perform inspections and tests in a manner that will not unduly delay the work”. It is essential that CORs accomplish sufficient in-depth inspections in all areas to measure the quality of contractor performance and provide an effective measurement/assessment to ensure overall performance meets contract requirements. Compliance with applicable directives prescribed by the PWS, Host Base regulations, Army PWS, and contractor -developed plans/regulations will be part of the surveillance. Maintenance data will be reviewed for accuracy, and adverse trends.

Contractor performance and mission reports, higher headquarters logistic reports and AETC maintenance summary will be reviewed for possible indications of negative trends. In addition, previous COR inspection reports/data will be checked for repeat or recurring discrepancies. The Chief COR/Superintendent will brief all CORs on any previous day discrepancy that is determined to be of a serious nature and direct any further actions, if necessary.

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3.1. Technical Inspections (TI). TIs normally consist of multiple areas. Discrepancy discovered in the following areas that directly relate to the TI being performed will be charged against the rated TI (Acceptable Quality Level (AQL)) unless otherwise stated in table 3.1:

- Aircraft/equipment

- Aircraft/equipment forms

- Maintenance Information Systems (MIS)

- Technical data

- Tool/support equipment

- Training record/documentation

- After maintenance FO checks

Discrepancies charged in these areas are considered part of the TI (and/or PMI) and counted in the basic Acceptable Quality Levels (AQL). Any discrepancy discovered in an area that does not directly relate to the TI being performed may be added to the AETC Form 447 as a non-chargeable or documented separately as an “As Observed.” CORs will use judgment and experience to make the above determine.

3.1.1. AQL/baselines. An AQL/baseline denotes the maximum allowable number of minor discrepancies that may be charged for a task to be rated “conforms”. The AQLs listed in Table 3.1 shall be used to determine conforms/non-conforms criteria for QC and COR inspections. The criteria are in addition to the minimum requirements established in AFI 21-101, paragraph 6.7.4.1 and this OI. A non-conforms rating will be assigned when the number of minor discrepancies exceeds the AQL of a like inspection contained in QASP table 3.1. If no like inspections exist then a non-conforms rating will be assigned when the number of discrepancies exceeds 3 minors. Any major discrepancy will result in a non-conforms rating.

NOTE: Contractor QC is expected to set and maintain a higher standard therefore all AQLs will reduced by 50% for QC follow-up evaluations QASP paragraph 2.9.2.1. AQLs will be rounded using standard computations according to PWS paragraph 3.16.3. Note B.

3.1.1.1. Major Discrepancy. A condition that would endanger personnel, jeopardize equipment or system reliability, affect safety of flight, or warrant discontinuing the process or equipment operation. Examples of major discrepancies include but are not limited to:

3.1.1.1a. Improper or untimely documentation of Red X discrepancies on aircraft, trainer, or equipment in AFTO forms and MIS to include referencing wrong TO procedures.

3.1.1.1b. Foreign object(s) (FO) within 50 feet of an aircraft flight line parking or engine operating area or within 10 feet of an aircraft or engine in a maintenance area (i.e., hangars, phase dock, wash rack, etc.).

3.1.1.1c. Test, Measurement, Diagnostic Equipment (TMDE) overdue calibration or when calibration status cannot be verified.

3.1.1.1d. Violation of environmental protection federal, state, or local laws and or Department of Defense or host base environmental policies and directives.

3.1.1.1e. Overdue time change and inspection items on AGE/SE (if applicable).

3.1.1.1f. Any inspections not loaded (except those specifically exempted by AF tech data); any due time errors, and improperly loaded low cycle fatigue cycle items.

3.1.1.1g. TO violations, not using required TOs to perform tasks, or violations of mandatory directives. And supplements when such may cause damage to government property or injury to government personnel. (reference T.O. 00-5-1, Air Force Technical Order System).

3.1.1.1h. Improper use of tools or use of out-of-date technical data when such may cause damage to government property or injury to government personnel (reference T.O. 00-5-1, Air Force Technical Order System).

3.1.1.1i. Performance of maintenance without being trained or qualified on the task.

3.1.1.1j. Failure of trainer to identify and explain critical elements of a task being taught; failure of trainer to properly document aircraft and equipment forms; failure of trainer to practice/demonstrate proper FOD control procedures; failure of trainer to use proper Tech Data; test compromise; course documents not signed or overdue annual review.

