Intent/Purpose -
The intent/purpose of this DCMA instruction
is
to ensure DCMA surveillance is intensively focused on Critical Safety
Items (CSIs) to mitigate risk of failure of those items with
characteristics, if nonconforming would likely cause serious injury or
death to the user or catastrophic failure of a major platform e.g.
aircraft, space vehicle, ship, etc. and to assure conformity of those
items prior to acceptance.
Process
1.QA personnel shall review
contract, technical data package (TDP), quality assurance letter of
instruction (QALI), purchase order and letter of delegation (LOD) to
determine if the item is CSI.
1.1. Non-aviation CSI include personal protective
devices such as Small Arms Protective Insert (SAPI) vests, gas masks,
chemical/biological suits, and parachutes; conventional ammunition
including small/large caliber munitions, artillery rounds, bombs, and
missiles; critical items associated with space launch vehicles (manned and
unmanned) and satellites; mission critical items for Missile Defense; and
Naval Sea System CSIs.
1.1.1. Non-aviation CSI TDPs and
customer QALIs (if issued) shall be reviewed for formally identified
critical characteristics. Where the TDP or QALI does not formally define or
identify critical characteristics, the results of a formal failure analysis
e.g. Failure Modes & Effects Criticality Analysis (FMECA) should be
used to identify items that are categorized as single point failures or
will cause a catastrophic failure. The identified cause of the failure mode
can be used as a basis for determining surveillance requirements and should
be treated as critical.
1.2.
Aviation CSIs are determined by
the military service Engineering Support Activity (ESA). Aviation CSIs are
identified to DCMA through Contracts, TDPs, and/or QALIs. CSIs at the
subcontract level are identified through the delegation and shall reference
the source document for the CSI designation e.g. contract, TDP, or QALI.
CSIs from legacy systems may be identified as Flight Safety, Flight
Critical Part, Flight Critical, etc. Questions of whether an item is a CSI
should be addressed through the procurement office to the applicable ESA.
1.2.1. The Joint CSI Data Viewer is a web portal that
encompasses a total listing of all ESA identified CSIs by accessing the
specific Service's database and may be used when there is a question of a
valid CSI. The data viewer is located at:
CSI
Viewer.
Items found to be CSI in the Joint CSI data viewer shall be treated
as CSI; if the contract does not identify the item as CSI, the procurement
office shall be notified of the contract error and confirmation of the CSI
designation requested. If an item is identified as CSI in the contract but
is found not to be classified as CSI in the data viewer, confirmation of the
CSI designation shall be requested and the procurement office notified of the
possible contract error; until the contract is modified, the item shall be
treated as CSI.
1.2.2. Aviation
CSI critical characteristics can only be determined by the military service
ESA. Documentation for critical characteristics may be found in the
contract, TDP or QALI. Critical characteristics may be identified as a
physical characteristic, installation characteristic, test parameter or
process e.g. shot peen. CSI critical characteristics at the subcontract
level are identified through the delegation and shall reference the source
document for the CSI designation e.g. contract, TDP, or QALI.
QA
personnel shall initiate contact with the procuring activity to request
guidance from the ESA when an item may be inappropriately identified as a
CSI or when an item is not identified as a CSI and the QA specialist
believes it should be.
2. QA personnel shall determine the
appropriate critical characteristic strategy for initial and continuing
surveillance of identified CSIs with defined critical characteristic(s). Unless the customer specifies
otherwise, the following methodologies outline the Agency approach for
critical characteristic surveillance:
2.1.
Product feature is defined as the critical characteristic and contract
quality requirement is
FAR 52.246-11 Higher Level Quality Requirement
or any Standard Inspection Clause (FAR 52.246-2 through 52.246-9).
2.1.1. Initial
Surveillance – Perform product examination of the critical characteristic
on the first available production piece.
2.1.2. Continuing
Surveillance – Perform product examination of critical characteristics in
accordance with a zero based statistically valid sampling plan of 0.4 Quality Release Level
(QRL), unless sampling plan is defined specifically in the contract.
