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The Aircraft Operations Community serves as the DoD's repository for all Contractor Flight and Ground Operations oversight Workload and Performance training, documents, publications, and Job Support Tools necessary for the Government Flight or Government Ground Representative to be successful in the execution of FAR 42.302(a)56, "Maintain Surveillance of Flight Operations"
"If an audit wasn't documented, it never happened!"
You've heard it before, and it's as true today as it's always been. In the effort to assure "safe and effective flight and ground operations", your appointed duty is to audit and document the Contractor's compliance (or non-compliance) to their flight and ground operating procedures. Absent from the current DCMA INST 8210.1 (The Combined Instruction, or 'CI') is a requirement that the GFR/GGFR create and maintain a Surveillance Plan. While it may not be a requirement, there is no more efficient way to assure "safe-and effective" than taking the up-front time to develop a logical surveillance strategy that includes a schedule with audit frequencies, sample sizes and randomization (if necessary), and data analysis - from there you're on autopilot!
Surveillance (a.k.a. "Auditing") is how we assure "safe and effective". The Contractor could have the perfect set of Procedures, but not until there exists empirical evidence of the employees' following (or not following) those Procedures can we take a 'safe-and effective' determination. Yes, the Contractor could have a really, really great set of FOPs and GOPs, but the majority of elevated risk exists from 'great' Procedures not being complied with - you'll never know of the elevated risk unless you audit. Collected data serves as justification when continued procedural noncompliance warrants the withdraw of procedure(s) approval or, if necessary, removal of the Assumption of Risk by the Contracting Officer. Collected data is also rooted in self-preservation as well; Woe is the GFR/GGFR who, after a Class-B mishap involving a lost tool, is asked by the Safety Investigation Board for his/her non-existent tool control surveillance data!
Have you completed the Contract Receipt and Review (CRR) yet?
Unless you are certain the contract is void of any requirements related to the CI, building a surveillance plan before performing the CCR is the 'cart before the horse' indeed! Yes, you would site the Contractor for exceeding 8 MPH straight line F-15 tow speed as described in their towing procedure. But without performing a CCR, you wouldn't know that T.O. 1F-15C-2-09JG-00-1 is on contract and limits this speed to 5 MPH. If a CCR has not been completed, go to "Contract Receipt and Review" on this CoP's home page for more information (under construction). This review is critical to understanding what Service guidance, outside of that specified in the Combined Instruction, has been placed on contract and how language in the performance work statement/statement of work, sections C or J of the contract may affect how Procedures are written potentially influencing surveillance.
Scope of Operations
A surveillance plan must take into account the scope of operations at the facility (e.g. footprint, employees, equipment, Operational Tempo).
The surveillance should be risk based. The CI directs an annual survey (semi-annual for non-resident sites). Ideally, the Surveillance Plan annual update should be scheduled for just after the annual survey. This provides structure to the annual cycle. For a new contract facility, a comprehensive post-award survey is recommended. Based on this initial survey, a risk based plan can be developed. The GFR/GGFR must balance the resource requirements for each plan with the risk and number of facilities over which they have oversight. The plan needs the flexibility to be adjusted based on the data analysis and thresholds, but remain mostly consistent in order to develop reliable trend data. Major updates to the plan should be made following the annual survey thus restarting the cycle.
There is no official or required Surveillance plan format! Whatever format used, the schedule should be detailed enough to identify surveillance event frequency from weekly events through annual events.
When creating this template, care was taken to assure that is could be used by any APT. Therefore, certain assumptions were taken during its development. Keep these in mind when using/modifying the template for your own use...
Assumption #1: The Contractor is responsible for enforcing all flight (chapter 4), ground (chapter 5), and contract safety (chapter 6) requirements in the CI - very few Contractors are responsible for all elements therein. Your first task is to determine which elements and sub-elements in the template are applicable to the Contractor's responsibility.
Assumption #2: The only contract requirement that exists from which the Contractor bases Procedures in the CI. The sub-element check sheets in the template are based purely from the CI. It may be necessary to modify the check sheet questions to conform to the specific contract requirement (e.g. Air Force T.O. 00-20-1), or add an element that the specific contract requirement that isn't addressed in the CI.
Assumption #3: The Contractor's Procedures are perfect! Why? Surveillance determines if a Contractor's Procedure(s) are "safe-and-effective", not just that they are complying with them.
Inspection Sampling Criteria
Suppose you are the GGFR at a large maintenance depot, and your contractor employs 274 individual company-owned tool 'boxes'. How do you assure 'safe-and-effective'? Inspect all 274 each audit? Inspect a portion (say 10%) each audit until all toolboxes have been inspected?
Both of the above are poor methods. Inspecting all 274 toolboxes each audit will 'assure' all you ever do is inspect toolboxes! The second method listed above is not horrible, but there's a better way...