3.1.1.1k. CTKs: missing tools, contents of the CTK do not match the master Inventory Listing (MIL), MIL not validated annually or when CTK custodian makes changes, major corrosion (excessive pitting, rust and/or a compromise of the integrity of the tool), tools not etched, tools etched incorrectly, etching illegible, etched with two (2) different CTK numbers, unapproved locally developed/manufactured tools in CTK, hammers etched on fiberglass handles and/or impact areas, tools not inlayed/shadowed, missing tool replacement log inaccurate or missing, tools not secured/left unattended, CTKs in use but not inventoried and/or signed out, explosive-proof flashlights with cracked or torn seals, grease guns not marked clearly with military specifications (type grease), damaged CTKs (broken hinges, drawers, doors, etc.) not documented, spare bulb or clip in flashlight, Uncontrolled/unetched/unmarked/ Personal Protection Equipment (PPE),equipment, Potential Fraud Waste and Abuse.

3.1.1.1l. Technical Order is not the current basic version or is missing current change, changes/TOPs/supplements improperly posted, TO in use with the annual inspection overdue, pages identified for deletion on the list of effective pages (LEP) not removed from the TO, TO is missing pages, changes/TOPs/supplements not filed within 5 days of receipt.

3.1.1.1m. Vehicles/Carts. Oil level not in the operational range, safety equipment not operational (brake lights inop, horn, parking brake, seat belts, etc.), not performing and/or documenting monthly tire pressure check, missing hardware (pip pins, lanyards, latches, etc.), and not documented as removed, prior to use inspection not accomplished and/or documented as accomplished.

3.1.1.1n. Uncontrolled, unaccounted for aircraft parts or equipment.

3.1.1.1o. Supply/parts abuse (for example but not limited to, part/s on order with no open discrepancy in forms/IMDS, multiple same part/s ordered when actual parts requirement is less then ordered, ordering next higher assembly with required part/s available/issued).

3.1.1.2. Minor Discrepancy. An unsatisfactory condition that requires repair or correction but does not endanger personnel, affect safety of flight, jeopardize equipment reliability, or warrant discontinuing a process or equipment operation. (NOTE: If the inspector determines it is appropriate, minor discrepancies that consist of a grouping of like deficiencies; for example, a bench stock with 6 commingled bins, 10 bins not flagged, and 4 bins with torn labels may be documented as one discrepancy on PMIs only.)

3.1.2. CORs will use Technical Orders (TO) and/or applicable checklists while performing

23 FTS/COR_OI 21-101_13 December 2016 13 surveillance. TIs are limited to the same inspection work cards or TOs required for the job.

CORs must inspect at least 50 percent of the TO/inspection items for the task/area selected for evaluation. Contractor personnel must have TOs at the job site and opened to the page for reference as required. Work cards must be open and referred to as each inspection item is accomplished. Checklists must be open, in-hand, and items performed in the prescribed sequence.

3.1.3. Contractors Training TIs. CORs will perform TIs to effectively monitor compliance with the contractor’s training plan to ensure that training provided meets applicable qualification and training standards. CORs will place special emphasis on the adequacy of the training provided.

In addition to the rating criteria listed in AFI 21-101 & AETC Sup, discovery of the following conditions while performing training TIs will be categorized as a major discrepancy;

- Failure of trainer to identify and explain critical elements of a task being taught properly document aircraft and equipment forms practice/demonstrate proper FOD control procedures use proper Tech Data

- Test compromise

- Non-compliance of contractor’s training plan

- Course documents not signed or overdue annual review

- Supervisor initial evaluations not complied with

- Lesson plans not personalized

3.1.3.1. Surveillance will include a random monthly over-the-shoulder observance of task qualification and certification training when available or classroom/floor formal training.

In addition to actually observing the task training as it takes place, the surveillance will include a review of training documentation, individual training records, and plans of instruction, when applicable. If formal training is evaluated, the COR will inspect all applicable course documentation and observe classroom and/or floor lecture. Observe a minimum of 30 minutes of lecture for classes longer than one hour. If lecture is less than one hour, observe entire lecture.

3.1.4. CTK; One (1) major discrepancy fails a CTK regardless of how many tools are being inspected. Minor discrepancy AQL will be 1 minor for each 50 tools inspected, not to exceed a maximum of 7 minors per CTK. See table below for example.