2.2. Process is defined
as the critical characteristic and contract quality requirement is
FAR 52.246-11 Higher Level Quality Requirement.
2.2.1. Initial
Surveillance – Conduct initial process review in addition to verifying the
output of the process through product examination.
2.2.2. Continuing
Surveillance – Evaluate the process incrementally until all process
characteristics have been evaluated and periodically perform product
examination to verify process adequacy; the frequency of the review is
dependent on the process activity and supplier performance.
2.3. Process is
defined as the critical characteristic and contract quality requirement is
any Standard Inspection Clause (FAR 52.246-2
through 52.246-9). Since
Standard Inspection systems,
FAR 52.246-2
through 52.246-9, do not require
process control; notify the customer and comply with any direction received.
Pending any direction, assure that the supplier inspection system verifies
the output of the process defined as a critical characteristic.
2.4. Where critical
characteristics/processes are produced / accomplished at a subcontractor
facility and cannot be adequately verified at the prime supplier location
using the methodologies described above, a delegation for subcontract QA
surveillance shall be issued. Surveillance performed at a subcontractor
through a LOD shall be included as a part of the surveillance strategy.
2.5. Where critical characteristics
apply to the item’s installation, sometimes known as “installation
critical” and that installation is not accomplished where the item is
produced, the point of installation is responsible for those critical
characteristics. This may be the military service in the case of
spare parts or the next higher assembly where a component or platform is
being procured/overhauled.
2.6. DCMA QA surveillance strategies
do not apply to commercial aircraft or subsystems purchased and maintained
in accordance with Federal Aviation Administration (FAA) regulation, unless
required by the Service ESA.
2.7. CSI’s procured under a
commercial contract requirement (FAR 52.212-4) will need addenda to give
the government the authority to perform the necessary in-process product
examinations and/or process reviews to verify conformity. Without addenda
this clause limits government surveillance to point of tender and to be
compatible with common industry practice. Where CSI’s are procured with a
commercial contract clause and no addenda, the QAR personnel should
determine if the necessary product examination and/or process review could
be accomplished to determine critical characteristic conformity. If QAR
is unable to perform product examination the procuring/delegating activity
shall be immediately notified and addenda requested.
3. Surveillance of
aviation CSI is not limited to verification of critical characteristics.
Important
manufacturing processes have been identified by the Engineering Support
Activities (ESA) for consideration for a specific CSI when identifying risk
factors. The processes on this list are not all inclusive; if
there are other important processes identified through the planning effort,
surveillance strategies shall be established accordingly. 4. Although the ESAs
are working to formally define critical characteristics, there will always
be an outstanding population of CSIs without defined critical
characteristics. QA surveillance in these instances is contingent on
whether the CSI manufacturer is a system or subsystem prime supplier, an
original equipment manufacturer (OEM) with design authority from the prime supplier/ESA,
or an alternative source.
4.1. A Prime Supplier is
one having responsibility for design of a system, subsystem, or
equipment. An Original Equipment Manufacturer (OEM) is the
individual, activity or organization that performs the physical fabrication
processes that produce the deliverable part or other items of supply for
the prime supplier. The OEM may or may not be granted design
responsibility by the prime supplier for preparation and technical currency
of drawings and technical data. OEM parts are sometimes referred to
as legacy items.
4.1.1. When
the CSI is the responsibility of the Prime or OEM with design authority and
critical characteristics have not been identified, the surveillance
strategy shall consist of applying the process review technique associated
with selected Important Manufacturing Process as outlined in
paragraph 3. Product examinations of the process
output on these processes may be performed as necessary.
4.2. An Alternate Source
is an offeror (Government or Supplier) other than the prime supplier or
OEM, as defined in paragraph 4.1, who provides an
identical part numbered item.
