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  • Question

    Non-repairable aircraft parts removed from aircraft by Government, whos is responsible for disposal?


    Answer

    FAR 52.245-1 states “Government-furnished property” means property in the possession of, or directly acquired by, the Government and subsequently furnished to the Contractor for performance of a contract. Government-furnished property includes, but is not limited to, spares and property furnished for repair, maintenance, overhaul, or modification. Government-furnished property also includes contractor-acquired property if the contractor-acquired property is a deliverable under a cost contract when accepted by the Government for continued use under the contract. 

    Based on the background provided it appears the aircraft has been furnished to the contractor for repair, maintenance, overhaul, or modification.  The aircraft is Government-furnished property (GFP), thus the components that were installed in the aircraft at the time of receipt are inherently GFP.  Therefore, the contractor has stewardship responsibility and is responsible for disposal in accordance with FAR 52.245-1 as well as the CLIN you referenced, which states that the contractor shall provide disposal of consumable and non-repairable assets. 

    FAR 52.245-1(j) Contractor inventory disposal states "Except as otherwise provided for in this contract, the Contractor shall not dispose of Contractor inventory until authorized to do so by the Plant Clearance Officer or authorizing official." Also, if DFARS 252.245-7004 Reporting, Reutilization, and Disposal is included in the contract, the contractor shall use the Plant Clearance Automated Reutilization Screening System (PCARSS). DFARS 252.245-7004 reads in part: 

    (b) Inventory disposal schedules. Unless disposition instructions are otherwise included in this contract, the Contractor shall complete SF 1428, Inventory Schedule B, within the Plant Clearance Automated Reutilization Screening System (PCARSS). Information on PCARSS can be obtained from the plant clearance officer and at
    http://www.dcma.mil/ITCSO/CBT/PCARSS/index.cfm.

    Note: Aircraft components are not scrap and should not be disposed of as such.  DFARS 252.245-7004(a)(4) states the following:

    "Scrap” means property that has no value except for its basic material content. For purposes of demilitarization, scrap is defined as recyclable waste and discarded materials derived from items that have been rendered useless beyond repair, rehabilitation, or restoration such that the item’s original identity, utility, form, fit, and function have been destroyed. Items can be classified as scrap if processed by cutting, tearing, crushing, mangling, shredding, or melting. Intact or recognizable components and parts are not “scrap.”

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