A logical approach to determine an appropriate sample size can be borrowed from the Quality Assurance. Launch the above link for detailed information on how to create a sampling plan.
You've got your surveillance plan and, if necessary, have determined you sample size(s), so what's next? If you want to achieve the 95% confidence level as described in the previous section, you'll need to randomly select you sample from the population. Launch the above link for detailed information on how to create a random sample calculator.
We've seen it many times! A GFR cites his Contractor for not complying with (e.g.) the AFI 21-101 job guide for T-6A towing. The contractor answers the level 2 Corrective Action Request (CAR) by revising their Procedure's compliance to the job guide. 2 weeks later you get a nasty-gram from the Contracting Officer, asking you why she received a bill for updating Procedures to a requirement that was NOT on contract. Whoops! Had a CRR been accomplished, such a "Constructive Change" (or just plain embarrassment) would have been avoided.
CRR is the process by which we receive and review contracts and modifications to identify customer requirements for contract Administration Services, or "CAS". Assignment of CAS functions is governed by FAR Subpart 42.202 and listed in FAR Subpart 42.302. Specifically, aircraft flight and ground operations surveillance is governed by FAR Subpart 42.302(a)56.
Developing an APT surveillance plan starts with a thorough review of the contract requirements (DCMA-MAN 8210-2, para 3.7 provides excellent guidance). This review is critical to understanding the Service Guidance, outside of that specified in the Combined Instruction, has been placed on contract and how language in the PWS/SOW/SOO, and sections C, H, I, and J of the contract may affect how Procedures are written, potentially influencing surveillance.
If not, you may be missing something critical to aircraft operations! Quite often the Contracting Officer/COR feels you only need the requirements document (PWS/SOW/SOO). While your focus will center on the PWS/SOW/SOO and sections C, H, I, and J (attachments), A complete CRR requires you to review the Schedule (sections A thru H), section I, and all attachments in section J.
DCMA policy requires the CRR completed within 30 days of receipt for DCMA-administered contracts. While you may not be assigned to a DCMA-administered contract, you should strive to complete the CRR within this time frame.
Has a Post-Award Orientation Conference (PAOC, or PAO) been conducted?
PAO aids both the Government and contractor personnel in achieving a clear and mutual understanding of all contractual requirements. It also enables the identification and resolution of potential contract administration problems. While your Contracting Officer may determine that a PAOC is not required, you should request that one occur.
DO NOT expect to find a contract requirement/reference (outside of the Combined Instruction (CI)) for for every CI element. For example:
Paragraph 4.1.1. "General Flight Rules" states that "Contractor flight operations shall follow Service Guidance". It's not necessary for section I of the contract schedule to list, say, AR95-01, "Flight Regulations" because it's already 'on contract' via the CI, or;
You cannot find any requirements related to paragraph 5.5, "Medical (Physical) Requirements for Ground Personnel". As with the previous example, the CI states as policy that personnel who perform certain ground functions must receive an examination at least every 5 years - enough said!, or;
You cannot find any requirement/reference relating to paragraph 5.8, "Aircraft Servicing" in the contract. This is not a contract deficiency! The contractor is still required to address all CI sub-elements in their Aircraft Servicing Procedure. Such a circumstance is addressed in the "Procedures Review" performance support asset (under construction).
Use this checklist when performing CRR. IT contains process instructions that will aid you thru the process.
In its most basic form, a Procedure is nothing more than a statement of how something gets 'done' - how a task is completed, the means to achieve a specific end. We use Procedures all the time; when we assemble our children's bicycle, we follow the instructions to assure the bike is assembled correctly, and most importantly, it's safe for our child to ride.
In Industry and the Military, there are many, many forms of Procedures. Most familiar to us are technical orders or technical manuals. We use these as a means to follow a sequence of steps or tasks to assure, say, the digital engine control is installed correctly, or the aircraft is properly configured for landing. Not completing all required tasks of following the required sequence could have dire consequences!
Flight and Ground Operating Procedures (FOPs and GOPS) are the same! They are the Contractor's written description of 'how' they intend to meet the procedural requirements set forth in the Combined Instruction.
The Combined Instruction
The Combined Instruction (CI) sets forth the minimum requirements that must be addressed in the Contractor's Procedures. Chapter's 4 (Flight), 5 (Ground), and 6 (Contract Safety) list processes the Services have deemed as elevated risk to DoD aircraft, and therefore require a Contractor-developed Procedure to mitigate this risk. As an example, Chapter 5 states the Contractor must have an approved procedure for the "Mooring and Tie-down" of aircraft (5.9.3). Specifically, the CI states the following sub-elements must be addressed:
5.9.3.1 Aircraft-specific tie-down points
5.9.3.2 Ground tie-down locations
5.9.3.3 Use of approved tie-down equipment for the specific aircraft
5.9.3.4 Grounding requirements
The items above represent the 'what' that must be addressed in the Contractor's Mooring and Tie-Down Procedure. How the Contractor provides the required fidelity (the 'how') can come from several sources.