Number of Tools Conforms Rating Non-conforms Rating 1 - 50 1 minor discrepancy 2 or more minor discrepancies

51 - 100 2 minor discrepancies 3 or more minor discrepancies 101 - 150 3 minor discrepancies 4 or more minor discrepancies 151 - 200 4 minor discrepancies 5 or more minor discrepancies 201 - 250 5 minor discrepancies 6 or more minor discrepancies 251 - 300 6 minor discrepancies 7 or more minor discrepancies

301 or greater 7 minor discrepancies 8 or more minor discrepancies

3.1.4.1. The following listing is not all inclusive, but are conditions that will be categorized as major discrepancies relating to CTKs:

- Missing, lost or unaccounted for tool/s (including parts/pieces of tools)

- Master contents listing (MIL) not available for CTK

- Contents of the CTK do not match the MIL

- MIL not validated when CTK custodian changes

- Major corrosion (excessive pitting, rust and/or a compromise of the integrity of the tool)

- Tools not etched, etched incorrectly, illegible etching,

- Tools double etched (with different CTK numbers)

- Overdue inspections or calibrations

- Unapproved locally developed/manufactured tools in CTK

- Hammers etched on fiberglass handles and/or impact areas

- Missing tool replacement log inaccurate or missing

- Tools not secured/left unattended

- CTKs in use but not inventoried and/or signed out

- Explosive-proof flashlights with cracked or torn seals

- Grease guns not marked clearly with military specifications (type grease)

- Damaged CTKs (broken hinges, drawers, doors, etc) not documented

- Spare bulb or clip in flashlight

3.1.4.2. The following listing is not all inclusive, but are conditions that will be categorized as minor discrepancies relating to CTKs:

- Tool etchings hard to read

- Minor corrosion (cosmetic)

- Deteriorated foam or plastic linings

- F.O. in CTK (unless secured in an approved FOD container)

- Unserviceable tools not removed from CTKs

- Minor damage to tools, (i.e. slight bends to screwdriver shafts, dull knives/chisels, etc.).

3.1.5. Technical Orders (T.O.) One (1) major discrepancy fails a T.O. regardless of how many pages are being inspected. Minor discrepancy AQL will be 1 minor for each 100 pages inspected, see table below for example.

Number of Pages Inspected Conforms Rating Non-conforms Rating

1 - 100 1 minor discrepancy 2 or more minor discrepancies 101 - 200 2 minor discrepancies 3 or more minor discrepancies 201 - 300 3 minor discrepancies 4 or more minor discrepancies 301 - 400 4 minor discrepancies 5 or more minor discrepancies 401 - 500 5 minor discrepancies 6 or more minor discrepancies

3.1.5.1. The following listing is not all inclusive, but are conditions that will be categorized as major discrepancies relating to technical orders: T.O. is not the current basic version or is missing current change, changes/TOPs/supplements improperly posted, TO in use with the annual inspection overdue, pages identified for deletion on the list of effective pages (LEP) not removed from the T.O., T.O. is missing pages, changes/TOPs/supplements not filed within 5 days of receipt.

3.1.5.2. The following listing is not all inclusive, but are conditions that will be categorized as minor discrepancies relating to T.O.s: pages with minor rips/tears, LEP check is not properly annotated, foreign materials (parts bags, tags, etc.) left inside of T.O.s.

3.1.5.3. TCTO AQL is set at 3 minors unless otherwise stated. TCTO AQL may be adjusted based on complexity of the TCTO. If contractor request adjustment; the contractor will notify the COR prior to starting first inspection. The contractor will provide justification and a recommended AQL. The COR will provide a written concurrence or non-concurrence. In the event of a non-concurrence, the KO will make a final determination. If the AQL is adjusted

23 FTS/COR_OI 21-101_13 December 2016 15 from 3, the COR representative will follow-up with an e-mail to the contractor leadership and Cc the 23fts.allcor@us.af.mil mailbox. A copy of this e-mail will be filed with respective AETC Form 447.

3.1.6. Document File AQL. Evaluation will include a review of MIS. A non-conforms rating will be assigned when a major discrepancy or more than three minor discrepancies for each ten pages inspected (e.g., 1 to 10 pages. three minors; 11 to 20 = six minors, 21 to 30 = nine minors).

The correct use and clearance of Red X symbols are items of special attention during documentation file inspections. CORs must ensure unsafe or unfit for operation conditions are represented by Red X entries and these entries are properly cleared. Active forms inspections will fall under the applicable TI AQL.

3.2. Program Management Inspections. To ensure a complete and comprehensive surveillance program, each area is covered by a specific EG as identified in AFI 21-101 & AETC Sup and this OI. Surveillance will be accomplished utilizing the appropriate EG in conjunction with the General EG. Any quarterly PMI receiving a consecutive non-conforms rating may, at the FC’s or Chief COR’s discretion, be rescheduled the next month. The rescheduled inspection will utilize the complete EG with emphasis on those areas that caused the non-conforms rating.

