1.  Risk Planning:

    1.1.  Prior to the beginning of each fiscal year, the Contract Safety Specialist/Manager (CSS/CSM) will prepare and maintain a schedule (also known as a risk handling plan) of all required post-award safety surveys to be accomplished during the fiscal year.  The plan will include the contractor name and address, type of survey, risk level, cage code and survey frequency assigned. The CSS/CSM will coordinate the schedule with the Team Chief.  Team is responsible for maintaining a consolidated RHP that is accurate and up to date.  Consolidated RHPs will be kept on record and act as the justifications for all surveillance decisions.
    1.2.  The CSS/CSM will use the risk matrix to establish a risk plan for each contractor under his cognizance. The plan will be based on contractual safety requirements, and will list all required postaward safety survey reviews by month.  The plan should project unscheduled reviews as well.

2.  Risk Assessment.

    2.1.  Contract review and identification of contractual requirements are the first and most essential steps in the management of the process.  If the contract contains safety requirements that are known to require contract safety surveillance, the contractor will be scheduled for a post-award safety survey.  The administrative contracting officer (ACO) and contract administrators (CAs) at the contract management office (CMO) have cognizance over the administration of the contracts are responsible to ensure that contracts  identified with contract safety requirements are routed to the Contract Safety Specialist/Manager (CSS/CSM) for review.
    2.2.  LATEST CHANGE The CSS/CSM will use every means available to identify contracts with specific contractual requirements to include; the contract receipt and review (CRR) Etool, communication and coordination with the ACO,  (CAs), quality assurance specialist, (QAR/QAS), industrial specialist (IS), government flight representatives (GFRs), etc. The CSS/CSM will coordinate with General Counsel as well. Included in this effort is the need to communicate with appropriate parties to ensure any contracts awarded as a result of recent pre-award surveys are identified. If the CSS/CSM through his/her review of a contract identifies nonconformities or errors in safety requirements, the procuring contracting officer (PCO) will be notified through the ACO.  A contract deficiency report (CDR) will be initiated using the electronic document access (EDA) for any contract found to be missing the appropriate requirements.
    2.3.  The Contract Safety workload is based primarily on specific safety and fire prevention clauses and requirements contained in contracts assigned to DCMA for administration.  Contracts requiring surveillance may have the following contractual clauses or other requirements delineated in the statement of works (SOWs) and/or appendices.  Included are the following contracts:

       2.3.1.  Ammunition and Explosives (A&E)

            2.3.1.1.  DFARS 223 223.370 requires that DFARS 252.223-7002 and DFARS 252.223-7003 clauses be inserted in all contracts and subcontracts involving A&E.
            2.3.1.2.  DFARS 252.223-7002 Clause requires the contractor to comply with DoD 4145.26-M, DoD Contractors’ Safety manual for Ammunition and Explosives or other cited safety standards or tailored requirements.
            2.3.1.3.  DFARS 252.223-7003 Clause Change in Place of Performance, Ammunition and Explosives, requires that a contractor that desires to change the place of A&E work performance must notify and receive specific approval in advance from the ACO.

Note:  The DFARS clause is inserted in all contracts involving the development, testing, storage, manufacture, modification, renovation, demilitarization, packaging, transportation, handling, disposal, inspection, repair, or any other use of A&E (excluding inert components containing no explosives, active chemicals or pyrotechnics).

        2.3.2.  LATEST CHANGE Aircraft

            2.3.2.1.  The DFARS 228.370 requires that (1) DFARS 252.228-7001, the Ground and Flight Risk Clause (GFRC) and (2) DFARS Subpart 228.370, Additional Clause, mandate the use of the GRFC in contracts for aircraft development, production, modification, maintenance repair or overhaul.  DFARS subpart 228-370 specifies two exceptions to these requirements and provides stringent guidance regarding how the GFRC can be modified.  The exceptions cover FMS contracts and instances where the cost of insurance to the contractor will not exceed $25,000. Another exception not specified in DFARS 228.370 is where a FAR 12 contract is awarded for commercial item.
            2.3.2.2.  DFARS 252.228-7002 Clause, the Aircraft Flight Risk Clause (AFRC). DFARS Subpart 228.370 mandates the use of the AFRC in cost type contracts for aircraft production, modification, maintenance repair or overhaul, and fixed price contracts for the same activities where the GFRC is not included and contract performance involves flight of a government furnished aircraft.
            2.3.2.3. Contracts with Both the GFRC and the AFRC.  DFARS Subpart 228.370 provides these clauses as alternatives.  It is unusual for both clauses to be used on the same contract because they establish different limits of contractor liability.   A possible exception to this general rule is where the contract contains both fixed price and flexible priced CLINs.  If the contract does not clearly explain why both clauses are present, DCMA personnel shall bring this to the attention of the appropriate ACO immediately for clarification and/or correction.
            2.3.2.4. Government-Owned Contractor-Operated (GOCO).  Facilities Use and lease contracts for the operation or use of Government-owned plants by private contractors normally contain industrial plant protection requirements.  These requirements  must be reviewed to determine if Contract Safety surveillance is required.
            2.3.2.5. LATEST CHANGE  NASA Contracts.  Contract Safety surveillance of NASA contracts are delegated in MOUs, MOAs or Letters of Delegation.  These surveillance activities are performed on a reimbursable basis with the specific surveillance requirements and reimbursable hours negotiated.  NASA contracts contain various NASA standard industry and tailored requirements specific to the services or items procured and the location of work to be performed (site specific).  The CSS/CSM shall coordinate all planned surveillance with the local or designated NASA Safety and Mission Assurance Office or the local NASA Resident Office.  In order for the Contract Safety Branch to be able to receive credit for reimbursable hours, ensure safety requirements and hours needed to support the effort are delegated through the Etool ECARS using the Contract Safety Branch DODAC S0606A. The CSS/CSM will use the performance labor accounting PLAS work performed to document work performed to the appropriate associated NASA codes.

    2.4.  When the CSS/CSM receives a contract containing safety clauses, the CSS/CSM will review the contract to determine whether the safety requirement is appropriate.  If the contract contains requirements that require Contract Safety review, the CSS/CSM will perform an initial assessment  using the risk matrix to determine the level  of surveillance necessary for the contractor. The CSS/CSM will add the contractor to the risk plan and schedule the contractor for postaward safety reviews.
    2.5.  The risk matrix provides the basis for surveillance decisions that are based on actual risks that are present at the contractor facility.  By assigning a risk value to the contractor facility based upon the evaluation of facility specific criteria, and employing that value in a risk assessment model, a numerical value is obtained that will reflect the general risks associated with the operation, and the specific risks associated with operations at a particular  facility.
    2.6.  Risk is an expression of consequences in terms of the probability of an event occurring, the severity of the event and the exposure of personnel or resources to potential harm or loss.  Uncertainty and risk are parts of every process that the CSS/CSM evaluates.  The CSS/CSM shall be aware that risk will never be totally eliminated, but identifying risk offers organizations a powerful tool for gauging whether a contractor can effectively complete contractual obligations.  Ultimately, the goal in identifying risk is to increase the chance of success by eliminating or mitigating identical hazards.
    2.7.  The risk assessment matrix provides a systematic means of identifying and controlling risk which will allow greater and more consistent results by using a logical method rather that relying solely on experience. Using the risk assessment matrix to identify risk for each contractual non-compliance will validate overall contractual risk.