Use of Service Guidance:
Service Guidance (TOs/TMs) specified in the contract is the 'best-case-scenario' because Service Guidance is generally accepted to meet or exceed the desire for safe and effective flight and ground operations. If (per the example above) the Contract specifies that T.O. 1C-130H-2-10JG-00-1 will be used for all C-130 mooring and tie-down, it would be a simple matter of the Contractor's Procedures stating "5.9.3.1 Aircraft-specific tie-down points will be IAW T.O 1C-130H-2-10JG-00-1" for this and each sub-element. ALL CI sub-elements must be addressed in the Procedure, even those not addressed by the TO/TM.
Industry Standards/Best Practices:
Industrial standards and best practices may also be specified on the contract. Such standards are gaining broader acceptance because they generally take into consideration the aggregate experience of the commercial workforce which is largely comprised of those who served in the military as maintainers and carry forward this experience to the Contractor. As with Service Guidance, all CI sub-elements must be addressed, even those not in the industry standard.
Contractor Wholly Developed Procedures:
It's not uncommon that, after you complete your Contract Receipt & Review, you find the contract doesn't state with what guidance the Contractor will develop a procedure for, say, Corrosion Control - THIS IS NOT A CONTRACT DISCREPANCY! They're still required to submit the procedure for your approval, you just need a standard with which to make a 'safe and effective' comparision. This 'comparision' is generally accomplished using the applicable Service Guidance. This 'comparision' will indicate if the Contractor's 'home grown' Procedure is safe and effective. However, you CANNOT compel the Contractor to comply with the Service Guidance used for comparision.
The AO Procedures Review Guide can be a very useful reference when reviewing Procedures. The columns of this tool can be altered to represent alternate data such as 'does the procedure address all CI elments and sub-elements?'
While there are as many 'ways' to review Procedures as there are stars in the sky, we'll look at the "Big-to-Small" method. It provides multiple opportunities to catch errors:
We have approved GOPs but there was just a bridge contract issued and a new contract number. The program office is telling me to send an interim approval to use the GOPs on the new contract. Has anyone ever heard of this or done it?
DoD is proposing to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to revise the requirements related to the assumption of risk associated with aircraft under DoD contracts. The current requirements are outdated and in need of revision to clarify applicability due to numerous changes in aircraft contract situations and the emergence of contracts for small, unmanned aircraft.
SCENARIO
COMMENTS
Here is the DFARS link to the new GFRC https://www.acquisition.gov/dfars/252.228-7001-ground-and-flight-risk and the presribing additional clause DFARS 228.371 https://www.acquisition.gov/dfars/228.371-additional-clauses.#DFARS_228.371 effective date 03/22/2023
The final rule for DFARS Case 2020-D027, Ground and Flight Risk, is currently being edited and prepared for final review and clearance. Publication is estimated in Q1 of FY 2023.
In 8210.1C, when going from CAO to PAO there is a statement that says there is a "significant shift in responsibility and liability to the government contracting agency occurs"
What does this mean? I understand the additional scrutiny that comes with all the processes, but specifically what does "liability to the government" mean? Does that mean the government is solely on the hook for the full payout of the aircraft in a mishap situation?
SCENARIO
COMMENTS
What document did you take the quote from? Generally, the GFRC is only used for COCO aircraft if the contract service is something the commercial insurance will not cover. Therefore, there is usually no need to 'cancel' the commercial insurance except for the duration of the contract. If it is such that the aircraft is in and out of PAO status, the insurance could be kept, but may only cover CAO operations. All this depends on specific contracts and insurance fine print.
The "shift in responsibility and liability" refers to the Service assuming responsibility for airworthiness and liability varies based on type of operations...this is not simply mishap cost liability...for example, if operating PAO outside the NAS, the designation is 'State Operations' and an example of additional liability could be the legal liability incurred if the contract does not follow the Foreign Clearance Guide for entry into another nation's airspace.
When the PAO contract does include the GFRC and a GFR, how is the best way to explain, "At its unilateral discretion, the Government may incorporate DFARS 252.228-7001 Ground and Flight Risk in the future if circumstances warrant and require cancellation of commercial aircraft insurance." I interpret it as being a point that is not covered by the contractor's insurance. Acts of War? Incidents that affect other DoD entities or host nation personnel or procedures? Or, anytime their own insurance does not cover an incident? I view it as anything that the government will now have to either settle or explain or investigate. But, the contractor is still required to comply with parragraph b, right? At all times? As a way to ensure that the contractor is operating in a safe manner, etc. (And by GFR discretion as stated in attchment 16, as well)
CAO (Civil Aircraft Operations) have a commercial purpose and are typically flown by a commercial entity (Delta, United, etc.) - they fly under 14 CFR. What we 'do' doesn't enter into the conversation when a commercial entity is performing CAO. PAO (Public Aircraft Operations); CANNOT have a commercial purpose, involves aircraft either owned by a US Government entity or a commercial entity and, fly under the Military Services' general flight rules. Under PAO, the "shift in responsibility and liability" varies. If it's a contractor-owned aircraft flying PAO, the USG's responsibility and liability is typically low since the GFRC would not be applicable. The Government entity's responsibility and liability for Government-furnished or new production aircraft could be significantly higher, but only as directed by the limits of liability outlined in the GFRC.
