Managers' Internal Control Program.  This instruction contains managers' internal control provisions that are subject to evaluation and testing as required by DCMA-FBP: Managers' Internal Control Program Instruction.

1. Perform Contract Technical Review and Identify FAT/PLT Contractual Requirement - Normally, there are two methods by which FAT requirements appear in contracts. Specifically, for FAT, there is: 1) Contractor Testing, FAR 52.209-3, which requires the contractor to perform the actual testing and submit a test report to the PCO through DCMA QA personnel, or 2) Government Testing, FAR 52.209-4, which provides for the Government to perform the actual testing to verify the product conforms to specification. PLT may also have either a Contractor PLT or Government PLT requirement stated in the contract.

    1.1. Within the contract, FAT/PLT may be invoked by several different methods including but not limited to: Contract Line Item Number (CLIN), DD Form 1423 (Contract Data Requirements List (CDRL), Supplemental Quality Assurance Provision (SQAP), Statement of Work (SOW), or drawing. Further guidance concerning DCMA QA personnel responsibilities may be provided through various customer communications including, but not limited to, a Quality Assurance Letter of Instruction (QALI).  

2. Determine Need for Technical Assistance - If QA personnel determine the need for additional technical assistance or resources to perform the necessary FAT/PLT functions, QA personnel shall make a request in writing to the supervisor for assistance. When the FAT/PLT requirement includes testing of software embedded in the end item or system, or stand-alone software products, QA personnel should ensure a DCMA Certified Software Professional is contacted for technical assistance.  The supervisor will review the QA personnel request and provide assistance as required.   QA personnel shall keep a record of the request for technical assistance and resource support provided for the FAT/PLT requirements and, if applicable, include a copy with the completed QA PAOC documentation file.

3. Conduct QA Post Award Orientation Conference (QA PAOC) - QA personnel shall conduct a PAOC in accordance with the QA PAOC Instruction for the following conditions that apply whether it is either a Contractor or Government FAT/PLT requirement:

• A supplier is performing a FAT/PLT for the first time
• When extended time has passed since the last FAT/PLT was performed by the supplier
• When FAT/PLT requirements change per the contract
• When FAT/PLT related supplier technical, quality, or documentation deficiencies, are being noted by QA personnel or reported from either the lab conducting the testing or the procuring activity
• When the supplier has significant personnel changes that may affect manufacturing and/or testing processes

    3.1.  All personnel required to provide technical assistance to DCMA QA personnel should either attend the PAOC meeting or, as required, teleconference into the meeting . As a minimum, DCMA QA personnel shall review and discuss the specific first article/production lot contractual requirements, required plans or reports, QA personnel inspection hold points, and any inspections or tests to be performed by the supplier and/or DCMA at subcontractor’s locations.

    3.2. A QA PAOC may not be required when repetitive contracts or orders with FAT/PLT requirements are issued to the same supplier or the supplier is already performing satisfactorily on identical items.

4. Develop FAT/PLT Surveillance Plan - QA personnel shall develop and document a plan for performing surveillance of the contractually required FAT/PLT in accordance with the GCQA Surveillance Planning Instruction.  The steps/bullets in this paragraph may be used to assist with developing the Risk Profile and Plan.

    4.1. Whether Contractor or Government Testing – As required by the contract, the plan shall:  

• Ensure the contract specified FAT/PLT exhibit amounts are available for testing (as applicable).
• Ensure the contract specified PLT samples are randomly selected for test/inspection (as applicable).
• Verify the supplier’s inspection of critical or major product characteristics or processes identified in the FAT/PLT report by independently inspecting or witnessing the supplier’s inspection or testing of these characteristics or processes. This includes characteristics or processes performed at subcontractor facilities (not applicable to FAR 52.209-4). 
• If FAT/PLT sampling is authorized in the contract, perform sample product examination of all other (non-critical or non-major) product characteristics or processes to the degree necessary to establish confidence of product conformance to technical specifications (not applicable to FAR 52.209-4). 
• Verify the supplier's inspection/test records and test report clearly demonstrate the products conformance to technical specifications.
• Ensure (as applicable) required records or reports are sent to the approval authority.
• Ensure all material/process certifications, inspection method sheets, test reports, DD 250s, DD 1222 and any other pertinent documentation are included with the exhibit (s) designated for testing.
• Perform any other activities requested by a QALI.
• Ensure, if applicable, the prime QA personnel notifies the Place of Performance (PoP) QA personnel that a FAT/PLT requirement is part of the contract.

