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    1. Can we pursue the IM rocket motor change as a 'safety modification'? 2. What is the definition of a safety modification and what references cover it? 3. What is the definition of 'increased capability' and what references cover it? 4. Could the change be considered a modification that we can do via an engineering change proposal (ECP) or is it a New Start? 5. What does 'previously justified' and 'normal budget process' mean in the definition of a New Start found in DoD Financial Management Reg 7000.14-R, chapter 6, para 060401E? 6. Would competitive prototyping be required for the new rocket motor? 7. What entity within DoD determines if we have met the intent of the IM Statutory Requirement (Military Law) of United States Code, Title 10, Chapter 141, Dec 2001: 'Section 2389. The Secretary of Defense shall ensure, to the extent practicable, that munitions under development or procurement are safe throughout development and fielding when subject to unplanned stimuli'?


    Answer

    You asked quite a few questions but they all center on the fundamental
    requirement for your program to now meet IM compliancy.  It sounds like your
    program was recently classified as such much later in its life cycle?
    Typically, safety is addressed throughout the acquisition process, and any
    system containing energetics would comply with insensitive munitions criteria.
    I'm not sure where in your program things changed, but because of DoD'
    experience with sympathetic detonation incidents, it developed specific
    standardized sets of IM testing criteria for use by all programs for
    evaluating IM compliance --and protecting lives.  Depending on where your
    program was at the time the JROC (the only authority who can waive this
    requirement) apparently authorized a temporary waiver for certain reasons.
     
    The testing criteria for IM compliancy are outlined in the Defense Acquisition
    Guidebook (DAG), Chapter 9.  The DAG is a tremendous source of information
    and can answer many of your questions, especially paragraph 4.4.9 with respect
    to IM compliancy (under the Systems Engineering paragraph, Chapter 4).  Table
    4.4.9.T1. addresses the tests, threats, passing criteria, and configuration.
     
    A single standardized set of IM tests and passing criteria are to be used by
    all Components for evaluating and reporting on the IM compliance status of the
    munitions in their portfolio. These standards are the default for use for
    typical munitions programs. For atypical circumstances, deviations will
    require review and approval by the JROC through the Joint Capabilities
    Integration and Development System (JCIDS).
     
    All programs are expected to develop a Programmatic Environment, Safety and
    Occupational Health Evaluation (PESHE) to document to address all the hazards.
    PESHE serves as a repository for top-level Environment, Safety, and
    Occupational Health (ESOH) management information to include:
    .  Identification, assessment, mitigation, and acceptance of ESOH risks,
    .  On-going evaluation of mitigation effectiveness, and
    .  Compliance Schedule for National Environmental Policy Act (NEPA)
    documentation.
     
    The PESHE communicates to program managers and others the status of the ESOH
    effort and ESOH risk management for the system.  If the program's original
    Acquisition Strategy did not adequately include a summary of the PESHE and the
    NEPA, it needs to. The program's Systems Engineering Plan (SEP) should also
    include a reference to the strategy for integrating ESOH into Systems
    Engineering processes.
     
    Ordinarily, the Lead Safety Engineer would ensure IM compliancy requirements
    are incorporated into the Test & Evaluation Master Plan (TEMP) followed by a
    plan of action and milestones (POA&M) describing how the program will meet
    these requirements.  Consequently, the first step is to develop the POA&M for
    the IM compliancy if not already done so.  The program manager and his/her
    team would have to determine the extent of this safety modification and build
    an acquisition strategy (which could range from a minor modification to an
    extensive one, to include everything that would reduce risk  including
    prototyping, competition, etc.--all within reason). The original acquisition
    strategy should be used as a starting point for any alternate pursuits.  The
    POA&M should also revisit the  SEP along with all the other existing program
    documentation and include a comprehensive Risk Management (RM) program with
    specific procedures that would address and mitigate (and perhaps not
    necessarily eliminate) all known risk factors.
     
    Safety modifications are not a short cut to increased capability (the JCIDS
    process addresses new capabilities and follows a very deliberate process).  I'm
    not sure of the connection to your question on "increased capability."  It
    doesn't sound like you're providing the warfighter with increased capability.
     
    The thresholds and criteria for Nunn-McCurdy breaches are well articulated
    (e.g. when a program's unit cost growth exceeds (or breaches) the original or
    the latest approved acquisition program baseline (APB), DoD must report it to
    Congress).  This safety modification (and I think that's how it should be
    codified) could indeed result in a Nunn-McCurdy breach but the program office
    should be able to substantiate "why."  Ultimately, the SECDEF's assessment to
    Congress would address the new estimate if the cost delta exceeds a percentage
    increase in the APB threshold.  It's up to the responsible component to fund
    it in the POM process.
     
    I hope this answers most of your questions.  You would be well served by
    researching some of your service-unique policies and directives that might
    shed more light on the subject.  Good luck!
     

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