What constitutes as maintaining a qualification when under contract with the Air Force?
IAW DCMA Inst. 8210.1C Chg. 1 Para. 4.2.5, "An approved DD Form 2628 is valid as long as the crewmember maintains their qualifications for the contractor."
Scenario A. A contractor crewmember's required periodic evaluation expires, which of the following should occur:
The DD Form 2628 shall be revoked/canceled immediately.
The DD Form 2628 shall remain active provided the contractor does not perform in their aircrew specialties until the evaluation is satisfactorily completed.
Regardless of the action chosen above, at which point (if any) should the GFR be notified of the evaluation expiration?
Scenario B. A contractor crewmember fails their required periodic evaluation, which of the following should occur:
The DD Form 2628 shall be revoked/canceled immediately.
The DD Form 2628 shall remain active provided the contractor does not perform in their aircrew specialties until the requalification evaluation is satisfactorily completed.
Once again, regardless of the action chosen above, at which point (if any) should the GFR be notified of the failure and requalification plan?
SCENARIO
COMMENTS
Sorry for the delaayed response to this:
Per the CI, the crewmember's DD2628 in scenario A is no longer valid. The crewmember ca nregain the qualification thru the DD2627/DD2628 process as outlined in the CI, and per the qualification requirements per the Service. The GFR should have access to some form of product which provides all crewmembers currencies and qualifications.
For scenario B, the second choice is the most reasonable if a simple recheck is the course of action. If re-training is required (the key word being "training") This would require the official training request via the DD2627, and completion via the DD2628.
"If an audit wasn't documented, it never happened!"
You've heard it before, and it's as true today as it's always been. In the effort to assure "safe and effective flight and ground operations", your appointed duty is to audit and document the Contractor's compliance (or non-compliance) to their flight and ground operating procedures. Absent from the current DCMA INST 8210.1 (The Combined Instruction, or 'CI') is a requirement that the GFR/GGFR create and maintain a Surveillance Plan. While it may not be a requirement, there is no more efficient way to assure "safe-and effective" than taking the up-front time to develop a logical surveillance strategy that includes a schedule with audit frequencies, sample sizes and randomization (if necessary), and data analysis - from there you're on autopilot!
Surveillance (a.k.a. "Auditing") is how we assure "safe and effective". The Contractor could have the perfect set of Procedures, but not until there exists empirical evidence of the employees' following (or not following) those Procedures can we take a 'safe-and effective' determination. Yes, the Contractor could have a really, really great set of FOPs and GOPs, but the majority of elevated risk exists from 'great' Procedures not being complied with - you'll never know of the elevated risk unless you audit. Collected data serves as justification when continued procedural noncompliance warrants the withdraw of procedure(s) approval or, if necessary, removal of the Assumption of Risk by the Contracting Officer. Collected data is also rooted in self-preservation as well; Woe is the GFR/GGFR who, after a Class-B mishap involving a lost tool, is asked by the Safety Investigation Board for his/her non-existent tool control surveillance data!
Have you completed the Contract Receipt and Review (CRR) yet?
Unless you are certain the contract is void of any requirements related to the CI, building a surveillance plan before performing the CCR is the 'cart before the horse' indeed! Yes, you would site the Contractor for exceeding 8 MPH straight line F-15 tow speed as described in their towing procedure. But without performing a CCR, you wouldn't know that T.O. 1F-15C-2-09JG-00-1 is on contract and limits this speed to 5 MPH. If a CCR has not been completed, go to "Contract Receipt and Review" on this CoP's home page for more information (under construction). This review is critical to understanding what Service guidance, outside of that specified in the Combined Instruction, has been placed on contract and how language in the performance work statement/statement of work, sections C or J of the contract may affect how Procedures are written potentially influencing surveillance.
Scope of Operations
A surveillance plan must take into account the scope of operations at the facility (e.g. footprint, employees, equipment, Operational Tempo).
The surveillance should be risk based. The CI directs an annual survey (semi-annual for non-resident sites). Ideally, the Surveillance Plan annual update should be scheduled for just after the annual survey. This provides structure to the annual cycle. For a new contract facility, a comprehensive post-award survey is recommended. Based on this initial survey, a risk based plan can be developed. The GFR/GGFR must balance the resource requirements for each plan with the risk and number of facilities over which they have oversight. The plan needs the flexibility to be adjusted based on the data analysis and thresholds, but remain mostly consistent in order to develop reliable trend data. Major updates to the plan should be made following the annual survey thus restarting the cycle.