     4.2. Specific to Contractor Testing – As required by the contract, the plan shall:  

• Verify the manufacturing processes, materials, and facilities used to produce the FAT product are the same as those used to produce production runs (FAR 52.209-3; Alternate 1, para i); NOTE: DLA Contractor FAT contracts may also specify DLA Clause 52.209-9017 requirements; (if applicable) DLA Contractor PLT contracts may also specify DLA Clause 52.246-9086 requirements.

    4.3. Specific to Government Testing – As required by the contract, the plan shall:  

• Verify the manufacturing processes, materials, and facilities used to produce the FAT product are the same as those used to produce production runs (FAR 52.209-4; Alternate 1, para j); NOTE: DLA Government FAT contracts may also specify DLA Clause 52.209-9018 requirements; (if applicable) DLA Government PLT contracts may also specify DLA Clause 52.246 -9085 requirements.
• Verify the packaging is clearly marked (as applicable) as either a: "FAT/PLT SAMPLE, DO NOT POST TO STOCK; DO NOT PUT INTO SUPPLY."

    4.4.  Determine Need for QA Personnel Inspection Hold Points - During the GCQA surveillance planning efforts, QA personnel shall determine if there is a need for inspection hold points at the various manufacturing process sequence locations in accordance with the Product Examination - QA Instruction. Hold points ensure the Government inspections are not inadvertently overlooked or bypassed by the supplier.

    4.5  Notify Supplier of GCQA Hold Points - Where QA personnel determine Government inspection hold points are necessary, the supplier shall be notified in writing detailing the requirement in a manner where supplier receipt and acknowledgement is verifiable.

    4.6.  Determine Need for GCQA at Subcontract Level - Where surveillance, as developed in accordance with paragraph 4.1. for critical or major product characteristics/processes can only be performed at a subcontractor’s facility, a request for subcontract GCQA shall be sent to the appropriate DCMA office in accordance with the Delegate Surveillance QA Instruction. Such requests shall be supported and the results documented and returned to the prime QA personnel in a timely manner.

5.  QA Personnel Executes Surveillance - QA personnel executes surveillance in accordance with the FAT/PLT Surveillance Plan:

• Surveillance results shall be documented in accordance with GCQA Surveillance Planning and Para. 7. below.
• Actual product inspected or witnessed by QA personnel shall be clearly identified to the approval authority.   Reference the Product Examination - QA Instruction for product inspection or witnessing specifics.
• Contractual nonconformities identified by QA personnel shall result in the appropriate level CAR. Reference CAR Instruction.

6.  Notify PCO of any Nonconformity or Waiver Request and Request Instructions - QA personnel shall notify the PCO: 1)  of any identified nonconformity and recommend disapproval; 2) of any waiver request by the supplier (with appropriate QA personnel recommendation for the waiver) and request instructions from the PCO as to how to proceed with the FAT/PLT requirement. QA personnel shall notify his/her supervisor whenever a PCO or ACO (with delegated authority) approves a first article/production lot unit containing nonconformities. QA personnel shall ensure waiver requests are processed and approved by the PCO prior to shipment of production units.

