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About secaucus

  • Birthday April 8

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    Milwaukee, WI
  1. Prior to completion, a CPFF contract is converted to FFP. What impact, if any, is there to title transfer of Contractor Acquired Property?
  2. The accident occured long after storage payments stopped.
  3. The Government has not abandoned the property per se. They have just refused to deal with the issue including ignoring REA's for storage costs. Unfortunately, this particular customer performs their own contract admin including Plant Clearance so there are limited options.
  4. We have had abandoned classified Government property on our books for almost 20 years. The equipment is outdated and not been maintained as it is not prototypical of anything in the active inventory. The Government wants to leave it where it is because they cannot reach internal agreement to scrap the equipment and they will not pay us for storage. Requests for disposition have been dissapproved. Twenty years ago, the equipment had a replacement value of $500K. Having designed the equipment, we can say that today it has no real value beyond scrap; however, replacing the equipment with known obsolesence issues could cost tens of millions for a redesign. Recently, the equipment was severely damaged by an act of God. If the Government wants to be reimbursed for the damage, how do we value that reimbursement? We believe it's the scrap value of the metal.
  5. A hypothetical GSI order requires six widgets to build. Our widget supplier receives a delegation for GSI on the widgets. We build this equipment all year long and end up buying over 500 widgets a year. Our supplier offers a huge discount if we place an order for 500 vice mulitple orders every week for six, twelve, etc. Can we buy 500 widgets under a PO that requires six and transfer the remaining 494 to stock as parts that have been through GSI? Is there an alternative method that allows us to stock parts that require source inspection? The Government saves tremendously on cost and schedule.
  6. We use a component on a number of different subcontracts with GSI. Ninety-eight percent of the time, the local Government QAR delegates GSI to the sources of this component. Lead times for this component vary widely and we want to mitigate schedule risk by stocking this component. How do we "flow down" GSI on a PO that has no tie to a prime contract? We had a few components in stock that did not go through source inspection and we have been unable to utilize them on any order with GSI.
  7. Yes. The process for a prime is fairly straightforward. The process for a sub that has no privity with the Government is not very clear.
  8. We're a sub on a Navy production contract awarded to us in 2007 and containing 252.225-7014 ALT 1 Specialty Metals clause. We've come to discover that our bill of material contains a number of COTS fasteners bought from McMaster Carr. Despite the flowdown in the McMaster Carr PO, they can not or will not comply with a certification as top the source of the smelted steel. We informed DCMA of a potential non-conformance and put a shipping hold on the equipment. The awarded contract meets the effectivity period of the Class DNAD for fasteners. The fasteners in question fall under the designated FS Classes. I don't understand how the DNAD applies to the subcontract. Our prime customer desperately needs the equipment to stay on schedule and has written a letter acknowledging the DNAD and authorizing shipment. The Government QAR would not accept the letter. We tried a mod, that was rejected as well. According to the QAR, only a Government PCO or ACO can approve use of the DNAD. Unfortunately, the Navy PCO or ACO tell me they have no privity on our subcontract and they can't help. Anyone have any recommendations? Thanks, Rich
  9. I recognize good business practice and we do ask and usually get the prime number of 90+% of the orders. There are instances where we are third tier subs and our customer doesn't know or doesn't care. Having said that, there's a big difference between good business practice and mandatory flow down. If mandatory, what's the reference? Thanks
  10. As a subcontractor, we receive DPAS-rated orders from a number of DoD primes. In some cases, we are a third or fourth tier subcontractor. We dutifully pass down the DPAS rating to our subs. No problems there. The issue is that a number of our contracts with the primes do not provide a Govt prime contact number in their PO to us. Many of the buyers we deal with either aren't sure of the prime number or they indicate that there are numerous prime numbers because of the various funding sources. In most cases, they ignore our requests and we don't get the number. However, our in-plant QAR continues to issue CARs because our POs to our subs do not flow down the prime number. Typically this is just on rated orders but not always. The issue has now intensified to the point where the QAR will not allow us to ship, even though it's a rated order. Is there a regulation that requires primes to flow down the Govt prime contract number? If the prime does not provide, what recourse does a sub have? Thanks
  11. As a prime, we use a sub's component on a number of long term projects. Some of the contracts invoke Government Source Inspection that flows down to this sub's components. Some of the prime contracts do not invoke GSI. It's not always the same project or the same Agency. Seems to be a coin toss. Other than outside source inspection, the parts are identical and have the same sub part number. Our drawings for the different projects call out the same part number as well. To order these parts under separate part numbers would be costly as the sub will not offer a bundled price without a single contractual document. Without spending a lot of extra dollars that the Government refuses to pay (all FFP contracts) to create segregated inventory systems, what are the options? If we commingle the inventory under the same part number, do we violate the GSI requirements? Do we need to formally request the Government to invoke GSI on all projects so we can commingle parts whether they desire to or not? Some sage insight would be appreciated. Thanks
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