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About cthewades

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  1. cthewades

    Government Liability

    We will be training Government pilots in Government-owned and company-owned aircraft. In the commercial realm, we require a significant insurance policy but the Government would not issue a policy. Would we would be covered under some law, act or regulation. Can someone tell me how we are covered if one of our trainers are hurt during a training period or our aircraft is damaged? Would we just need to carry the insurance and charge that to the Government?
  2. cthewades

    DFAR 252.225-7012 - Qualifying Country

    I missed that and ©(5). I appreciate the prompt response. This is helpful.
  3. We are getting ready to propose a product which uses a fuel cell made out of synthetic fabric. This fabric comes from Italy, a Qualifying Country under 252.7002-2. In the clause 252.225-7012, it defines "qualifying countries" but it does not state what exemptions are provided to them. I have been told that QC qualify for an exemption but I do not see in the FAR or DFAR where an exemption is specifically granted. I can only infer based on language. Does anyone know how this is interpreted in the Government - particularly case law or board of appeal findings, etc.
  4. cthewades

    Technical Data

    I am not sure that "responding to customer phone calls would be considered "technical data" per FAR 2.101 since it most likely is "incidental to contract administration"; however, the "troubleshooting the X model of equipment" would be difficult to call "incidental to contract administration". But, I agree with Mr. Edwards, that an attorney should be consulted since we are working off a vague description.
  5. This does help but the section states, "affiliates of the contractor under a common control shall be on the basis of cost incurred..." I am not sure what is meant by "under a common control". We are owned by a foreign entity with completely separate reporting structure. Our commonality is that we both report to the same holding company. We are covered by FOCI whereas they are not since they are commercial. Do we still fall within the parameters of "common control"?
  6. When buying a commercial item of greater than $15M, how do I determine what we need to flow-down to a subcontractor of commercial items? If the subcontractor is an affiliated company, does this change anything? If I read the FAR correctly, we would flow-down the clauses in Part 12 and those clauses superceded anything in other Parts of the FAR. What is not clear is what requirements would need to be flowed-down. For example, in subcontracts over $700k, small business reporting is required. Part 12 is silent and I am told that we do not have to flow this down to subs. What about the other mandatory flow-downs that would be difficult for the commercial supplier to comply?