46.504 Certificate of conformance (CoC) may be used in certain instances instead of source inspection at the discretion of the contracting officer if the following conditions apply: (a) Acceptance on the basis of a contractor’s certificate of conformance is in the Government’s interest. (b)(1) Small losses would be incurred in the event of a defect; or (2) Because of the contractor’s reputation or past performance, it is likely that the supplies or services furnished will be acceptable.
Procurement commands are not using 46.504 enough. They are issuing inspection and acceptance authority at sources; delegating this responsibility to the Defense Contract Management Agency (DCMA). These inspected items are none complex/critical items and hold a very small value.
Using the DCMA charge to reimbursable of $109.28 per hour, a Quality Assurance Specialist (QAS), will perform multiple inspections on items that are valued very small. For example, a QAS will inspect “purification cloths” which has an individual value of $5.51, however; a QAS performing proper QA Surveillance will review the Inspection Request, travel to supplier location in a government vehicle, inspect the items, drive back to his office, perform computer duties to accept the item and document his inspection. A QAS just spent 3+ hours ($327.84+) on a $5.51 low valued commercial item.
Procurement offices are not using CoC properly and the DOD is wasting millions of dollar on misuse of Government QASs. What I suggest, is each procurement command creates a list at their level to determine items that should be considered CoC. This list should be maintained at Command level and if there are commercial or low valued items which are not on CoC then there should be an explanation with proof of risk to the government. DCMA management work load may reduce upwards of 20%, potentially saving DCMA $6 mil a year on Management cost, also resulting in the reduced requirement to hire additional QAS support.