1) Since COTS parts are an exception from the specialty metal restriction, do we have to document every instance when we utilize this exception? Meaning my team designs a new Special Tool and there are 7 items purchased from McMaster Carr, do we have to document the usage of all 7 items anywhere other than the tool drawing?
2) Are fasteners exempt from the clause if they are incorporated into a Special Tool (end item assembly)?
DFARS clause 252-225-7009, Restriction on Acquisition of Certain Articles Containing Specialty Metals does not apply to your situation as presented/framed.
The prescription for use of DFARS clause 252-225-7009, is located at DFARS 225.7003-5(a)(2) and states the following:
(2) Use the clause at 252.225-7009, Restriction on Acquisition of Certain Articles Containing Specialty Metals, in solicitations and contracts, including solicitations and contracts using FAR Part 12 procedures for the acquisition of commercial items, that—
(i) Exceed the simplified acquisition threshold; and
(ii) Require delivery of any of the following items, or components of the following items, if such items or components contain specialty metal:
(B) Missile or space systems.
(D) Tank or automotive items.
(E) Weapon systems.
From you background statement it’s discernable that your contract involves the fabrication/delivery of tooling and does not involve delivery of any of the items (A)-(F) listed items.
· As embedded