There is no official or required Surveillance plan format! Whatever format used, the schedule should be detailed enough to identify surveillance event frequency from weekly events through annual events.
When creating this template, care was taken to assure that is could be used by any APT. Therefore, certain assumptions were taken during its development. Keep these in mind when using/modifying the template for your own use...
Assumption #1: The Contractor is responsible for enforcing all flight (chapter 4), ground (chapter 5), and contract safety (chapter 6) requirements in the CI - very few Contractors are responsible for all elements therein. Your first task is to determine which elements and sub-elements in the template are applicable to the Contractor's responsibility.
Assumption #2: The only contract requirement that exists from which the Contractor bases Procedures in the CI. The sub-element check sheets in the template are based purely from the CI. It may be necessary to modify the check sheet questions to conform to the specific contract requirement (e.g. Air Force T.O. 00-20-1), or add an element that the specific contract requirement that isn't addressed in the CI.
Assumption #3: The Contractor's Procedures are perfect! Why? Surveillance determines if a Contractor's Procedure(s) are "safe-and-effective", not just that they are complying with them.
Inspection Sampling Criteria
Suppose you are the GGFR at a large maintenance depot, and your contractor employs 274 individual company-owned tool 'boxes'. How do you assure 'safe-and-effective'? Inspect all 274 each audit? Inspect a portion (say 10%) each audit until all toolboxes have been inspected?
Both of the above are poor methods. Inspecting all 274 toolboxes each audit will 'assure' all you ever do is inspect toolboxes! The second method listed above is not horrible, but there's a better way...
A logical approach to determine an appropriate sample size can be borrowed from the Quality Assurance. Launch the above link for detailed information on how to create a sampling plan.
You've got your surveillance plan and, if necessary, have determined you sample size(s), so what's next? If you want to achieve the 95% confidence level as described in the previous section, you'll need to randomly select you sample from the population. Launch the above link for detailed information on how to create a random sample calculator.
We've seen it many times! A GFR cites his Contractor for not complying with (e.g.) the AFI 21-101 job guide for T-6A towing. The contractor answers the level 2 Corrective Action Request (CAR) by revising their Procedure's compliance to the job guide. 2 weeks later you get a nasty-gram from the Contracting Officer, asking you why she received a bill for updating Procedures to a requirement that was NOT on contract. Whoops! Had a CRR been accomplished, such a "Constructive Change" (or just plain embarrassment) would have been avoided.
CRR is the process by which we receive and review contracts and modifications to identify customer requirements for contract Administration Services, or "CAS". Assignment of CAS functions is governed by FAR Subpart 42.202 and listed in FAR Subpart 42.302. Specifically, aircraft flight and ground operations surveillance is governed by FAR Subpart 42.302(a)56.
Developing an APT surveillance plan starts with a thorough review of the contract requirements (DCMA-MAN 8210-2, para 3.7 provides excellent guidance). This review is critical to understanding the Service Guidance, outside of that specified in the Combined Instruction, has been placed on contract and how language in the PWS/SOW/SOO, and sections C, H, I, and J of the contract may affect how Procedures are written, potentially influencing surveillance.
If not, you may be missing something critical to aircraft operations! Quite often the Contracting Officer/COR feels you only need the requirements document (PWS/SOW/SOO). While your focus will center on the PWS/SOW/SOO and sections C, H, I, and J (attachments), A complete CRR requires you to review the Schedule (sections A thru H), section I, and all attachments in section J.
DCMA policy requires the CRR completed within 30 days of receipt for DCMA-administered contracts. While you may not be assigned to a DCMA-administered contract, you should strive to complete the CRR within this time frame.
Has a Post-Award Orientation Conference (PAOC, or PAO) been conducted?
PAO aids both the Government and contractor personnel in achieving a clear and mutual understanding of all contractual requirements. It also enables the identification and resolution of potential contract administration problems. While your Contracting Officer may determine that a PAOC is not required, you should request that one occur.
DO NOT expect to find a contract requirement/reference (outside of the Combined Instruction (CI)) for for every CI element. For example:
Paragraph 4.1.1. "General Flight Rules" states that "Contractor flight operations shall follow Service Guidance". It's not necessary for section I of the contract schedule to list, say, AR95-01, "Flight Regulations" because it's already 'on contract' via the CI, or;
You cannot find any requirements related to paragraph 5.5, "Medical (Physical) Requirements for Ground Personnel". As with the previous example, the CI states as policy that personnel who perform certain ground functions must receive an examination at least every 5 years - enough said!, or;
You cannot find any requirement/reference relating to paragraph 5.8, "Aircraft Servicing" in the contract. This is not a contract deficiency! The contractor is still required to address all CI sub-elements in their Aircraft Servicing Procedure. Such a circumstance is addressed in the "Procedures Review" performance support asset (under construction).
