4.3.18.6. Critical Safety Item
4.3.18.6. Critical Safety Item
Critical Safety Item (CSI) is a part, assembly, or support equipment whose failure could cause loss of life, permanent disability or major injury, loss of a system, or significant equipment damage. Special attention should be placed on CSIs to prevent the potential catastrophic or critical consequences of failure. Significant problems occurred when DoD purchased CSIs from suppliers with limited knowledge of the item’s design intent, application, failure modes, failure effects, or failure implications. The definition of CSI is not to be confused with the MIL-STD-882E definition of a Safety Critical Item (SCI). A SCI is “a hardware or software item that has been determined through analysis to potentially contribute to a hazard with catastrophic or critical mishap potential, or that may be implemented to mitigate a hazard with catastrophic or critical mishap potential.”
The purpose of CSI analysis is to ensure that Program Managers for DoD acquisition programs who enter into contracts involving CSIs do so only with resources approved by the Design Control Activity (DCA). The DCA is defined by law as the systems command of a military department. The DCA is responsible for the airworthiness or seaworthiness certification of the system in which a CSI is used.
The intent of CSI laws, policies, regulations, and guidance is to avoid hazards through mitigating receipt of defective, suspect, improperly documented, unapproved, and fraudulent parts having catastrophic potential. These statutory requirements are contained in section 802 of Public Law 108-136, enacted to address aviation CSIs, and section 130 of Public Law 109-364, enacted to address ship CSIs, embedded in section 2319 of title 10, United States Code. The statute addresses three specific areas:
- Establish that the DCA is responsible for processes concerning the management and identification of CSIs used in procurement, modification, repair, and overhaul of aviation and ship systems.
- Require that DoD work only with sources approved by the DCA for contracts involving CSIs.
- Require that CSI deliveries and services performed meet all technical and quality requirements established by the DCA.
CSI policies and guidance ensure that items of supply that are most critical to operational safety are rigorously managed and controlled in terms of:
- Supplier capability
- Conformance to technical requirements
- Controls on changes or deviations
- Inspection, installation, maintenance, and repair requirements
DoD 4140.1-R, DoD Supply Chain Materiel Management Regulation establishes top-level procedures for the management of aviation CSIs. The Joint Aeronautical Commanders Group issued the Aviation Critical Safety Items (CSIs) Management Handbook. This guidance establishes standard user-level operating practices for aviation CSIs across the Services, the Defense Logistics Agency (DLA), the Defense Contract Management Agency (DCMA), and other Federal agencies. Appendix I of the Aviation CSI Management Handbook is a joint Military Service/Defense Agency instruction on "Management of Aviation Critical Safety Items" issued on January 25, 2006. This instruction (SECNAVINST 4140.2, AFI 20-106, DA Pam 95-9, DLAI 3200.4, and DCMA INST CSI (AV)) addresses requirements for identifying, acquiring, ensuring quality, managing, and disposing of aviation CSIs. Similar policies and guidance are being developed and/or revised to address ship CSIs as defined by public law.
The Defense Federal Acquisition Regulation Supplement (DFARS) was amended to implement the contractual aspects regarding aviation CSIs. Comparable DFARS amendments are being developed to address ship CSIs. DFARS 209.270 states that the DCA is responsible to:
- Identify items that meet aviation CSI criteria
- Approve qualification requirements
- Qualify suppliers
This supplement states that the contracting activity contracts for aviation CSIs only with suppliers approved by the DCA. Program Managers should coordinate with the contracting activity to ensure that they contract for aviation CSIs only with suppliers approved by the DCA and that nonconforming aviation CSIs are to be accepted only with the DCA’s approval, as required by DFARS 246.407. DFARS 246.407 was amended to state that DCA authority can be delegated for minor nonconformance. DFARS 246.504 requires DCA concurrence before certificates of conformance are issued to accept aviation CSIs.
Because the system developer may uncover problems with products after items are delivered, DFARS 246.371 and 252.246-7003 require the developer to notify the procuring and contracting officers within 72 hours after discovering or obtaining credible information that a delivered CSI may have discrepancies that affect safety. Program Managers should coordinate with the contracting authority to be kept aware of materiel recalls and shortfalls that may impact production rates and sustainment.
The CSI list evolves as the design, production processes, and supportability analyses mature. Program Managers identify and document CSIs during design and development to influence critical down-stream processes such as initial provisioning, supply support, and manufacturing planning to ensure adequate management of CSIs throughout a system’s Operations and Support (O&S) phase. The Program Manager should make provisions for developers including original equipment manufacturer (OEM) contractors to deliver an initial allocated baseline at the Preliminary Design Review (PDR), to include an initial list of proposed CSIs and a proposed process for selecting and approving CSIs as well as addressing the critical characteristics of those items. Prior to the Critical Design Review (CDR), the program office, with support from the DCA and developer/OEM contractors, should ensure there is a clear understanding of CSI processes, terms, and criteria. The initial product baseline is delivered at CDR and at that time the program should have 100% of drawings completed for the CSIs. Throughout Low-Rate Initial Production (LRIP) (if applicable), conduct of the Physical Configuration Audit (PCA), and establishment of the final product baseline, the program should update the CSI list and review it to ensure the list reflects the delivered system. Before the Full-Rate Production / Full Deployment Decision Review (FRP/FD DR), a final CSI list should be documented and approved by the DCA.
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