4.2.1. When
the CSI is the responsibility of an alternate source, the following
significant characteristics criteria are
established for QA personnel to use when critical characteristics are
not otherwise defined by the ESA in
the technical data package, contract, or specific instructions provided by
the buying activity. A courtesy copy of DCMA identified significant
characteristics shall be provided to the buying activity and PCO for transmittal
to the ESA and shall be maintained on file by the QAR.If significant investments in time
and effort are anticipated in reviewing the tech data package to identify
applicable significant characteristics the ESA shall be contacted with
proposed alternative surveillance strategies focused on surveillance of
important manufacturing processes as defined in paragraph
3.The intent of these criteria is to define those
significant product characteristics on which QA personnel shall focus their
surveillance in the absence of ESA defined critical characteristics.
Surveillance strategies for significant characteristics may include process
reviews or incremental process reviews (performed on processes that produce
or control the significant characteristic) in addition to product
examinations. The contractual technical requirements (e.g. drawing
characteristics) shall be compared to the criteria below.Any
characteristics meeting these criteria shall be considered as significant
product characteristics for surveillance purposes only.
Application of these criteria does not impose any additional contractual
requirements on the supplier. Typical significant characteristics
are:
Diametrical
and linear dimensions having a total tolerance of “.001” or less.
Geometric
features other than diametrical and linear dimensions (e.g. run out,
perpendicularity, parallelism, and concentricity) with a total tolerance of
“.002” or less.
Surface
finishes having a value of “16 RMS” or less.
Threads
specified to class 3 or greater or classified as Safety Critical.
Angular
dimensions with total tolerance range of 1 degree (60 minutes) or less.
Test
Methods & Acceptance Criteria for Nondestructive Testing (e.g. magnetic
particle, liquid penetrant, radiographic inspection, ultrasonic, eddy
current, etc.).
Hardness
testing (e.g. Rockwell).
Shot
peen requirements.
Material
properties and material certifications.
Dynamic
balancing of rotating units and static balancing of flight control
surfaces.
Flow
checks for blades and vanes.
Spray
pattern requirements for fuel nozzles (including afterburner rings).
Weight
checks.
4.3. In addition to these
significant product characteristics surveillance shall also encompass the
Aviation CSI Important Manufacturing Processes detailed in paragraph 3 above.
5. Dealers or Distributors do not always possess the
measuring devices and/or technical data associated with the CSI’s they are
offering for acceptance. If QA personnel are unable to perform product
examination due to unavailability of measuring devices or technical
drawings/specifications, the procuring/delegating activity shall be
immediately notified to request that the procuring activity either provide
specific acceptance criteria or require inspection and acceptance at
destination in lieu of source. 6.The CSI
surveillance strategy shall be documented in a surveillance plan. This
strategy shall include a determination of CSI
subcontract delegation requirements. This may be a CSI specific plan
or incorporated into the appropriate facility or program surveillance plan.
As a minimum the plan shall include:
Identification
of CSI Items
Critical
characteristics
Important
manufacturing processes (if applicable)
Significant
characteristics (if applicable)
Surveillance
methodology e.g. Product Examination, Process Review, etc.
Intensity
and frequency of surveillance
Nonconforming
material authority (if applicable)
Customer
communication requirements
7.The QAR shall execute the CSI
surveillance strategy as documented in the surveillance plan. 8. DCMA
personnel do not have authority to disposition minor non-conformances of
aviation CSI unless specifically delegated.
The authority
to disposition minor non-conformances of CSI is vested with the military
service ESA. All
use-as-is or repair dispositions being applied to contractually designated CSIs
with defined
critical characteristics shall be forwarded through the procuring activity
to the ESA for approval. Where the critical characteristic is not
identified on the drawing, specification, technical data package, or
otherwise specified in the contract, but identified through a QALI or other
customer direction, all use-as-is or repair dispositions to
non-conformances of such characteristics shall be forwarded to the procuring
activity and subsequently to the ESA for approval. In certain
situations, the procuring activity may vest authority for disposition of
minor non-conformances with DCMA. In these cases, the ESAs have
delegated minor nonconformance authority to DCMA by CAGE code or have
detailed DCMA authority in the contract. The following documents
identify where the military service ESAs have delegated minor
nonconformance authority to DCMA.
8.1.