Use this checklist when performing CRR. IT contains process instructions that will aid you thru the process.
In its most basic form, a Procedure is nothing more than a statement of how something gets 'done' - how a task is completed, the means to achieve a specific end. We use Procedures all the time; when we assemble our children's bicycle, we follow the instructions to assure the bike is assembled correctly, and most importantly, it's safe for our child to ride.
In Industry and the Military, there are many, many forms of Procedures. Most familiar to us are technical orders or technical manuals. We use these as a means to follow a sequence of steps or tasks to assure, say, the digital engine control is installed correctly, or the aircraft is properly configured for landing. Not completing all required tasks of following the required sequence could have dire consequences!
Flight and Ground Operating Procedures (FOPs and GOPS) are the same! They are the Contractor's written description of 'how' they intend to meet the procedural requirements set forth in the Combined Instruction.
The Combined Instruction
The Combined Instruction (CI) sets forth the minimum requirements that must be addressed in the Contractor's Procedures. Chapter's 4 (Flight), 5 (Ground), and 6 (Contract Safety) list processes the Services have deemed as elevated risk to DoD aircraft, and therefore require a Contractor-developed Procedure to mitigate this risk. As an example, Chapter 5 states the Contractor must have an approved procedure for the "Mooring and Tie-down" of aircraft (5.9.3). Specifically, the CI states the following sub-elements must be addressed:
5.9.3.1 Aircraft-specific tie-down points
5.9.3.2 Ground tie-down locations
5.9.3.3 Use of approved tie-down equipment for the specific aircraft
5.9.3.4 Grounding requirements
The items above represent the 'what' that must be addressed in the Contractor's Mooring and Tie-Down Procedure. How the Contractor provides the required fidelity (the 'how') can come from several sources.
Use of Service Guidance:
Service Guidance (TOs/TMs) specified in the contract is the 'best-case-scenario' because Service Guidance is generally accepted to meet or exceed the desire for safe and effective flight and ground operations. If (per the example above) the Contract specifies that T.O. 1C-130H-2-10JG-00-1 will be used for all C-130 mooring and tie-down, it would be a simple matter of the Contractor's Procedures stating "5.9.3.1 Aircraft-specific tie-down points will be IAW T.O 1C-130H-2-10JG-00-1" for this and each sub-element. ALL CI sub-elements must be addressed in the Procedure, even those not addressed by the TO/TM.
Industry Standards/Best Practices:
Industrial standards and best practices may also be specified on the contract. Such standards are gaining broader acceptance because they generally take into consideration the aggregate experience of the commercial workforce which is largely comprised of those who served in the military as maintainers and carry forward this experience to the Contractor. As with Service Guidance, all CI sub-elements must be addressed, even those not in the industry standard.
Contractor Wholly Developed Procedures:
It's not uncommon that, after you complete your Contract Receipt & Review, you find the contract doesn't state with what guidance the Contractor will develop a procedure for, say, Corrosion Control - THIS IS NOT A CONTRACT DISCREPANCY! They're still required to submit the procedure for your approval, you just need a standard with which to make a 'safe and effective' comparision. This 'comparision' is generally accomplished using the applicable Service Guidance. This 'comparision' will indicate if the Contractor's 'home grown' Procedure is safe and effective. However, you CANNOT compel the Contractor to comply with the Service Guidance used for comparision.
The AO Procedures Review Guide can be a very useful reference when reviewing Procedures. The columns of this tool can be altered to represent alternate data such as 'does the procedure address all CI elments and sub-elements?'
While there are as many 'ways' to review Procedures as there are stars in the sky, we'll look at the "Big-to-Small" method. It provides multiple opportunities to catch errors:
In the world of post-award contract administration, contractor ground operations requires a very different 'mindset' than that which you, especially aviation maintenance professionals, are accustomed to. As an aircraft maintainer, your duty was that of assuring the aicraft structures, hydraulics and avionics systems (etc.) are good to go and ready for flight. As a GFR or GGFR, your duty now becomes one of "asset protection" - assuring that aircraft in the possession or care of the Contractor is not damaged or destroyed through the actions for which they are contracted to perform.
Ground Operations:
The "Ground Operations" section of the Combined Instruction (CI) simply represents a list of ground operations (processes, tasks, procedures) that the Military Services have determined represent elevated risk to the aircraft. The criteria for inclusion as a ground operation is typically based on historical aircraft damage and mishap reports. This ground operations 'list' grows and shrinks from CI revision to revision as the Services determine what was once elevated risk is no longer, or that new technologies or practices are resulting in damage and therefore require inclusion as a ground operation.
If not, you may be missing something critical to aircraft operations! Quite often the Contracting Officer/COR feels you only need the requirements document (PWS/SOW/SOO). While your focus will center on the PWS/SOW/SOO and sections C, H, I, and J (attachments), A complete CRR requires you to review the Schedule (sections A thru H), section I, and all attachments in section J.