        2.7.1.  Step one of the risk assessment matrix processes involves identifying hazards associated with the operation or activity.  A hazard can be defined as any real or potential condition that can cause failure or degradation of a component or system.
        2.7.2.  Step two is to assess the risk of each identified hazard.  The assessment step involves the application of quantitative or qualitative measures to logically determine the probability and severity of ill effects potentially resulting from exposure to a hazard.
        2.7.3.  Step three is to ensure proper documentation or risk. Once the severity and probability are determined, document the risk as extremely high, high, moderate high, or low and document where the severity and probability intersect. For example, if the risk is identified as high with severity as critical and probability as likely, then define the risk as high (II, B).  This will provide accurate risk identification that can be understood by everyone. 

Risk Definitions.

E - Extremely High Risk: Potential Inability to Accomplish Mission

Loss of the ability to accomplish the contractual mission if threats occur during mission.  A frequent or likely probability of catastrophic loss or frequent probability of critical loss exists.

H - High Risk: Potentially Degraded Mission Capability

Significant degradation of mission capabilities in terms of the required mission standard, inability to accomplish all parts of the mission, or inability to complete the mission to standard if threats occur during the mission.  Occasional to seldom probability of catastrophic loss exists.  A likely to occasional probability exists of a critical loss occurring.  Frequent probability of marginal losses exists.

M - Moderate Risk: Needs Attention

Expected degraded mission capabilities in terms of the required mission standard will have a reduced mission capability if threats occur during mission.  An unlikely probability of catastrophic loss exists.  The probability of a critical loss is seldom.  Marginal losses occur with a likely or occasional probability.  A frequent probability of negligible losses exists.

L - Low Risk: Meets Standard Requirements

Expected losses have little or no impact on accomplishing the mission.  The probability of critical loss is unlikely, while that of marginal loss is seldom or unlikely.  The probability of a negligible loss is likely or less.

Severity Categories

The following table outlines severity categories for risk assessment:

Probability Categories

The following table outlines probability categories for risk assessment:

3.  Risk Handling:

   3.1. Pre-award Safety Survey. 

        3.1.1.  The pre-award safety survey is normally the first and one of the most important steps in the contract management process.  When conducted properly, the pre-award safety survey can significantly reduce the possibility of serious contractor nonconformities of contract safety and fire protection provisions during the performance period.
        3.1.2.  LATEST CHANGE  When the CSS/CSM receives a request for a pre-award safety survey which involve technical disciplines in which he/she does not have specific training or extensive experience, the CSS/CSM will immediately notify the Team Chief, who will ensure that a qualified CSS/CSM is available to perform the survey(s).  The Team Chief may call upon their team resources or request the assistance of another Team Chief or procuring activity.  This policy is specifically intended to cover highly technical areas requiring specific knowledge not adequately covered by a certification area or specific products or processes with which the CSS/CSM is not familiar.
        3.1.3.  The CSS/CSM should be cognizant of pre-award safety surveys conducted with solicitations containing safety clauses/requirements which are early indications of potential new contracts requiring surveillance.  Such pre-awards shall be suspended and follow-up action taken with contract management personnel to determine if and when contracts are awarded.
        3.1.4.  Pre-award safety surveys must be performed when:

            3.1.4.1.  Requested by the procuring activity, and
            3.1.4.2.  The solicitation contains a safety clause/requirement.   
            3.1.4.3.  When a pre-award safety survey is requested on a solicitation which contains no safety requirements the procuring activity will be contacted through the Pre-Award Survey Manager (PASM) to delete the pre-award safety survey requirement.   If the procuring activity provides the safety requirement, the pre-award safety survey will be performed using those safety standards cited by the procuring activity.  If the procuring activity does not provide the safety requirement, the pre-award survey report shall indicate that the solicitation contained no safety requirements and cite the standards provided by the procuring activity.  Circumstances of this type shall be brought to the attention of the Team Chief.
            3.1.4.4.  If, during the pre-award safety survey, the CSS/CSM learns that a significant portion of operations covered by the safety clause/requirement or a portion of that work which is highly hazardous is to be performed by a subcontractor, the PASM will be notified immediately.  Secondary pre-awards will normally be requested for these proposed subcontractors. 
            3.1.4.5.  When secondary pre-awards are performed, the final safety recommendation will be dependent upon the combined results of both primary and secondary surveys.  This policy does not generally apply to proposed subcontractors, including A&E manufacturers, providing commercially produced items, materials or supplies commonly available on the open market unless sole source, critical to DoD readiness, or a danger to other DoD interests.
            3.1.4.6.  If a secondary pre-award safety survey of a specific subcontractor is not requested for the above reason in 3.1.4.3, the CSS/CSM must include a specific statement of that fact and the reason for the decision must be included in the pre-award safety survey report.
            3.1.4.7.  In accordance with DFARS 252.223-7002, offerors must include in their proposal a list of all proposed A&E subcontractors and other places of performance.  This provides the buying activity the option of requesting pre-award safety surveys of both prime and subcontractors simultaneously.  If the buying activity exercises this option, the CSS/CSM surveying the prime does not need to request a secondary pre-award safety survey.  When this situation exits, the secondary pre-award safety survey will be routed to the primary PASM to be included into his report to the buying activity.
            3.1.4.8.  DFARS 252.223-7003, Change in Place of Performance (A&E), requires that prime contractors obtain the contracting officer's approval of any changes in subcontractors or other places of performance after the award of the contract.  If this occurs, the CSS/CSM may be requested by the PCO/ACO to perform plant capability surveys of the proposed new places of performance.  Such surveys must be performed and documented in the same manner as regular pre-award safety surveys, with the exception that no recommendation for award is required.
            3.1.4.9.  Desk audits.  Desk audits of contractors and subcontractors currently under surveillance are an acceptable alternative to on-site pre-award safety surveys when justified by historical data and current documented knowledge.  The CSS/CSM may perform a desk audit under the following circumstances for a solicitations that involve A&E in which:  

                3.1.4.9.1.  There is no significant change in type of work to be performed.
                3.1.4.9.2.  The change in quantity and/or type of A&E will not cause quantity-distance or compatibility violations.
                3.1.4.9.3.  No new or modified equipment and facilities are required.
                3.1.4.9.4.  The previous on-site safety survey of the contractor was conducted within the survey interval established in accordance with paragraph 3.1.4.9.  All significant safety violations have been resolved, and information contained in the survey report remains current.
                3.1.4.9.5.  No adverse impact on other DCMA administered contracts is anticipated.  The CSS/CSM will also perform desk audits of contractors that are not manufacturing or using A&E, but are currently under surveillance.  These include solicitations that involve:

                    3.1.4.9.5.1.  No significant change in the type of work to be performed or facilities to be used.
                    3.1.4.9.5.2.  There is no significant change in safety requirements.
                    3.1.4.9.5.3.  The previous on site safety surveillance was performed within the survey interval established, the update of all significant safety violations has been resolved, and information contained in the survey report remains current.
                    3.1.4.9.5.4.  No other adverse impact on other DCMA administered contracts is anticipated.

            3.1.4.10.  Lastly, the CSS/CSM will perform desk audits when portions of the work are to be subcontracted. This must be identified in the report, and procedures of paragraph 3.2.6.6 followed.
            3.1.4.11.  Pre-award safety surveys conducted on Army GOCOs facilities are the sole responsibility of Army personnel. Copies of Army pre-award safety surveys will be obtained through the US Army Joint Munitions Command, AMSJM-SFS by calling 309 782-2973 / DSN 793-2973.