Deficiencies will be documented on AETC Form 447. FOD walks will also be performed in the aircraft parking/maintenance areas during performance of the regular assigned PMI. PMIs will receive a failed rating when a major discrepancy is identified or seven or more minor discrepancies are identified.

3.2.1. Aircraft appearance/cleanliness. During the flight line PMI, a random sample of a minimum of two aircraft will be inspected for appearance/cleanliness in accordance with the PWS. All write-ups for appearance/cleanliness will be grouped into one minor write-up.

Deficiencies noted that are not a part of the PMI will be documented as “As Observed” or “Non- Rated”.

3.2.2. Tool control inspections. When applicable; CORs will accomplish tool control inspections (TAS/TC-Max as applicable) in conjunction with PMI. The COR will inspect dispatchable tool boxes/pouches, and non-dispatchable tool boxes/pouches, to surveil tool control requirements listed in AFI's, AETCI's and contractor OIs. As a minimum, inspections will consist of the Consolidated Tool Kit (CTK) inventory process, lost/missing tools, and overage of tools, etched tools, shadowed tools, special tools storage and calibration.

3.2.2.1. Major tool control discrepancies; Always refer to AFI 21-101 & AETC Sup, contractor’s QMS and this OI to ensure consistency when determining major/minor discrepancies. The COR will use sound judgment and experience when determining classification of discrepancies. As a minimum, consider the following as possible major discrepancies;

- Items identified in and QASP paragraphs 3.1. – 3.1.5.

- Overdue calibration on TMDE/PMEL items

- Unserviceable tools (if replacement is required to preclude potential FO or damage to equipment)

- Unattended tools – no oversight by anyone in the area

- Uncontrolled/unetched/unmarked Personal Protection Equipment (PPE)

- Uncontrolled rags or any other material used as a rag

- MIL not validated annually

- Potential FW&A

- TAS- tools & equipment removed, not signed out in TAS

3.2.3. Training Management (TM) TMI; Always refer to AFI 21-101 & AETC Sup, PWS, contractor’s QAP and this OI to ensure consistency when determining major/minor discrepancies.

3.3. Foreign Object (FO) Inspections. FO inspections are applicable to performed in several different manors; separately as TIs on aircraft, engines, equipment; as a part of routine TIs; part of PMIs and/or as independent area FOD Walk TIs.

3.3.1. The AQL for FO inspections is no majors and the minor AQLs are the same as stated in QASP Table 3.1. and paragraphs 3.1. - 3.1.5.

3.3.2. FO not meeting the criteria of a major discrepancy will be counted as 1 minor discrepancy against the AQL per each piece of FO discovered.

3.3.3. When practical, perform flightline FO walks shortly after contractor has performed their FO walk or after the first "Go" of aircraft for the selected pads.

Note: due to the condition of the Army provided ramp, items discovered on the ramp that are beyond the control of the contractor and attributable to the poor condition of the ramp and/or surroundings will be non-chargeable (non-rated) against the rated flightline FO inspection. Items found that are directly contributed to poor maintenance practices and/or housekeeping by the contractor will be charged against a rated inspection. CORs will use judgment and experience to make the above determine.

3.4. Other Surveillance Methods. In addition to TIs and PMIs, performance assessment includes the following;

3.4.1. As Observed (AO) Deficiencies. These deficiencies will be documented on AETC Form 447 and classified as “Non-Rated”. They occur when discrepancies or deficiencies are observed or discovered that are not directly associated with a scheduled inspection.

3.4.2. Customer Complaint. Customer complaints will be recorded on local letterhead or official e-mail. A customer complaint can led to a level II, III or VI CAR depending on the severity of the complaint. A COR will be assign to validate the customer complaint and will ensure the applicable technical order and/or contract reference is properly annotated. The COR will validate the actual occurrence and/or the results of the investigation. Customer complaints will be sent to the contractor for action. The Chief COR will consider the actions taken by the contractor, follow up as needed, and if the response is expected to solve the customer’s complaint, attach the response to the letter and file as part of the permanent surveillance records. If the response fails to address the customer’s complaint or is insufficient, the Chief COR will non-concur and do the following; file for record, return to contractor for additional comment and/or forward to the KO for further action. Provide a copy of the completed customer complaint to the originator, contractor, FC, PM and KO. Customer complaints originating from 23FTS personnel will be coordinated with the 23FTS CC and/or DO.