DCMA policy requires the CRR completed within 30 days of receipt for DCMA-administered contracts. While you may not be assigned to a DCMA-administered contract, you should strive to complete the CRR within this time frame.
Has a Post-Award Orientation Conference (PAOC, or PAO) been conducted?
PAO aids both the Government and contractor personnel in achieving a clear and mutual understanding of all contractual requirements. It also enables the identification and resolution of potential contract administration problems. While your Contracting Officer may determine that a PAOC is not required, you should request that one occur.
DO NOT expect to find a contract requirement/reference (outside of the Combined Instruction (CI)) for for every CI element. For example:
Paragraph 4.1.1. "General Flight Rules" states that "Contractor flight operations shall follow Service Guidance". It's not necessary for section I of the contract schedule to list, say, AR95-01, "Flight Regulations" because it's already 'on contract' via the CI, or;
You cannot find any requirements related to paragraph 5.5, "Medical (Physical) Requirements for Ground Personnel". As with the previous example, the CI states as policy that personnel who perform certain ground functions must receive an examination at least every 5 years - enough said!, or;
You cannot find any requirement/reference relating to paragraph 5.8, "Aircraft Servicing" in the contract. This is not a contract deficiency! The contractor is still required to address all CI sub-elements in their Aircraft Servicing Procedure. Such a circumstance is addressed in the "Procedures Review" performance support asset (under construction).
Use this checklist when performing CRR. IT contains process instructions that will aid you thru the process.
We've seen it many times! A GFR cites his Contractor for not complying with (e.g.) the AFI 21-101 job guide for T-6A towing. The contractor answers the level 2 Corrective Action Request (CAR) by revising their Procedure's compliance to the job guide. 2 weeks later you get a nasty-gram from the Contracting Officer, asking you why she received a bill for updating Procedures to a requirement that was NOT on contract. Whoops! Had a CCR been accomplished, such a "Constructive Change" (or just plain embarrassment) would have been avoided.
CRR is the process by which we receive and review contracts and modifications to identify customer requirements for contract Administration Services, or "CAS". Assignment of CAS functions is governed by FAR Subpart 42.202 and listed in FAR Subpart 42.302. Specifically, aircraft flight and ground operations surveillance is governed by FAR Subpart 42.302(a)56.
Developing an APT surveillance plan starts with a thorough review of the contract requirements (DCMA-MAN 8210-2, para 3.7 provides excellent guidance). This review is critical to understanding the Service Guidance, outside of that specified in the Combined Instruction, has been placed on contract and how language in the PWS/SOW/SOO, and sections C, H, I, and J of the contract may affect how Procedures are written, potentially influencing surveillance.
If not, you may be missing something critical to aircraft operations! Quite often the Contracting Officer/COR feels you only need the requirements document (PWS/SOW/SOO). While your focus will center on the PWS/SOW/SOO and sections C, H, I, and J (attachments), A complete CRR requires you to review the Schedule (sections A thru H), section I, and all attachments in section J.
DCMA policy requires the CRR completed within 30 days of receipt for DCMA-administered contracts. While you may not be assigned to a DCMA-administered contract, you should strive to complete the CRR within this time frame.
Has a Post-Award Orientation Conference (PAOC, or PAO) been conducted?
PAO aids both the Government and contractor personnel in achieving a clear and mutual understanding of all contractual requirements. It also enables the identification and resolution of potential contract administration problems. While your Contracting Officer may determine that a PAOC is not required, you should request that one occur.
DO NOT expect to find a contract requirement/reference (outside of the Combined Instruction (CI)) for for every CI element. For example:
Paragraph 4.1.1. "General Flight Rules" states that "Contractor flight operations shall follow Service Guidance". It's not necessary for section I of the contract schedule to list, say, AR95-01, "Flight Regulations" because it's already 'on contract' via the CI, or;
You cannot find any requirements related to paragraph 5.5, "Medical (Physical) Requirements for Ground Personnel". As with the previous example, the CI states as policy that personnel who perform certain ground functions must receive an examination at least every 5 years - enough said!, or;
You cannot find any requirement/reference relating to paragraph 5.8, "Aircraft Servicing" in the contract. This is not a contract deficiency! The contractor is still required to address all CI sub-elements in their Aircraft Servicing Procedure. Such a circumstance is addressed in the "Procedures Review" performance support asset (under construction).
Use this checklist when performing CRR. IT contains process instructions that will aid you thru the process.
We've seen it many times! A GFR cites his Contractor for not complying with (e.g.) the AFI 21-101 job guide for T-6A towing. The contractor answers the level 2 Corrective Action Request (CAR) by revising their Procedure's compliance to the job guide. 2 weeks later you get a nasty-gram from the Contracting Officer, asking you why she received a bill for updating Procedures to a requirement that was NOT on contract. Whoops! Had a CCR been accomplished, such a "Constructive Change" (or just plain embarrassment) would have been avoided.