    3.2. LATEST CHANGE Pre-award Safety Survey Preparation/Processes.

        3.2.1.  Pre-award Survey System.  The Pre-award Survey System (PASS) Etool is an application that can be accessed from the DCMA portal.  The Etool application enables DCMA functional specialists to request, transfer, evaluate, and complete a pre-award survey.  The PASS has a search engine which permits users to view previously completed pre-award surveys within the last 18 months.
        3.2.2.  The PASS Etool was designed to support the pre-award survey process from the request to receipt of the pre-award survey results.  The PASS provides DCMA customers with an accurate assessment of a prospective contractor’s capabilities as they relate to government procurements.  The CSS/CSM must use the PASS Etool to document all pre-award safety surveys.
        3.2.3.  Review of Bid Package.  A thorough and professional review of the solicitation and contractor’s proposal is essential for performance of an adequate pre-award safety survey.  The CSS/CSM must obtain, when possible, a complete copy of the solicitation package prior to visiting the contractor and review it in its entirety.  When packages are not available, the contractor's copy may be used; however, this should be avoided since it decreases the time available for review and increases the time necessary in the contractor's facility.  The review will include the:

            3.2.3.1.  Verification of the inclusion of the safety clause(s) and familiarization with requirements of the clause.  This may include researching referenced documents and publications.
            3.2.3.2.  Determination if other safety requirements are included.  These may be included in the DD Form 1423 data item descriptions, statements of work, technical drawings, data sheets, and referenced publications (i.e., technical orders, military standards, Joint/Departmental manuals and regulations, etc.).
            3.2.3.3.  Familiarization with both the item to be procured and/or work to be performed.  This will require, where applicable, a review of all technical drawings and/or statements of work.
            3.2.3.4.  Familiarization with transportation and property disposition/disposal requirements when A&E or hazardous materials are involved.
            3.2.3.5.  Early review will provide the CSS/CSM with the product, work, process, and material knowledge necessary to begin determining if the prospective contractor can perform the contract work in compliance with safety requirements.

        3.2.4.  Review of Historical Data.  All Contract Safety historical data applicable to the prospective procurement will be reviewed prior to the survey.  The review includes an examination of past survey/visit reports, facility data sheets, mishap reports, waivers of safety requirements, site plans, licenses, and prior preawards.
        3.2.5.  Conduct of On-site Surveys. When performance of an on-site pre-award safety survey is determined necessary, it will be conducted in accordance with the requirements of the Pre-award Survey Instruction.  When feasible, the safety portion of the survey shall be conducted in conjunction with the pre-award survey team designated by the pre-award survey monitor to enhance the exchange of information and cause minimal disruption of contractor operations.  Frequently, pre-award surveys are requested as safety only reviews.  For A&E pre-awards the requirements of DoD 4145.26-M, Chapter 1 must be followed.  The pre-award safety survey must result in a determination of the prospective contractor's ability to perform the proposed work in compliance with the safety requirements of the contract.  To do so, the prospective contractor must provide demonstrable proof of capability.  General statements or signed letters of intent do not constitute demonstrable proof unless supported by documented information.  The government is not required to discover capability when the prospective contractor fails to demonstrate it.  As a minimum the survey process will include:

            3.2.5.1.  Safety History.  A. review of past safety surveys reports by federal, state, or local safety, fire prevention, or regulatory authorities which may impact DoD operations.  These authorities may be contacted directly if information is not available through the contractor.   It shall be determined if any nonconformities, violations, etc., remain open.
            3.2.5.2.  Mishap History.  A review of annual OSHA accident summary sheets must be available and insurance records reflect property damage mishaps.  The review shall be geared toward mishaps affecting past, current, or proposed DoD contracts.
            3.2.5.3.  Waivers and Exemptions.   A determination of the proposed contractor has been granted exemptions or waivers on existing DoD contracts and what are the terms.
            3.2.5.4.  Operational Experience.  A review of the prospective contractor's past experience with similar or related work shall be reviewed.  Experience on previous government contracts shall be reviewed to evaluate the prospective contractor's ability to perform similar types of work and to comply with required safety regulations.
            3.2.5.5.  Current Status.  A review of the prospective contractor's current safety posture must be conducted.  This will include where applicable:

                3.2.5.5.1.  Safety program, organization, and training.  A review of the effectiveness of the overall program to assure contractual compliance shall be evaluated.
                3.2.5.5.2.  Current Facilities.  A review of the size, construction, fire resistance, and protection, utilities, etc., of each building shall be reviewed.  Current compliance with existing regulations, codes, requirements, and with proposed contract safety requirements must be specifically addressed.  This includes current compliance with specific proposed ammunition and explosives or other contract facility requirements.  The CSS/CSMs shall focus their review on the facilities to be used for the proposed work and must, when applicable, include facilities which, in case of mishap, would potentially impact contract related facilities.
                3.2.5.5.3.  Current Operations. An evaluation of the contractor's current compliance with the proposed safety requirements.                  

        3.2.6.  Contractor Proposals. While the prospective contractor's historical and current safety posture is important, proposed methods of performing work required by the bid package are the most critical elements in determining capability. The CSS/CSM must specifically address the following elements:        

            3.2.6.1.  Contractor Knowledge.  The prospective contractor must demonstrate a thorough knowledge of contract safety requirements and the hazards and protective measures associated with the solicited products or services.
            3.2.6.2.  Proposed Operations.  The prospective contractor proposals for manufacturing processes, tests, storage, handling, transportation, disposal, etc., must be evaluated for compliance with contract safety requirements. Specific hazards shall be identified and proposed methods of control evaluated.
            3.2.6.3.  Personnel and Training.  The contractor must determine how many personnel are anticipated for the new operations.  The CSS/CSM must evaluate the training to be provided.
            3.2.6.4.  Facilities and Equipment.  If new facilities and equipment are required, determine if these will meet the contract requirements.  In cases where the contracts contain facility and equipment standards, the CSS/CSM must specifically address the A&E, aircraft hangars, etc.  The prospective contractor's ability to provide for the new facilities and equipment must also be evaluated before production begins.
            3.2.6.5.  Licenses/Permits.  If proposed contract work requires the prospective contractor to possess federal, state, local, and host nation licenses or permits, determine if these are currently possessed or acceptable applications can be submitted.
            3.2.6.6.  Subcontractors.  If the prospective contractor proposes to subcontract a portion of contract work that is hazardous in nature, the CSS/CSM must evaluate the capability of the prime contractor to verify the subcontractor(s) compliance with the safety requirements of the contract.  Prime contractors are responsible to the government for compliance with contractual terms wherever work is to be performed.

    3.3. LATEST CHANGE Post-award Orientation Conference.  Post-award Orientation Conferences (PAOCs) are conducted to assure that all matters requiring clarification or resolution between contractor and government are considered and contractual requirements explained and understood.  These conferences are normally established by the ACO.  However, Contract Safety personnel may initiate a request for a PAOC to the ACO and may, with the ACO approval, conduct safety only conferences when deemed appropriate. The CSS/CSM will participate in a request and/or conduct a PAOCs when one or more of the following conditions exist:

        3.3.1.  CSS/CSM participation is requested by the ACO or buying activity.
        3.3.2.  The contract involves significant ammunition and explosives operations or major/new production, overhaul, maintenance or modification of government aircraft.
        3.3.3.  The contract contains a specific clause requiring clarification. Contract commitments made during the pre-award survey, i.e. letters of intent, request for existing conditions, etc.
        3.3.4.  The Team Chief determines that it is necessary.
        3.3.5.  The buying activity safety personnel are holding a PAOC and/or participating in the PAOC.  The Contract Safety agenda covered during the PAOC shall include:

            3.3.5.1.  A discussion of the safety requirements specified in the contract.
            3.3.5.2.  The function, frequency and scope of surveys, discrepancy reporting, and corrective action requests and methods.
            3.3.5.3.  The contractor's plans to satisfy the safety requirement of the contract
            3.3.5.4.  The status of the pre-award commitment.  Verify whether the contractor commitment has/has not been satisfied; initiate corrective action if commitment has not been satisfied.
            3.3.5.5.  The contractor's mishap notification and investigation procedures.
            3.3.5.6.  The protection of Government property.
            3.3.5.7.  A discussion on the special contract requirements and procedures for the submission of waiver requests, site and construction plans, and other required reports, documentations, approvals, requests, etc.        

