By Michael Porfilio, Director of Quality and Engineering NDE Level III, Certified Lead Nuclear Auditor
To function in the modern, industrialized manufacturing environment, business and quality systems require controls with formal guidelines and good practices. This is especially true when working in government purchasing.
Federal Acquisition Regulation (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS) cover many of the contracts issued by the U.S. Armed Forces and NASA. FAR is a set of federal purchasing requirements applied as required for incoming customer work. DFARS is a set of federal purchasing requirements applied as required for incoming customer work, which is for defense and Department of Defense (DoD) contracts.
If you are manufacturing parts or equipment that require compliance with FAR and DFARS, your foundry partner needs to be compliant as well. The following are typical government purchasing and quality pass down requirements imposed on foundries. Stainless Foundry & Engineering recommends you use this list to ensure your manufacturing partners are processing customer orders to specification.
- Combating Trafficking in Persons – FAR 52.22-50 – The U.S. Government has adopted a policy prohibiting trafficking in persons, in compliance with FAR 52.222-50. All employees and agents of the company shall comply with this policy.
- Ethics and Compliance Systems– FAR 52.203.13 – Ethics and compliance at Stainless Foundry & Engineering are in accordance with FAR, as detailed in our corporate value, vision and mission statements.
- 10CFR Part 21 Whistle Blowing Regulation – DFAR 252.203-7002 – Foundries should be able to offer full assurance and compliance to the ability for employees to be empowered to safe guard.
- Production Control Requirements 15CFR700 – DFAR 252.204-7008 – Foundries should be cognizant to the requirements for delivery and production. In addition, they should take on the responsibility of accommodating a priority order that allows governmental scheduling if necessary.
- Quality Assurance Protocols – FAR / DFARs Clause 204-7008, General Dynamics – Electric Boat EB Spec. 2648 J, Appendix B General Dynamics – Electric Boat EB Spec. SP 05-15. – All records, inspections, tests, supplier activities, material testing, certifications (CMTRs) / certificates of Compliance (COC) or other informal or formal documentation for all orders processed at the foundry (rated or non-rated) are to be recorded. Any deviation should be directly reported to the foundry’s QA department.
- Certified materials and Certifications of Conformance (COC) – DFAR 252.204-7008 – Material and order certificates or conformance and certified material test reports should available for any casting produced.
- Information Technology and Security – DFAR 204-7012, NIST 800.53, and NIST 800.171 – Cyber security is a prime directive to safe guard information. When customer rated or federally controlled orders and contracts specify that germane FAR/DFARs requirements apply, Stainless Foundry & Engineering’s IT department is quickly notified. Our IT department will determine that the correct security has been applied as appropriate to the referenced customer purchasing requirements.
- Processing and Rating of Work – DFAR 252.225-7001 – Special prioritization of customer orders should be followed as required. Foundry partners should demonstrate how they aim to deliver orders when delivery needs and part criticality are specified.
- Preference for Domestic Specialty Metals – DFARS 252.225-7014 – Specialty metals must be melted in the United States or qualifying country, or they can be melted anywhere but must be “incorporated in an article manufactured in a qualifying country.” Qualifying countries include: Australia, Austria, Belgium, Canada, Czech Republic, Denmark, Egypt, Estonia, Federal Republic of Germany, Finland, France, Greece, Israel, Italy, Japan, Latvia, Luxembourg, Netherlands, Northern Ireland, Norway, Poland, Portugal, Slovenia, Spain, Sweden, Switzerland, Turkey, and United Kingdom.
- Specialty Metals – Conflict Minerals Stance – Stainless Foundry & Engineering has a high compliance factor in meeting and having our providers comply with the requirements of the DoD Frank / Conflict Minerals stance.
- International Traffic in Arms Regulation (ITAR) – 22 CFR 120 – 130 – Complying and having a Technical Control Plan in place for ITAR rated work is one of the things that differentiate many foundries from the competition. It can be easy to get a registration, but difficult to comply.
- Export Administration Regulations(EAR) – 15 CFR 730– As a companion program to the requirements of ITAR, foundries should also follow the logistics and requirements or EAR.
- Operations Security Employees (OPSEC) – Government contractors are provided this guidance to ensure compliance and protection of Nation Security information.
- ISO 9004:2018 – Quality Management – Quality of an Organization – Guidance to Achieve Sustained Success – This standard is an augmented and enhanced version of ISO 9001:2015. ISO 9004:2018 provides a self-assessment tool to review the extent to which an organization has adopted the concepts in the standard.
- ISO 31000:2018 – Risk Management – Principles and Guidelines – Managing risk is part of governance and leadership, and is fundamental to how the organization is managed at all levels. It contributes to the improvement of management systems.
Stainless Foundry & Engineering is committed to following FAR and DFARS requirements as we process customer orders. If you have questions about our compliance programs, or would like to learn more about working with foundries that can support government purchasing specifications, contact sales@stainlessfoundry.com.