Sign In
  • Question

    Does COTS have to be in-compliance with Mil-Spec Standards and other gov't regulatory rules like FARs, etc.? If so, this seems to contradict the COTS concept to save money, time, etc. If the COTS is in-compliance with the contract or OEM standards, then is this adequate? Is there a general COTS regulatory statement for all shipping, packaging and handling requirements? Who would be the USG POC for specific shipping, packaging and handling questions?


    Answer

    Let me preface by stating that I am referencing publication that incorporates multiple policies: Army Regulation 700–15/NAVSUPINST 4030.28E/AFJMAN 24–206/MCO 4030.33E/DLAR 4145.7---Logistics Packaging of Materials. 
    It states:
    2–1. Requirements and specifications
    a. Materiel will be packaged to prevent damage and deterioration and to provide for efficient and economical handling.
    b. Use of commercial packaging should be considered before a contract is awarded. Commercial packaging will be used when such packaging is cost effective, and it can be determined that the materiel will not enter the military distribution system. Packaging personnel at the buying activity will make these decisions.
    c. Requirements for packaging will be developed for all DOD items to meet conditions described in this joint regulation.
    The requirements of MIL–STD–2073–1 will be used by all DOD components in the development, documentation, dissemination, and acquisition of packaging data
     
     
    So to answer the questions:

    Does COTS have to be in-compliance with Mil-Spec Standards and other gov't regulatory rules like FARs, etc.? 

    ANSWER----Use of commercial packaging should be considered before a contract is awarded. Commercial packaging will be used when such packaging is cost effective, and it can be determined that the materiel will not enter the military distribution system. Packaging personnel at the buying activity will make these decisions.  So the COTS packaging has to be in compliance with MIL-SPEC if the buying activity determined it to be so AND stipulated that in the contract (section D).
     
    If the COTS is in-compliance with the contract or OEM standards, then is this adequate?

    ANSWER---- Being in compliance with the contract only equates to the contractor meeting their contractual obligations, so they are in compliance.  However, according to the above references, the government has the obligation to determine if COTS packaging is sufficient (either meets the USG criteria or items not entering the military distribution system).  If it is not, they must stipulate in the contract that alternate packaging requirements be met, at which time the government owns the problem.
     
    Is there a general COTS regulatory statement for all shipping, packaging and handling requirements?

    ANSWER----I am only aware of the above references, which tend to say that we must determine if the COTS packaging meets the requirements of the military distribution system.  If not, we add additional requirements to the contract to make the COTS items compliant with the MIL STD requirements. The determining factor is if the item will enter the military distribution system.  If so, it is likely additional standards will be required (UID, ruggedized containers, etc).
     
    Who would be the USG POC for specific shipping, packaging and handling questions?

    ANSWER----I am not aware of a USG POC.  Though I will note that DLA handles a fair amount of COTS items and would most likely maintain a fair amount of expertise in this area. 
     


    Open full Question Details