Jump to content
The Wifcon Forums and Blogs

Recommended Posts

I have a vendor that is doing some dip-coating on a program through one of our higher tier vendors.  The higher tier vendor asked if the dip-coating company was ITAR registered and they are not - they are a small job shop.  The Prime contract is subject to ITAR but does that mean this 3rd tier vendor needs to be?  He's doing standard dip-coating on supplied parts, he isn't making the parts, just dip coating them to specs as provided.

Share this post


Link to post
Share on other sites

 

59 minutes ago, Jetsterkitty said:

The Prime contract is subject to ITAR but does that mean this 3rd tier vendor needs to be? 

I think that the DFARS clauses that invoke ITAR must be flowed down to almost all subcontracts. See e.g., DFARS 252.225-7048, Export-Controlled Items (JUN 2013), paragraph (e).

I don't know what the implications of that are for your vendor.

Share this post


Link to post
Share on other sites

Jesterkitty,

You seem to be suggesting that, essentially, what is going on is a commercial transaction (dip-coating of a part) that does not involve export. You are asking if that transaction is subject to, or perhaps exempt from, the requirements of the ITAR clause in your prime contract, the one that you have (or should have) flowed to your 2nd tier subK. I'm absolutely not an expert in this area, but I've always been told that the three main items that are to be protected under the ITAR are defense articles, defense services and technical data. Is the part the lower tier supplier is dip-coating a controlled defense product, where handling of the item by a foreign national would constitute a deemed export? You need to know the answer to that question.

If the ITAR clause was flowed to the 2nd tier subK then it was the 2nd tier subK's responsibility to comply with the clause in its subcontract. That would include checking, prior to award, to see if its (lower tier) supplier was ITAR-registered--if applicable to the transaction. What does your subcontractor say? (To your credit, though, you are taking responsibility for subcontractor compliance, as a good prime contractor should.)

That's all I've got.

Share this post


Link to post
Share on other sites

You mention that "The higher tier vendor asked if the dip-coating company was ITAR registered". I guess you mean the question is whether the dip-coating company is registered with the Directorate of Defense Trade Controls (DDTC). This is a standard compliance request by primes. Registration with the DDTC is required for all manufacturers, exporters, and brokers of defense articles, related technical data and defense services as defined on the United States Munitions List (Part 121 of the ITAR).   If dip-coating company does not a manufacturer or is providing dip-coating services, then they would not be required to register. That said there may still be export considerations if "ITAR controlled" parts are exported (or deemed exported). This will occur when the company employees non-US persons  or is itself located overseas.  Any vendor at any tier would be affected by the ITAR is they manufacture defense articles or generate controlled technical data. 

Share this post


Link to post
Share on other sites

Gosh, no wonder we had $600 toilet seats in Air Force C-5's (1970's prices). I was in two C-5's a couple of weeks ago and they still have the same awful latrines that they had in the 1980's. I hope that the Russians and Chinese stole our technical data for those toilet seats. Better yet, I hope they copied the (non-functioning) lavatory sink design. Of course, they weren't dip-coated. 🤑

Share this post


Link to post
Share on other sites
3 hours ago, joel hoffman said:

Gosh, no wonder we had $600 toilet seats in Air Force C-5's (1970's prices)

Joel:

That's fake news.

The item was not a toilet seat; it was a "Toilet Cover Assembly/4510-01-259-0538LH832862-403" for the C-5B, which was not operational until 1985. The DOD IG described the item as follows:

Quote

The toilet cover assembly is for the lavatory holding tank in the troop compartment of the C-5B aircraft. The cover is corrosion resistant, measures 34 inches x 28 inches x 0.25 inches, and is made of honeycombed reinforced fiberglass and polyurethane plastic with a stainless steel skin on both sides. It has a cutout for the toilet seat and several cutouts for piping and mechanical components of the holding tank. It has 32 drilled screw holes and several screws bonded to its surface. The manufacturing process involves labor and time-intensive processes, such as drilling, sawing, reaming, deburring, bonding, cleaning, passivating, and inspecting after each operation.

The USAF contract number for this noncompetitive procurement of sample items was F04606-88-C-0129-SA18, awarded August 19, 1988. The unit price for two was $1,868.15. The $600 item (actually $640) was a similar device for the Navy's P-3 Orion, not the C-5. An Air Force "should cost" analysis estimated a unit cost of $1,700. The contract was awarded at the quoted price, because the company refused to negotiate. According to the IG report:

Quote

The contracting officer also stated that similar cover assemblies on the VC-137 (Boeing 707) and the DC-10 aircraft cost $2,062 and $9,532, respectively. The cover used on the VC-137 aircraft is smaller and of the same construction. The cover on the DC-10 is considerably larger and constructed entirely of fiberglass.

The DOD IG's finding was: "We concluded that the toilet cover assembly was reasonably priced." They reached the same conclusion in the same report about the $640 "toilet seat." You can see the DOD IG report, No. 93-105A, JUNE 4, 1993, pg. 52, DTIC ADA376642, at handle.dtic.mil/100.2/ADA376642.

As a former Air Force member and DOD employee you should be ashamed of yourself for repeating such a false story and misrepresentation of the facts by the enemy, I mean press.

Sad.

Share this post


Link to post
Share on other sites
9 hours ago, Vern Edwards said:

Joel:

That's fake news.