7.  QA Personnel Prepare FAT/PLT Results - QA personnel will use a DD Form 1222 or cover letter to forward the supplier's FAT/PLT report and/or to report the results of the inspection of the first article/production lot units. The DD Form 1222, or cover letter, will be separate from and in addition to any supplier reports. QA personnel shall include the following minimum information:

• Names, activities, and telephone numbers of individuals providing technical assistance to QA personnel and other Government personnel witnessing or participating in the FAT/PLT.
• A statement identifying the characteristics actually inspected or witnessed by the Government. Alternatively, QA personnel may attach copies of the inspection results if these forms clearly identify the characteristics actually inspected or witnessed by the Government.
• A detailed description of any nonconformity in the FAT/PLT units or test results or departures from the contractually specified FAT/PLT procedures (if applicable).
• A statement identifying by name, title, activity, and telephone number the ACO or PCO authorizing the shipment of nonconforming FAT/PLT units or test reports (if applicable).
• A recommendation for approval or disapproval when the contract requires contractor conducted FAT/PLT. Disapproval will always be recommended whenever any nonconformity in the FAT/PLT units or deviation from the FAT/PLT procedure is observed.

8.  Notify ACO of FAT/PLT Unit Shipment - Immediately before shipment of a FAT/PLT unit or test report, QA personnel shall request the ACO provide the receiving activity with the notice and advice required in accordance with FAR 9.307. QA personnel shall not authorize the supplier to ship FAT/PLT exhibits or test reports containing known or suspected nonconformities, unless specifically directed in writing to do so by the ACO or the PCO. QA personnel shall report immediately to the ACO and PCO indications that the supplier has or intends to ship non-conforming FAT/PLT units.

9.  FAT/PLT Approval - When the PCO retains approval or disapproval authority, the notification to the supplier as to the approval, conditional approval, or disapproval of the first article/production lot unit is the responsibility of the PCO. Where approvals, conditional approvals, or disapprovals are received from other than the PCO, i.e. the Technical Activity, QA personnel will forward a copy to the appropriate ACO for their coordination with the PCO. Formal notice to the supplier will be signed by the PCO or ACO.

   9.1. Where the PCO elects to delegate first article/production lot approval authority to the ACO, formal notice to the supplier of first article/production lot approval/disapproval shall be signed by the ACO.   

    9.2.  Approved FAT units sometimes serve as a manufacturing standard for production units, but only when specifically stated in the contract. When this occurs, the FAT unit may be useful in evaluating the adequacy of production units with respect to technical requirements. The approval of a nonconforming FAT unit shall not be construed as authorization to accept production items containing any nonconformity with the contract requirements.   

    9.3.  Most contracts require first article/production lot units to be manufactured using the same facilities, manufacturing processes, methods, and materials as the production units.  When this or similar requirements are included in the contract, and QA personnel observe any changes that may reasonably be expected to affect product quality, QA personnel will immediately advise the PCO and ACO of the circumstances. QA personnel shall issue a CAR, if warranted, and withhold formal acceptance pending further direction from the PCO.   

    9.4.  Before accepting and/or authorizing shipment of any production quantities, QA personnel shall verify and document that contractor corrective actions resulting from the first article/production lot test were implemented and any deficiencies noted in letters of conditional approval were corrected.

Competency and Certification requirements for all QA personnel are addressed in the QA Development instruction and the Training Competency Assessment Tool (TCAT).

• FAR 52.209-3 – First Article Approval – Contractor Testing
• FAR 52.209-4 – First Article Approval – Government Testing
• FAR Part 9, Subpart 9.3 – First Article Testing and Approval

• Process Indicator/s:
  • Metric: FAT/PLT properly planned, executed, and documented as evidenced through First Level Supervisor (FLS) Review. FAT/PLT surveillance is accomplished in accordance with technical and schedule requirements; results are reported via 1222 or customer directed equivalent; recommendations address all variances and deviations. Calculation: The number of FAT/PLTs found without any planning, execution, or documentation errors divided by the total number of FATs conducted during the report period.
    • Performance Standard: FAT/PLT shall be properly planned, executed and documented 100% of the time required by contract.
• Workload Indicator/s:
  • TBD
• Resource Indicator/s:
  • TBD
• Supplier Indicator/s:
  • TBD

• PLAS Process code: 085A, 085C

• Sample DD Form 1222
• FAT/PLT Process Flowchart

• Quality Assurance Sub Community (This is a sub community of the PA Portal)