CRR is the process by which we receive and review contracts and modifications to identify customer requirements for contract Administration Services, or "CAS". Assignment of CAS functions is governed by FAR Subpart 42.202 and listed in FAR Subpart 42.302. Specifically, aircraft flight and ground operations surveillance is governed by FAR Subpart 42.302(a)56.
Developing an APT surveillance plan starts with a thorough review of the contract requirements (DCMA-MAN 8210-2, para 3.7 provides excellent guidance). This review is critical to understanding the Service Guidance, outside of that specified in the Combined Instruction, has been placed on contract and how language in the PWS/SOW/SOO, and sections C, H, I, and J of the contract may affect how Procedures are written, potentially influencing surveillance.
If not, you may be missing something critical to aircraft operations! Quite often the Contracting Officer/COR feels you only need the requirements document (PWS/SOW/SOO). While your focus will center on the PWS/SOW/SOO and sections C, H, I, and J (attachments), A complete CRR requires you to review the Schedule (sections A thru H), section I, and all attachments in section J.
DCMA policy requires the CRR completed within 30 days of receipt for DCMA-administered contracts. While you may not be assigned to a DCMA-administered contract, you should strive to complete the CRR within this time frame.
Has a Post-Award Orientation Conference (PAOC, or PAO) been conducted?
PAO aids both the Government and contractor personnel in achieving a clear and mutual understanding of all contractual requirements. It also enables the identification and resolution of potential contract administration problems. While your Contracting Officer may determine that a PAOC is not required, you should request that one occur.
DO NOT expect to find a contract requirement/reference (outside of the Combined Instruction (CI)) for for every CI element. For example:
Paragraph 4.1.1. "General Flight Rules" states that "Contractor flight operations shall follow Service Guidance". It's not necessary for section I of the contract schedule to list, say, AR95-01, "Flight Regulations" because it's already 'on contract' via the CI, or;
You cannot find any requirements related to paragraph 5.5, "Medical (Physical) Requirements for Ground Personnel". As with the previous example, the CI states as policy that personnel who perform certain ground functions must receive an examination at least every 5 years - enough said!, or;
You cannot find any requirement/reference relating to paragraph 5.8, "Aircraft Servicing" in the contract. This is not a contract deficiency! The contractor is still required to address all CI sub-elements in their Aircraft Servicing Procedure. Such a circumstance is addressed in the "Procedures Review" performance support asset (under construction).
Use this checklist when performing CRR. IT contains process instructions that will aid you thru the process.
Simply stated, a Waiver is a tool used to seek relief from a requirement of the contract. In our world, its a request to seek relief from the CI or Service Guidance applicable to the FOPS and GOPs. Given the complexity and diversity of world-wide Aircraft Operations,
When should a Waiver be requested?
Combined Instruction Waiver MUSTS (Refer to the applicable version of the CI):
Must be submitted on company letter head to the GFR/GGFR
Must include a risk management analysis and risk mitigation plan
This waiver requires Navy contracts with older versions of NAVAIRINST 3710.1 to use NAVAIRINST 3710.1C Change 1, paragraph 6.16.2, as their requirement when their place of performance is located in a U.S. military owned aircraft facility.
This instruction establishes the USAF Small Unmanned Aircraft System Operator (SUAS-O) training program for Air Force military and civilian personnel, personnel from other services and foreign personnel assigned or attached to USAF units, and for contracted SUAS-Os as stipulated in contracts. This publication applies to the Air Force Reserve Command (AFRC) and the Air National Guard (ANG).
This supplement describes AFMC�s general flight rules and procedures for use in conjunction with the basic AFI. It applies to all AFMC units and personnel conducting flying operations. It also applies to AFRC, ANG, and DCMA units under AFMC OPCON. This publication may not be supplemented.
Use this template when building your annual/semi-annual Survey outbrief. Instructions on the use of this template can be found in CMA241, Module 7, "Formal Survey of Operations".
228-370 is the Ground and Flight Risk clause's (GFRC) prescribing Document. It state when the GFRC must be included on an aviation contract, and defines 4 exceptions when the GFRC shall not be included on an aviation contract. Instruction on the application of this clause can be found in CMA241, Module 1, "The Ground and Flight Risk clause".
This instructions establishes requirements, responsibilities, and guidelines for operation of Air Force Small Unmanned Aircraft System (SUAS) by Air Force military and civilian personnel, personnel of other services and foreign personnel assigned or attached to USAF units, and contracted Small Unmanned Aircraft System Operators (SUAS-O) as stipulated in contracts. This publication applies to the Air Force Reserve Command (AFRC) and the Air National Guard (ANG.) Headquarters, Air Force Flight Standards Agency (FOA-AFFSA) is the Office of Primary Responsibility (OPR).