Need some clarification concerning Contractor First Article Testing (C-FAT) Requirements. I have an Army Critical Safety Item (CSI) coded with an AMC/AMSC of 1/C. There are three approved sources of supply, one of which is a small business (SB) manufacturer, the other two are very large manufacturers. Due to the expectation of receiving at least 2 SB quotes offering the product of at least 1 SB manufacturer, the solicitation was set-aside. The low evaluated offer is a dealer for one of the Large approved sources. They have quoted the C-FAT. Tech/quality is saying that dealers can not perform a FAT, but they have no references to confirm their argument. I have reviewed the FAR, DFARS, the DLAD, and our local guidance and have found nothing saying that they cannot perform the testing. I could not find anything prohibiting a dealer from performing a FAT on the DCMA websites either. The dealer/distributor is a major supplier to DLA and states they have the capabilities to perform the testing at their location (this I do not doubt). Is their anything prohibiting me from buying the parts of an approved source of supply through a dealer/distributor (adequate traceability provided) with a Contractor First Article Testing requirement CLIN? Can a dealer perform a Contractor First Article Test requirement?
At the Department of the Army Level, contractors are authorized to perform first article tests. See Paragraph 4-3a(2) within AR 73-1 for guidance. However, as this is an aviation program, there might be specific guidance that requires a government first article test rather than allowing a contractor first article test. The source for such guidance would be within the Army Aviation Engineering Directorate (AED) (http://www.redstone.army.mil/amrdec/RD&E/AED.html) at Redstone Arsenal, AL. Please consult with your AED representative for specific guidance in this case.
Reference Army Regulation 73-1 (http://www.apd.army.mil/pdffiles/r73_1.pdf)
"(2) First article test. The FAT may be required for quality assurance purposes to qualify a new manufacturer or
procurements from a previous source out of production for an extended period (usually 2 years) and to produce
assemblies, components, or repair parts conforming to requirements of the technical data package. Requirements for
first-article testing may be invoked in production contracts by citing the applicable Federal Acquisition Regulation first
article inspection and approval clause. When a first-article test is specified in a contract, it may not be waived or
changed without prior approval of the head of the contracting activity. First article tests may be conducted at
Government facilities or at contractor facilities when observed by the Government."
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