Concessions (formerly known as waivers), requests for deviation permits,
and Engineering Change Proposals (ECPs) shall be reviewed for completeness
and accuracy and comments/recommendations shall be provided to the procuring
activity.
8.2.
Where CSI contracts
specify the supplier is required to perform 100% inspection of critical
characteristics e.g. AMCOM QE-STD-1and the supplier is pursuing contractual
relief based on statistical process control (SPC), the QAR shall evaluate
the supplier’s SPC approach for adequacy and provide a recommendation to
the ESA via the ACO and PCO.
9.Documentation of surveillance
results shall include:
Date of
surveillance
Identification of who performed the inspection
Supplier
name
The
specific CSI serial or lot number as applicable
Associated
critical characteristics
Associated
“Important Manufacturing Processes” as applicable
Number of
observations
Deficiencies found
Traceability to associated Corrective Action Requests (CARs)
10.Contractual nonconformities
noted during CSI surveillance shall be documented in accordance with the QA
Corrective Action Request policy. Nonconformity of critical
characteristics shall result in a Level II CAR as a minimum. 11.Data shall be analyzed on a
periodic basis. See Data
Analysis Policy (TBP). The data to be analyzed shall include as
applicable, but not limited to DCMA surveillance results, customer
complaints, results of supplier internal audits, 2nd and 3rd party audit
results, and supplier corrective/preventive actions. The surveillance
plan shall identify the applicable data and analysis interval. Adjustments
to process reviews and significant characteristics shall be based on the
documented results of data analysis. 12.The following constitute minimum
customer communication requirements:
Advise
the procuring activity of corrective action requests issued by DCMA to the
supplier relative to nonconforming CSI, CSI critical characteristics, or
deficient manufacturing, configuration management, quality management, or
supplier management processes. Advise procuring activities of supplier
responses and status of corrective actions relating to defective CSI or CSI
processes.
Notify
affected procuring activities when DCMA becomes aware that a supplier
removes a source from the supplier's approved subcontractors or suppliers
because of improper or suspect manufacturing, quality management, or
configuration management processes and there may be an impact on critical
safety items.
Advise
the procuring activity of recommendations for the use of Certificate of
Conformance (CoC) in lieu of Government Contract Quality Assurance (GCQA)
and assure that the contract has been appropriately modified prior to
implementing an ESA approved CoC.
Initiate
contact with the procuring activity to request guidance when an item may be
inappropriately identified as a CSI, or when an item is not identified as a
CSI and the QAR feels it should be. Instances of procurement office
non-responsiveness should be elevated to the next level of management.
Provide
comments and recommendations regarding concessions (formerly known as
waivers), requests for deviation permits and ECPs to the procuring
activity.
Competencies/Certifications
Current DCMA QA certification requirements are addressed
in the PA
Competencies and Certification. CMOs may authorize personnel to perform
surveillance tasks for which they are qualified whether or not the
individual meets certification requirements.
Prior to assigning QA personnel to work this process, the
first level supervisor is responsible to ensure QA personnel are qualified
to perform the tasks defined in this policy as it relates to the assigned
facility, contract, or product.
To meet the full competency requirements for this
instruction:
QA personnel who have not previously
taken or received an equivalency for Quality Assurance
Fundamentals ( S-01) need to take Government Contract
Quality Assurance (QUAL-101).
QA personnel who have previously taken or
received an equivalency for Quality Assurance Fundamentals (
S-01) need to take Government Contract Quality Assurance
Advanced/Update(QUAL-201).
Both QUAL-101 and QUAL-201 are currently
listed in
CTMS (DCMA Training) and should be added to individual
eIDPs as appropriate.
Training Matrix
Critical
Surveillance Items Training Matrix
What
TASKS are
required to
accomplish this
process?
Methods
of training
On-the-Job
Training (OJT)
Computer
Based Training (CBT)
Course
(Commercial, College/ Vocational)
Contractor
Sponsored Training
Guidebooks
DCMA
Developed
Administrative Task (The task is wholly enabled by the
contents of the instruction and requires no training intervention)