    3.4.  The CSS/CSM must use the DD Form 1484 to document the PAOC discussions, agreements, decisions, action items and other conference minutes which will be provided to the ACO for inclusion on DD Form 1484, Post-Award Conference Record. 
    3.5.  Pre-Operational Safety Review.  A pre-operational safety review will be conducted of all new A&E contractors and all contractors whose contracts require significant new or modified operations, facilities, and/or equipment.  The pre-operational reviews should be conducted prior to the start of actual production or contract work.  These reviews will be directed at providing reasonable assurance that hazards have been identified and adequate controls established prior to the introduction of hazardous materials.  Pre-operational safety reviews of other contractors may be conducted as deemed necessary.  If the results of these reviews potentially affect the assigned contractor risk level, a new change in the risk rating may be appropriate.  Pre-operational safety reviews will be documented as part of the post-award safety survey report if conducted in conjunction with such survey or as a Contract Safety visit, if conducted separately.
    3.6. LATEST CHANGE  Post-Award Safety Surveillance

        3.6.1.  The post-award safety survey is a comprehensive on-site evaluation of the contractor’s safety and fire protection program as it relates to the contractual safety requirements.  It includes a review of both management effectiveness and program evaluation with regard to specific contractual requirements.  It is essential that personnel conducting these surveys possess both technical and management expertise to assure that contractor methods of hazard control area acceptable.  Corrective actions must address specific causes of nonconformities and management action to prevent recurrence rather than just the reported instances.
        3.6.2.  The frequency of post-award safety surveillance will primarily be based upon the degree of risk and magnitude of potential Government loss associated with the type of work being performed and the materials involved.  However, the individual contractor's safety history, current level of performance, complexity of operations and sole source must also be considered when determining the proper level of surveillance.  The CSS/CSM cognizant of the individual contractor is charged with the responsibility of determining the post-award safety survey frequency.  The frequency shall also be based on the risk level derived from previous surveillance, the criticality of the system and/or customer driven requirements.  In no case will a frequency of less than one survey during a fiscal year be established.  Where intermittent contractors and short-term contracts are involved, survey scheduling shall be adjusted to correspond with contract performance periods. Decisions on postaward safety survey frequency will initially be made by fully certified CSS/CSM.  However, Team Chiefs are ultimately responsible for meeting organizational performance objectives and ensuring that the workload assigned to each CSS/CSM on the Team Chief's team is performed to the highest standards in accordance with published guidance. CSS/CSMs will be assigned workload by his/her Team Chief.  Team Chiefs shall work closely with each assigned CSS/CSM to manage individual RHPs.  If necessary they will provide assistance and make decisions on the frequency of surveys.
        3.6.3.  Risk is identified as High, Moderate or Low.  ORM is the primary tool that is used to assess risk at contractors’ facilities during the survey.  The consequences and likelihood of a mishap determine the risk rating.  Each CSS/CSM must be trained to use ORM to accurately assess risk at all types of facilities under their cognizance.
        3.6.4.  The post-award safety surveys are to be conducted as program evaluations and are not intended as compliance inspections.  All post-award safety surveys are based on a contract assignment or secondary delegation requiring periodic monitoring of a contractor's compliance with contract safety requirements.  The survey must result in an overall conclusion as to the current status of the contractor's program and degree of protection provided.  For a contractor that has a surveillance frequency of more than annually, a limited post-award safety survey report can be documented identifying only relevant changes to the contractor’s management, safety program and any nonconformities noted with the requested corrective action, if necessary.
        3.6.5.  Each month, the CSS/CSM will review the RHP to determine the proper contractor surveillance.  The CSS/CSM will notify the contractor in advance of the proposed survey to determine a time convenient for both parties and to assure that necessary personnel are available.  If mishap reports or QAR deficiency reports demonstrate that on-site surveys are not resulting in a true evaluation of the contractor's normal operations or when corrections of nonconformities are transitory, unannounced surveys may be performed.  Such surveys must be coordinated with the ACO.
        3.6.6.  The CSS/CSM will also notify the QAR who is cognizant of the contractor operations to be surveyed and invite them to accompany the CSS/CSM during the survey.  This will aid the QAR in the event that they asked to verify corrective actions, and to familiarize them with potential hazards in the facility.  The QAR will only be utilized to perform verification of corrective actions to issues that do not require review of complex operations or processes requiring advanced safety technical knowledge.
        3.6.7.  During the post-award safety review, the CSS/CSM shall conduct a complete review of all contract related safety program elements, facilities and operations.  The survey will be limited to only the portions of the facility used for government contract work or by the QAR in the normal course of duties, and the areas adjacent, which in the event of fire, explosion, or other mishap, could adversely affect government property, production, or personnel.  Exceptions to this requirement may be made when multiple storage magazines, intermittent operations, or operating remote processes are involved.  Selective or sampling reviews may be conducted if multiple magazines, intermittent operations, or remote processes limit entry.  In the case of intermittent operations (i.e., weapons firing, test, etc.), every effort shall be made to schedule surveys when operations are in progress.
        3.6.8.  Preparation for post-award safety survey is essential.  Prior to conducting a survey, the CSS/CSM will familiarize himself/herself with the following:

            3.6.8.1.  Contract safety requirements.
            3.6.8.2.  Product, test and operations required by contract.
            3.6.8.3.  Previous pre-award/postaward safety surveys.
            3.6.8.4.  New contracts awarded.
            3.6.8.5.  Status of follow-up actions and/or nonconformities.
            3.6.8.6.  Existing waivers or exemptions of contract safety requirements.
            3.6.8.7.  QAR reports of nonconformities/hazards.
            3.6.8.8.  Mishap reports.
            3.6.8.9.  Existing facility data.
            3.6.8.10.  Facility risk assessment. 
            3.6.8.11.  Scheduled completion date of contract(s).
            3.6.8.12.  ACO concerns.

        3.6.9.  The CSS/CSM shall conduct an in-briefing with contractor management personnel to ensure that they are aware of the purpose, scope and nature of the survey.  Representative(s) of the contractor must accompany the CSS/CSM during the survey to answer questions, obtain data, and provide descriptions of the process flows and operations.
        3.6.10.  The actual post-award safety survey shall consist of a review of the following elements:

            3.6.10.1.  Safety program staffing, organization, and management and its effectiveness.
            3.6.10.2.  Operational procedures, hazard analysis and compliance with contract safety requirements.
            3.6.10.3.  Facilities construction and maintenance, including fire protection systems.
            3.6.10.4.  Equipment design, maintenance, and operation.
            3.6.10.5.  Operational performance, hazard analysis and compliance reviews with written procedures.
            3.6.10.6.  Protection of government property and equipment whether in use or storage. 
            3.6.10.7.  Control of hazardous material and the disposal/disposition procedures.
            3.6.10.8.  Status of nonconformities noted on previous surveys.
            3.6.10.9.  Site plans, waivers, quantity distances issues and exposures between production facilities and product lines.
            3.6.10.10.  Request information pertaining to federal or state OSHA inspections conducted along with any outstanding notices of violations.  Review OSHA 300 log information to ascertain the contractor's Lost Workday Injury Rate (LWIR) for comparison to the national average for the same type of industry. 

