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    Questions: If a prime contractor is using a third party logistics company as a shipment center for GP, how should the prime contractor treat this logistics company as it relates to Government Property and how should the GPA review this? Should the prime be treating the logistics company as a subcontractor? If so, the applicable flow-down requirements and subcontractor reviews should be adhered to and are they viable for testing and review? If the contractor is treating the logistics company as an extension of their own company, meaning as an alternate site, how should the GP be housed or used for performance? How does the GPA handle this situation during auditing? If the third party logistics company is housed within a contractor's facility, how should the prime contractor handle this arrangement with regard to GP requirements? If the logistics company has their own/additional insurance, would this be considered violation contractual standards when GP is covered under the 52.245-1 clause? How could a PL liability / relief determination be made in these instances?


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    If a prime contractor is using a third party logistics company as a shipment center for GP, how should the prime contractor treat this logistics company as it relates to Government Property and how should the GPA review this?

    Should the prime be treating the logistics company as a subcontractor? If so, the applicable flow-down requirements and subcontractor reviews should be adhered to and are they viable for testing and review?

    Good questions.  I cannot speak to the GP requirements or FAR criteria, but I CAN answer your 3PL focused questions.  Generally speaking a 3PL is seen as a subcontractor to the prime.  Whether they are co-located under the same roof as the prime, or operating out of another facility, the work the 3PL provides is pursuant to the contract with the Prime (just like any other contractor providing product to the Prime).  If there is GFE assigned to the Prime - and then to the 3PL by the Prime, they are both equally accountable for its care and cognizance.

     

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