3.4.3. Documentation file inspections. CORs will evaluate aircraft, support equipment (powered AGE), and engine historical documents to include IMDS. Always refer to AFI 21-101 & AETC Sup to ensure consistency when determining major/minor discrepancies.

3.4.4. Safety Violations. IAW AFI 21-101 & AETC Sup, paragraph 14.5.7 guidance applies.

23 FTS/COR_OI 21-101_13 December 2016 17

3.4.5. Mishap Investigation Surveillance. CORs will monitor and evaluate the contractor’s compliance with the PWS 3.4.18, AFI 91-204, local requirements, contractor OI’s and checklist during mishap investigations. Emphasis will be placed on actions taken during the initial phase of securing aircraft/equipment data. Depending on the severity of the discrepancies; they may be recorded on AETC Form 447 as an As Observed or issued as a CAR IAW section 6.5. of this OI.

3.4.6. Functional Check Flight. Contract FCF pilots are utilized by the PWS and the 23FTS GFR validates their qualifications. COR will evaluate the FCF briefings according to table 3.1 of this

OI.

3.4.7. Government Furnished Equipment. Chief COR will assist the KO in managing the applicable government-furnished property clause of the contract. Both Army and Air Force owned GFE discrepancies will be documented IAW paragraph 3.5 of this OI.

3.4.7.1. CORs will surveil management of GFE during routine performance of PMIs and TIs, when applicable. GFE will be checked for proper item identification/labeling and accountability on master inventory listings (MIL), CA/CRL and/or Property Books. Surveillance will include checks for evidence of waste and abuse.

3.4.8. Combating Trafficking in Persons. DoD has a zero tolerance policy for human trafficking. CORs are the first line of defense in the battle against human trafficking and must complete Combating Trafficking in Persons training annually. As the COR monitors the contractor and its employees, Combating Trafficking in Persons should rank among the COR’s chief priorities. CORs must be diligent in ensuring that contractors and contractor personnel are not trafficking in persons. During surveillance, the COR will monitor the contractor’s performance regarding trafficking in persons for compliance with all that is required IAW FAR clause 52.222-50, Combating Trafficking in Persons. The COR must inform the Contracting Officer if the contractor, contractor personnel, subcontractor, or subcontractor personnel have failed to comply with the requirements of the clause at FAR 52.222-50. After receiving this information, the Contracting Officer shall provide information for any investigation and enforcement to:

Program Manager DoD CTIP Law Enforcement and Support

OUSD (P&R) DHRA

4800 Mark Center Dr Suite 06J25-01 Alexandria, VA 22350-4000

Reports may also be made:

On-line at http://ctip.defense.gov/;

On-line via the National CTIP Hotline website at http://www.polarisproject.org/;

By e-mail to CTIPReports@OSD.Pentagon.mil; or By phone to the National CTIP Hotline at 1-888-373-7888.

Note: The COR must report any suspected violations or activities to the Contracting Officer (See FAR Subpart 22.17 and DFARS Subpart 222.17).

Note: CORs should not personally investigate suspected incidents of Trafficking in Persons but should forward all reported or suspected violations to the Contracting Officer immediately.

Note: The Contractor must take appropriate action should a violation occur. For corrective procedures and remedies for non-compliance, see FAR 52.222-50.

3.5. Performance Assessment Documentation. All TI, PMI, and as observed discrepancies will be documented on an AETC Form 447, hard or electronic version. The date the inspection was performed and contract references will be entered in all reports. Specific references for T.O., AFI's, AETCI's, etc., will be entered for each discrepancy cited. Ensure discrepancies discovered during evaluations are documented in the aircraft/equipment AFTO Forms as appropriate. Repeat discrepancies from previous COR inspections will be identified and annotated on the AETC Form 447. Repeat discrepancies can lead to a Level II or higher CAR.

When aircraft forms are documented, the COR will ensure the status-of-the-day block is updated and inform the lead-man, Technical Inspector or supervisor to review the forms and ensure that input into IMDS is accomplished. All AETC Form 447's requiring corrective will be routed to the contractor for corrective action. The Performance Assessment Documentation process may be automated.

3.5.1. Contractor response to AETC Form 447 discrepancies: Each discrepancy (including non-rated and as observed discrepancies) requires a three part answer as stated in PWS 6.2.2.

Deficiencies. Part 1; identifying the root cause of that discrepancy. Part 2; enter the corrective action taken or action to be taken to correct that discrepancy and estimated date of completion; if the corrective action in not complete. Part 3; define the preventive measures to prevent recurrence of the discrepancy. All responses should be professional; AETC Form 447’s are permanent records that are open for review from all levels of Government and contractor management.