The item was not a toilet seat; it was a "Toilet Cover Assembly/4510-01-259-0538LH832862-403" for the C-5B, which was not operational until 1985. The DOD IG described the item as follows:

The USAF contract number for this noncompetitive procurement of sample items was F04606-88-C-0129-SA18, awarded August 19, 1988. The unit price for two was $1,868.15. The $600 item (actually $640) was a similar device for the Navy's P-3 Orion, not the C-5. An Air Force "should cost" analysis estimated a unit cost of $1,700. The contract was awarded at the quoted price, because the company refused to negotiate. According to the IG report:

The DOD IG's finding was: "We concluded that the toilet cover assembly was reasonably priced." They reached the same conclusion in the same report about the $640 "toilet seat." You can see the DOD IG report, No. 93-105A, JUNE 4, 1993, pg. 52, DTIC ADA376642, at handle.dtic.mil/100.2/ADA376642.

As a former Air Force member and DOD employee you should be ashamed of yourself for repeating such a false story and misrepresentation of the facts by the enemy, I mean press.

Sad.

Vern, I'm glad you know all the facts. Thanks. 

Here is some more fake news, I guess. "Only the Pentagon Could Spend $640 on a Toilet Seat" 

https://www.thenation.com/article/only-the-pentagon-could-spend-640-on-a-toilet-seat/

I never had the opportunity to fly on a C-5 as an Air Force member between 1967 and 1976.  Saw the first one during the summer of 1968 or 69.  I flew on most every other cargo type plane that the Air Force or Guard still had in their inventories but the C-5  and the C130.  As an Army employee living in Saudi Arabia in the mid 1980's, My family and I took numerous trips to Europe or to the US and back to Dhahran on C-5's over a three or four year period.  I also flew back to Germany from Dhahran during Desert Storm in 1991 on one. I also finally got to fly all over the Arabian Penninsula in C-130's. My daughter was a C130 pilot. The sinks in the C-5's were never once operable on any of those flights. They issued hand wipes instead. The toilets stunk and they looked horrible. 

My son-in-law just retired at Dover AFB, where he flew both C-17's and C-5M's in his last position. He is a seasoned C-17 pilot, former  DO, former Squadron Commander, former Instructor and Check Pilot, etc. The Wing organized some tours for a dozen of us of a C-5M that is undergoing a major (8 year cycle) tear down inspection and systems' overhaul plus a C-5 , a C-17 and C130 on the flight line. We all, including my 4 year old grandson, had a once in a lifetime opportunity to walk from the wing tip, along the wing, over the fuselage and over the length of the other wing on the C-5 in the maintenance hangar.  What an amazing experience! 

When we climbed up to the upper deck passenger area on the operational C-5, I immediately checked out the latrine and saw what appeared to be the same "crappy" looking (no pun) toilet and sink. The Loadmaster told me that they finally got "blue water" capability for the toilets, so they stink less and - oh  - the sinks still often don't work. There were hand wipes in the sink bowl. But the C-5 crew compartment up front looks like a first class cabin on a train. Fine digs! 

We were also allowed a special tour through a C-130 at the Museum at Dover that both my daughter and my son-in-law flew on its last operational flight to the boneyard at Davis-Monthan AFB, AZ.

I am darned proud of today's Air Force anyway. My daughter became a pilot because of those C-5 flights as a very young girl. Maybe her son will always remember the wing walk and running up and down all the cargo bays that day at Dover...

 

Share this post


Link to post
Share on other sites

I don't understand why the Air Force didn't simply specify commercial airliner bathroom fixtures in the passenger compartment of the C-5. 

Share this post


Link to post
Share on other sites

Joel:

If you want to complain about an aircraft, complain about a long, below radar, low altitude approach to Vieques Island in a C-124 that made my entire Army platoon airsick. I was on the upper deck and was so sick I couldn't put on my parachute and attach my equipment bag and rifle without help from a fellow squad member. As the plane climbed to jump altitude (1,250 feet) I had to make my way forward, climb down a vertical ladder to the main deck, and then turn aft  to line up to jump. The @#$$%@ crew chief made us take our barf bags out the door. We exited while over the ocean and had to wear Mae West life vests and carry shark repellant in case we didn't make it inland. We were told not to do a PLF if we hit the water, because we'd probably fall onto coral and get cut up. They said the Navy would pick us up if we hit deep water. (We practiced water landings at Fort Bragg the week before.)

I was never so happy to jump out of an airplane in my entire life. When I hit the ground I laid there in awe watching the unending line of aircraft drop an entire brigade of the 82d Airborne and then heavy 155 artillery pieces under huge canopies. I watched until my sergeant came up and told me to stop sightseeing and get my a** to the company assembly area. I was 18. Later that day, while I was standing guard near the Tactical Operations Center, Lt. Gen. Bruce Palmer, Commander, XVIII Airborne Corps, brought a group of NATO officers over to show me off as "One of my 18 year olds."

It was Operation Quick Kick VII, April 1965. I think it was practice for Cuba.

Compared to C-124s, C-5s were luxury planes.

Share this post


Link to post
Share on other sites

Thanks Jamaal.

Hey, Vern, thanks for your service! GREAT story. The first big plane I flew in as a Cadet was a C-124 Barfmaster in 1968 - I mean "C-124 Globemaster II" the official nickname for the plane was "Barfmaster" though.  I was 19. My brother flew to Europe in one in 1961 as a 20 year old Air Force Cadet, shortly before the Russians erected the Berlin Wall.

(I have 7 static line jumps made at about that same altitude but from a Cessna 182 at a sport parachute club in Xenia OH while TDY to Wright Pat. Three hours of training instead of the three week basic parachute course with the Army.) 

You are correct about the C-5 luxury. The passenger compartment in the C-5 is actually quite nice with big, comfortable AF Blue seats.

You are one of my heroes...My brother was my other one. 

Share this post


Link to post
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now

×