        3.6.11.  After the survey, the CSS/CSM must conduct an exit briefing with both the government representative and the contractor management personnel.  The debriefing will include all observed nonconformities of contract safety requirements, corrective action required by the contractor; timeframes for completion of corrective action by the contractor; corrective action request (CAR) level to be pursued by the CSS/CSM, ACO and/or QAR; dates of proposed follow-up visits by the CSS/CSM, if necessary; and an evaluation of the current effectiveness and status of the contractor’s safety program; planned follow-up actions, and an evaluation of the effectiveness and current status of the contractor's safety program.  The exit meeting shall serve as a forum for discussion of recommended management improvements, interpretation of safety standards, and free exchange of ideas and knowledge leading to potential opportunities for improvement.

4.  Risk Monitoring:

    4.1.  Special Activities.  Certain types of contracts, surveillance requirements, surveys/visits and special programs require special guidelines.  These activities include:      

        4.1.1.  LATEST CHANGE  Indemnification Safety Survey.  Contract Safety supports the Air Force and Missile Defense Agency (MDA) in performing industrial safety surveys at facilities that have requested indemnification.  Prime contractors with launch operations at government facilities are authorized by Public Law (PL) 85-804 and 10 USC 2354 to request indemnification for themselves and their subcontractors for unusually hazardous or nuclear risk.  The Air Force or MDA will submit a request for the CSS/CSM to perform an indemnification survey of prospective prime contractor and subcontractors they have identified in the package they submit to DCMA.  The contractor is currently, or will be soon, performing unusually highly hazardous or nuclear risk operations within the scope of an existing awarded contract, established solicitation, contract modification or proposed solicitation's statement of work or they may be a commercial entity with launch operations on a government facility and have no current government contracts.  Indemnification safety surveys are conducted to protect the government and contractor against damage, loss of property and/or injury to people.  Additionally, they are to assure that the contractor operational or manufacturing risks of unusually highly hazardous or nuclear risk operations in nature are appropriately insured and/or indemnified.  The safety portion of the indemnification requests will be submitted to DCMAC-JS or his representative.  The requests will then be passed on to the CSS/CSM via the appropriate Team Chiefs.  If a CSS/CSM receives an indemnification request from any other source, the CSS/CSM is required to contact his/her Team Chief for further instruction.  Indemnification requests have short deadlines with the safety requirements flowed down to the subcontractors.  When the government accepts a request for indemnification from a contractor, the Government assumes an established level of monetary risk partially based on the contents and findings found within the CSS/CSM’s indemnification report.  When the CSS/CSM has received the indemnification request the CSS/CSM shall review it to determine:

            4.1.1.1.  Whether the contractor is in compliance with current contractual safety requirements.
            4.1.1.2.  Whether the contractor is currently in a pre-award survey contract process.
            4.1.1.3.  If there are no current government contracts a review of the company command media and safety programs is an acceptable method as part of the process to determine if the company has a demonstrable safety program.
            4.1.1.4.  The CSS/CSM will utilize both regulatory and consensus standards to determine what might be required to mitigate any identified risks, i.e., as an example but not limited to NFPA 10, 30, 495, 498, etc.

        4.1.2.  The CSS/CSM will provide the following safety information for indemnification survey request:

            4.1.2.1.  A description of the contractor’s safety program, including system safety efforts.
            4.1.2.2.  A copy of the contractor’s organizational chart of key personnel.
            4.1.2.3.  A summary of the contractor’s performance record in accordance with the safety plan over the past 12 months, including the status of any OSHA Notices of Violation.
            4.1.2.4.  The date of the last post-award safety survey.   (If the contractor is currently under contract surveillance)
            4.1.2.5.  The contractor's compliance with the safety requirements contained in the current contracts or through the review of their programs to have the ability to express in a report that the company being reviewed has a demonstrable safety program with no outstanding issues where a recommendation of not recommending indemnification will be made.  All decisions for indemnification are made at the Secretary of the Air Force or associated service level of authority.

        4.1.3.  Mishap Notification and Investigation.  When the CSS/CSM is informed of a reportable mishap, the CSS/CSM will make immediate telephonic notification to his/her supervisor and the Branch Director. The Branch director will determine the level of notification necessary to the applicable DOD component and DCMA Director that a mishap occurred, furnish information concerning the mishap, monitor the progress of the investigation, and its impact on the contract performance and production base.  Electronic distribution of mishap information will be made IAW published instructions contained in this policy.  Mishap reports are fact-based information intended for DoD and military services.  Reports should have limited technical language and properly spelled out acronyms. Contents should briefly state the facts and assess the impact on contractor performance.  The CSS/CSM shall ensure that:

            4.1.3.1. The contractor’s reports comply with the contractual requirements.
            4.1.3.2.  LATEST CHANGE  The Branch Director, DCMA Director, ACO, PCO and POC Safety Office are notified of any potentially reportable mishap within 3 hours or as soon as possible of being notified of the reportable mishap.   The CSS/CSM shall follow the guidelines of DoD 4145.26-M, Chapter 2 to report an A&E mishap.  For aircraft mishaps, the CSS/CSM shall follow the mishap guidelines of DCMA Instruction 8210.2, 6.5, Mishap Notification.
            4.1.3.3.  All mishap notification, i.e., initial, supplementary and final reports must be forwarded to all mishap addressees listing. Mishaps that occur at subcontractor facilities shall be reported to the cognizant CSS/CSM and ACO for the prime contract.
            4.1.3.4.  Use e-mail, fax or electronic message to transmit the reports.  LATEST CHANGE  Refer to  Aircraft Operations Guidebook, 6.5.3 to report the following mishap categories:

                4.1.3.4.1.  Aircraft Flight.
                4.1 3.4.2.  Aircraft Flight Related.
                4.1.3.4.3.  Aircraft Ground.
                4.1.3.4.4.  Foreign Object Damage (FOD)
                4.1.3.4.5.  Industrial.
                4.1.3.4.6.  Missile.
                4.1.3.4.7.  A&E and industrial mishaps.  (Use DoD 4145.26-M, Chapter 2 and/or service requirements).

        4.1.4.  LATEST CHANGE  Aircraft.

            4.1.4.1.  Aviation Program Team (APT). As a member of the APT, the CSS/CSM is responsible for the surveillance of the contractor’s aircraft ground and industrial safety processes as specified by DCMA Instruction 8210.2, 1.2.12.  The CSS/CSM must comply with the requirements below:

                4.1.4.1.1.  CSS/CSM Initial Qualification.  The CSS/CSM must complete the DCMA Aircraft Ground Safety Course and must be certified in industrial safety. 
                4.1.4.1.2.  Verify Aircraft Rescue and Fire Fighting (ARFF)/Hangar Fire Suppression Requirements. The CSS/CSM will coordinate with the contractor’s representative to ensure all hangar fire suppression systems, ARFF equipment and firefighter training standards meet contractual requirements.
                4.1.4.1.3.  The CSS/CSM will advise the GFR of any nonconformity and make recommendations regarding the validity of the contractor’s mitigation plan.
                4.1.4.1.4.  Verify Overall Ground Safety Environment.  The CSS/CSM will ensure that the contractor is conducting operations using facilities, equipment and procedures that do not put government assets at undue risk.

        4.1.5.  The CSS/CSM is required to participate in the Annual APT survey(s).  The CSS/CSM must participate at a minimum in one contractor survey every 12 months.  The APT will use numerous sources of information such as observations throughout the year, corrective action requests (CARs), Aircraft Operations Inspection (AOI) reports, etc, to formulate the assessment(s).  The assessment shall be risk based.  The Contract Safety report must contain a facility data sheet.
        4.1.6.  Aircraft Operations Inspections (AOI).  AOIs are risk based evaluations of DCMA units with flight operations.  DCMA-AO regulates the frequency of an AOI visit based on factors such as known risks and the extent of the government’s exposure. AOIs look at both Government and contractor operations.  The goal is to determine where the Government’s risks lie and how well those risks are managed. AOIs focus on the observations made during the inspections.  However, the AOI team also considers past performance and documentation in their overall evaluation.  Special assessments may be conducted at any time on high risk facilities or facilities that may be of special interest.  The DCMA-AOI Guide is available on the DCMA Homepage, and it contains extensive information about the AOI process.
       4.1.7.  In preparation for an AOI the CSS/CSM shall have the following information readily available for review:

            4.1.7.1.  A schedule of inspections and dates completed.
            4.1.7.2.  Inspection reports of last three audits.
            4.1.7.3.  The last AOI inspection report.
            4.1.7.4.  Minutes of the last three contractor's safety council meetings.
            4.1.7.5.  The contractor reportable injury rate lost day rate.
            4.1.7.6.  The contractor's accident log.
            4.1.7.7.  The contractor's confined space procedure.
            4.1.7.8.  The contractor's severe weather Plan.
            4.1.7.9.  The facility data sheet (contents to be determined by the CSS/SM).
            4.1.7.10. The DESC fuel contract or fuel supplied by services, fuel samples reports. 
            4.1.7.11.  The record of the last emergency exercise.
            4.1.7.12.  The record of other federal/state agency visits, i.e., EPA, FAA, OSHA.
            4.1.7.13.  The auditor's evaluation, e.g., brief description, of the CSS/CSM's interaction with the APT, and its effect on the contractor’s safety program, to the supervisor.

        4.1.8.  Contract Safety Surveillance. Contract Safety surveillance is a series of contract management processes that, when combined, should provide reasonable assurance that a contractor's safety and fire prevention programs meet or exceed contractual requirements.  The thrust of these surveillance processes shall be the evaluation of the contractor safety management systems' effectiveness.  The management systems or programs include the organizational structures, policies, authorities, lines of communication, management tools, and assessment indicators used by the contractor to manage, direct, and control safety and fire prevention programs. 

Note:  DCMA functional elements that require advice, assistance and clarification of contractual safety related matters shall coordinate with the Contract Safety Branch, DCMAC-JS.

        4.1.9.  Surveillance processes.  Contract Safety surveillance processes provide the framework for the continuous and periodic surveillance.  All actions are predicated on the existence of solicitations and/or contract safety requirements over-and-above or directed at different areas of coverage than existing federal, state, or local laws, standards, or regulatory requirements.  When properly applied, the surveillance processes should result in the selection of a fully capable contractor that performs required contract work, assures that requirements are met, and, when necessary, identifies and assures correction of nonconformities as to cause.
        4.1.10.  LATEST CHANGE  Risk Management. Operational Risk Management (ORM) will be used to assess the risk levels of contractor operations and facilities. Surveillance strategies and frequencies will be based on assigned risk levels. CSS/CSMs will focus surveillance efforts in the areas where the greatest risks are identified. 
        4.1.11.  Contractor Improvement.  The primary tool to manage and ensure contractor improvement is through the identification of nonconformities during routine surveillance and the issuance of CARs when contractual nonconformities are discovered.  Specific guidance for the issuance of CARs and follow-up are contained in the Product Assurance section of the DCMA Guidebook.  The CSS/CSM shall document and track CARs until they are completed and closed.  Repeat findings during subsequent reviews may indicate systematic issues in the contractor’s safety program and may require elevation of risk ratings and increased surveillance.
        4.1.12.  Contractor Site and Construction Plans and Request for Waivers.  During contract review the specific requirement for processing site and construction plans and/or waiver requests must be determined.  The review process for contractor submissions differs for contractor-owned contractor-operated (COCOs) and (GOCOs) facilities.  DoD 4145.26-M, as provided for in contracts by DFARS 252.223-7002, requires submission and approval of site and construction plans prior to the construction or use of new or modified explosives facilities.  Numerous contracts containing this requirement also contain a DD Form 1423 Data Item Requirement for the same information to be submitted to the procuring activity program manager.  When this dual requirement exists, Contract Safety personnel must ensure that the contractor and the ACO are aware of the review and approval procedures required, DoD 4145.26-M, and that dual submissions are avoided where possible.  When contractor requests for approval of site and construction plans and/or waivers of explosives safety requirements are received, the initial review will be performed by the CSS/CSM, who will ensure that the contractor’s site plan and/or waiver request is in compliance with the appropriate contractual requirements before the plan/waiver request is submitted to the Team Chief or his/her designee for a second level review.  The Team Chief and/or his/her designee will review the CSS/CSM comments and recommendations, conduct the final review, and forward a recommendation for approval or disapproval to the ACO for transmittal to the procuring activity for final determination.
        4.1.13.  Department of Defense Explosives Safety Board (DDESB).  DDESB functions under the administrative guidance of the Office1 of Secretary of Defense and is under the direction, authority, and control of the Secretary of Defense, as set forth in DoD Directive 6055.9, the Department of Defense Explosives Safety Board.  The Board has authority to visit any Government-owned facility where explosives are manufactured, tested, handled, transported, or stored while in the custody of DoD.  The DDESB will normally advise DCMAC-J before entering a contractor's plant, citing the purpose of the visit. Additionally, Contract Safety personnel will notify DCMAC-J through their management chain of the time, date, and place of the DDESB survey immediately after becoming aware of the proposed survey.  They will cooperate fully with DDESB members and will accompany them during the survey.  A copy of the DDESB report will be requested by the CSS/CSM for inclusion in the DCMA contractor file.  Additionally, a copy will be provided to DCMAC-J.  If difficulties arise in obtaining a copy of this report, DCMAC-J will be notified.
        4.1.14. Subcontractors.  The prime contractor is responsible to the government for all work including the work performed by subcontractors under their contract.  The CSS/CSM shall perform surveillance of subcontractors and subcontract work when supporting contract administration is requested in accordance with FAR 42.204(b) and DFARS 223.7004(b).  All decisions on and requests for supporting contract administration will be performed in accordance with the requirements of FAR 42.204, DFARS 242.204.  DFARS 223.370 and DFARS 252.223-7002 clause specifically address subcontracting as related to A&E contracts.  DFARS 223.70 requires that contracting officers normally request supporting contract administration when the nature of the subcontract work potentially endangers Government property, Government personnel, production capability or prime contract completion. Therefore, the CSS/CSM will determine when these conditions are met and inform the ACO that a request may be issued.  The DFARS places no restriction on the number of tiers of subcontractors to which these requirements are applicable.
        4.1.15.  When the CSS/CSM become aware of subcontract work in a prime contract facility which potentially endangers the Government’s interest, the CSS/CSM shall alert the ACO cognizant of the prime contractor issuing such subcontracts.  Upon receipt of such information, the CSS/CSM cognizant of the prime shall make a determination if a request for supporting contract administration is appropriate.  When subcontract work potentially endangers Government property, personnel, or production capability related to existing, assigned prime contracts in the same facility, such work will be reviewed and nonconformities reported under the existing prime contracts.  Although the prime contractor is responsible for corrective actions of subcontractors, the CSS/CSM has a legal responsibility to address situations where the work endangers government property, personnel or production capabilities and will address the situation at the subcontractor level with copies of actions taken to the CSS/CSM and ACO cognizant of the prime contractor.
        4.1.16.  LATEST CHANGE  The CSS/CSM will not provide contract administration surveillance of subcontractors or subcontract work unless a formal request for supporting contract administration has been received from the CMO cognizant of the prime contractor.
        4.1.17.  Aircraft Fuel and Servicing (Reference MILD STD 1518).  This standard establishes the minimum performance and quality requirements for the storage, handling and servicing of aviation fuels, lubricating oils, and hydraulic fluids at contractor-owned contractor-operated aircraft maintenance facilities.
        4.1.18.  Property Administration.  Contracts Directorate (DCMA-AQ), Business Operating Center, Property Division (DCMAC-EY) has responsibility for the management of the Government property provisions of contracts.  The PA is the technical expert in property administration and is responsible for providing guidance, training, education and clarification to contractor and other government personnel on property administration issues.  DCMA is the Executive Agent for the publication of DoD 4160.21-M-1, the DoD Manual for the Performance of Contract Property Administration.  The CSS/CSM shall familiarize themselves with the PA in their geographical area and request information pertaining to aircraft or aircraft components damaged that are under the cognizance of Property Division and not under the GFRC.  This information shall be passed up to their supervisor and the Contract Safety Branch Director. 
        4.1.19.  When during Contract Safety surveillance, actual or potential hazards to Government property/material/equipment are observed, the details will be noted in the report and the PA and ACO will be notified IAW the DCMA PA Instruction.  The report will include suggested corrective actions.  The PA and ACO will pursue corrective actions in accordance with the contract requirements in coordination with the CSS/CSM.
        4.1.20.  Contract Safety visits for the sole purpose of Government property protection (in the absence of a safety clause) are discretionary and will only be conducted in response to requests from responsible management personnel (i.e., CMO Commanders, ACOs, PAs, PLCOs).  Findings and recommendations included in the visit reports will be provided to the requestors for action.  The CSS/CSM will continue to coordinate and provide assistance until corrective actions are completed.  Individual justifications, citing potential hazards which place Government property at risk, must be provided.
        4.1.21.  When there are allegations that government property is or may be affecting the health or safety of Government/contractor personnel, the CSS/CSM shall coordinate with the Safety & Health Manager (SHM) on this matter.
        4.1.22.  The requirement for cooperation and coordination on all the above actions makes it essential that the CSS/CSM ensure that the applicable Contract Management personnel are fully aware of the CSS/CSM's role and expertise.  The CSS/CSM must continue to coordinate and assist, on all actions until final resolution.
        4.1.23. Plant Clearance.  The plant clearance officer (PLCO) is responsible for ensuring that the contractor complies with the disposal provisions of the contract. Contract Safety personnel may be requested to assist PLCOs with activities related to the demilitarization and disposal of government property in accordance with DCMA policies for Property Management on Government Contracts and Plant Clearance.
        4.1.24.  The CSS/CSM must inform the ACO of situations in contractor facilities that may require the disposal of Government A&E.  Potential or actual contract explosives safety standard violations must be cited in this correspondence.  A&E residue (other than Government) that is generated under a DoD contract and that violates contractual safety standards must be referred to the ACO for resolution.
        4.1.25.  LATEST CHANGE  Industrial Base Analysis (IBA).  DCMA Industry Surge Analysis Guidebook requires the Industrial Base Analysis Manager (IBAM) to coordinate requests for production planning schedules with the CSS/CSM when items containing explosives components are involved. Industrial base planning (IBP) is an evaluation of the contractor's production capacity and the results of this evaluation may be affected by limitations imposed by explosives quantity-distance and maximum explosives loading capacities.  The CSS/CSM will respond to such requests and assist the IBAM in the evaluation.
        4.1.26.  LATEST CHANGE  Occupational Safety & Health Act (OSHA Act).  Enforcement of the OSHA Act for contractor employees is the responsibility of the Department of Labor or applicable state program offices.  DCMA CSS/CSMs shall be observant of federal and/or state safety requirements if they pose potential harm to government employees or damage to government property during the performance of a contract safety survey.  The CSS/CSM is responsible for identifying nonconformities observed during the conduct of the survey and/or walk-through inspection of contractor facilities to the contractor, on-site DCMA employees and the DCMA Safety & Health Manager.  All nonconformities must be documented in the survey report with the specific references.  DCMA Safety & Health will assume the responsibility for follow-up of issues pertaining to DCMA employee exposures to nonconformities and efforts by DCMA in seeking corrective actions initiated by DCMAC-JS.  Contract Safety's role in supporting any safety and health request from CMO Commanders, employee supervisors or the DCMA Safety & Health Program is only by special request.
        4.1.27.  Systems Safety Engineering and Management, Systems Safety is the responsibility of the Program and Technical Support function. Systems Safety clauses/requirements do provide direct support to Contract Safety surveillance.  The CSS/CSM shall establish close coordination with their respective Program and Technical Support organizations to assure a clear delineation of responsibilities and the identification and resolution of common problems.
        4.1.28.  Radioactive Materials.  DFARS 252.223-7005, Notice of Radioactive Materials, is not considered a safety clause requiring scheduled Contract Safety surveys.   However, when requested by the procuring activity, pre-award safety surveys may be conducted to verify proposed contractor’s current compliance with existing licenses/permits.  The cognizant Nuclear Regulatory Commission (NRC) office or Agreement State may be contacted to verify information provided by the proposed contractor. Specific safety clauses containing radioactive materials control/operational requirements will be administered according to the terms of the contract and delegation.  Clauses only requiring compliance with NRC or Agreement State requirements are not considered safety clauses requiring postaward contract safety surveillance.                       

    4.2.  Exceptions.  Certain contract requirements that appear to address safety related issues do not require Contract Safety involvement.  These contracts include:

        4.2.1.  DFARS 252.217-7251, Hazardous Material Identification and Material Safety Data.  This DFAR clause requires that the contractor develop and submit to the procuring activity a Material Safety Data Sheet for contract end items.  It neither contains safety standards with which the contractor is required to comply, nor is it a valid indication of the presence of hazardous operations or materials in the contractor plant.  Therefore, there is no safety delegation requiring Contract Safety surveillance.  The CSS/CSM will not be involved with these contracts based solely upon DFARS 252.217-7251.
        4.2.2.  Defense Fuel Supply Center (DFSC) GOCO Facilities.  DFSC has assumed complete responsibility for all safety surveillance at its GOCO facilities.  DFSC conducts annual surveys of these facilities to assure both contractor safety compliance and the safety and health of government personnel assigned. Contract Safety surveys/visits of these facilities are not required.
        4.2.3.  FAR 52.246, Inspection Clauses.  These clauses will not be considered as a safety clause which requires regular on-site safety surveillance for protection of Government employees.
        4.2.4.  DFARS 252.228-7006, Accident Reporting and Investigation Involving Aircraft, Missiles and Space Launch Vehicles.  This clause is a reporting requirement.  While The CSS/CSM should be aware of its presence in contracts, it does not require on-site surveillance by the CSS/CSM.
        4.2.5.  Walsh-Healey Public Contracts Act.  The Department of Labor conducts investigations and enforces requirements of the Act independently of procuring departments.  Contract Administration offices are not responsible for conducting safety inspections of the type foreseen by the Act.  This is not a clause requiring Contract Safety surveillance.                                    

    4.3.  LATEST CHANGE  Corrective Action.

        4.3.1.  If contractual nonconformities are noted during the safety survey, the following guidance will be followed to determine the level of the corrective action request to be issued to the contractor:

            4.3.1.1.  Timely correction of nonconformities of contract safety requirements is a basic element of the contractor’s mishap prevention program. The CSS/CSM will always request contractor corrective action when nonconformities in contract compliance are found.  The CSS/CSM must promptly notify the contractor of nonconformities found during the survey visit; must assure that the contractor understands that the nonconformities are in violation of the contract; that the contractor understands when the corrective actions should be completed; and the contractor understands that appropriate corrective action includes addressing both the specific nonconformity and its underlying cause.
            4.3.1.2.  Current Agency policy for the issuance of CARs shall be followed to ensure that a standard approach is used by all members of the Contract Management Team when dealing with contractual nonconformities.  The CSS/CSM must objectively analyze each nonconformity before the selection of the corrective action request level.  The analysis must consider timeliness of the desired action, the relative importance, worst case potential for mishap, prior responsiveness of the contractor, criticality of the nonconformity, time period remaining until the schedule end of the contract, and repetitiveness of similar nonconformities.  The contractor responses to corrective actions must address specific causes of the nonconformities and management action to prevent recurrence rather than just the reported instances.  The CSS/CSM must determine the effectiveness of the contractor corrective actions and consider the possible need for increased surveillance until assured that the contractor’s corrective actions are satisfactory.
            4.3.1.3.  CARs.  CARs are generated to document contractual nonconformity and to assure contractors correct and prevent recurrence.  The level of CAR issued is dependent on the severity of the contractual nonconformity and contractor responsiveness to the request.  CARs may be issued when any contractual vehicle is in place. All CARs require documentation - a record of contractual noncompliance.  The stated nonconformity shall clearly show a departure from the stated contract requirement.  As all level of CARs are required to be communicated in writing.  All CARs require follow up to assure that contractor corrective and preventive actions have been accomplished and are effective.
            4.3.1.4.  Selection of Corrective Action. 

                4.3.1.4.1.  The CSS/CSM will always request contractor corrective action when nonconformity is found in contract compliance.  The level of corrective action will depend upon the criticality of the nonconformity.  There is no restriction on the initial level of corrective action selected.  Levels I through III are not intended to be progressive in nature for serious or repetitive conformities.  They may, however, be used progressively for minor nonconformities of a noncritical nature.
                4.3.1.4.2. All nonconformities and requests for corrective action will be fully discussed with contractor management personnel before formal correspondence is generated.  This is the intent and reason for the exit interview. This is the intent and reason for exit interview required by paragraph 3.6.11.  
                4.3.1.4.3. When contractor corrective action is required, it will be requested by one or more of the following levels: 

                    4.3.1.4.3.1.  Level I – Issued when a contractual nonconformity requires no further attention to resolve the issue.  Level I CARs are appropriate for issues that can be corrected on the spot. Level I CARs are not to be issued in situations that require further assessments of supplier controls or systems.  Level I CARs may be directed to working level personnel.
                    4.3.1.4.3.2.  Level II – Issued when contractual non-compliances cannot be corrected on the spot and where they could adversely affect cost, schedule, or performance if not corrected.  Level II CARs shall be directed to the supplier management level responsible for the process with a copy to the responsible ACO.
                    4.3.1.4.3.3.  Level III – Issued to call attention to serious contractual non-compliances to the supplier's top management.  They may be coupled with contractual remedies such as reductions of progress payments, cost disallowances, cure notices, show cause letters, or business management systems disapprovals.
                    4.3.1.4.3.4.  A Level I or II need not be issued before a Level III CAR is generated.
                    4.3.1.4.3.5.  Due to the seriousness of the Level III CAR, it will be coordinated with the Contract Safety Team Chief, the Contract Safety Branch Director, ACO, cognizant CMO Commanders and management personnel.  Further coordination may be required through the Division Director and HQ staff personnel prior to issuance.

            4.3.1.5.  A copy of the Level III CAR and all accompanying correspondence shall be provided to the customer, the Product Division Operations Director, the appropriate DCMA Contract Integrity Center (CIC) Counsel, and the appropriate Defense Contract Audit Agency (DCAA) representative.  If a prime contract is involved, a copy should be provided to the responsible government Office at the prime contractor's location.
            4.3.1.6.  When Level III CARs are closed out, copies of the letter notifying the supplier of the closure action shall be sent to all those addressed/copied in the original CAR.
            4.3.1.7.  Level IV- issued to advise the supplier of contractual remedies such as suspension of progress payments or product acceptance activities, termination for default, and suspension or debarment, in accordance with applicable FAR/DFARS policies and procedures.  Level IV CARs shall be addressed to the supplier’s top-level management.  The Level IV CAR is to be signed by the responsible ACO; in addition, the ACO’s supervisor shall countersign the CAR.  The CMO Commander shall be notified before a Level IV is issued.
            4.3.1.8.  A copy of the Level IV CAR and all accompanying correspondence shall be provided to the CMO Commander, customer, the Product Division Operations Director, the appropriate DCMA CIC Counsel, and the appropriate DCAA representative.
            4.3.1.9.  When Level IV CARs are closed out, copies of the letter notifying the supplier shall be sent to all those addressed in the original CAR.
            4.3.1.10.  CAR records shall include the original CAR, the contractor’s response (may not be applicable to a Level 1), and applicable documentation relevant to resolution of the issue.
            4.3.1.11.  Should a request for the release of information associated with contractual nonconformity be received, these requests are to be forwarded to the appropriate General Counsel for action.  Requested information may not be released without expressed written authorization.

        4.3.2. Subcontractor Corrective Action.

            4.3.2.1.  If nonconformities noted involve subcontract work at any tier and safety surveillance has been delegated, corrective action methods of paragraph 4.3.5.4 shall be followed.  When Level III corrective action is required, correspondence will be sent to the prime ACO requesting that the prime contractor be directed to take immediate action with the subcontractor.  Copies of all reports and resulting correspondence will be provided to the ACO and the CSS/CSM of the prime contractor.
            4.3.2.2.   If nonconformities are noted in subcontract work for which no safety delegation has been received, the ACO and CSS/CSM cognizant of the prime contractor will be notified and corrective actions recommended.  Additionally, a request for supporting contract administration will be recommended if work involved potentially endangers Government interests (Reference FAR 42.204(b) and, when applicable, DFARS 223.7004(b).)        

    4.4.  Contract Safety Visit.

        4.4.1.  Contract Safety visits supplement post-award surveys and are conducted to address specific problems or questions, coordinate with visiting procuring activity personnel, or increase the knowledge of complex contractor processes.  They are usually for a short period of time and are not as extensive as postaward safety surveys.  Notification to contractors of impending visits will be as described in paragraph 3.6.5.  Contract Safety visit reports will contain the same basic data as postaward safety survey reports in paragraph 5.1 and will list the contract(s) involved in the visit.  Contract Safety visits shall be conducted for the following reasons to: 

            4.4.1.1.  Perform limited reviews of specific contractor operations/ processes.
            4.4.1.2.  Verify follow up to survey recommendations.
            4.4.1.3.  Observe and verify investigation of mishaps.
            4.4.1.4.  Provide assistance to contractors, QARs, and other DCMA elements, or procuring activities.
            4.4.1.5.  Investigate problems/complaints concerning ACO, government property issues, and other DCMA functional elements.
            4.4.1.6.  Increase knowledge of new or complex contractor processes and operations.
            4.4.1.7.  Perform pre-operational reviews.
            4.4.1.8.  Responses to employee reports of imminent danger situations or in support of DCMA government employee occupational safety and health program.

    4.5.  DCMA SAFETY AND HEALTH PROGRAM

        4.5.1.  DCMA Safety and Occupational Health (SOH) Program ensures appropriate regulatory guidance is followed, to improve agency operations and/or mission processes, and mitigate operation and/or mission hazards, thus minimizing the likelihood of occupational injury and illness.

            4.5.1.1.  The SOH Division is located in the DCMA HR Operations Center, supports the CMO Commanders/Directors by providing technical expertise, hazard mitigation recommendations, periodically evaluating implementation of all safety and occupational health program elements, as well as the overall effectiveness of the CMO's SOH Program.
            4.5.1.2.  If determined necessary, SOH Product Division Safety& Managers may request the assistance of Contract Safety personnel in conducting a site visit. The Division Safety & Manager's written request will detail what assistance is necessary. