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  • Question

    Does all Government owned Special Tooling other than tools having PSI or calibration requirements need to have some form of documentation kept on file for inspections that are performed visually by a machine operator prior to using tool?


    Answer

    What does the FAR tell us?  FAR 52.245-1 (1)(f) “(ix) Maintenance. The Contractor shall properly maintain Government property. The Contractor's maintenance program shall enable the identification, disclosure, and performance of normal and routine preventative maintenance and repair.” 
    “(iii) Records of Government property. The Contractor shall create and maintain records of all Government property accountable to the contract, including Government-furnished and Contractor-acquired property. (A) Property records shall enable a complete, current, auditable record of all transactions and shall, unless otherwise approved by the Property Administrator, contain the following…”
    Now, if your “visual inspection” is a process you perform that is “outside” your documented normal routine preventative maintenance program then you would not necessarily consider documenting this practice a requirement.  Simply because your normal preventative maintenance documented within your procedures ensures that Government property, in your possession, is being controlled, used, preserved, protected, repaired and maintained in accordance with contract requirements.  The Property Administrator has the authority to determine if your procedures adequately address these risks.  However, if this “visual inspection” process is documented within your procedures and/or is part of your normal routine preventative maintenance program, then yes, you have a requirement to document the process when it is performed. Otherwise, how do you or your customer know it ever happened or that it is regularly being performed?  It is easy to see the logic within your perspective that if there is a problem then it will be documented when it is addressed eliminating some administrative burden; however, there must be some type of evidence in order for a contract  required process to be auditable.  Many undocumented processes increase risk because this gives the impression of non-importance and these practices will tend to be low priority especially when schedules are tight or resources are low.  One of the Property Administrator’s primary jobs is to ensure risk is being mitigated on behalf of the Government and it sounds as if this is the perspective in which their concern is based.


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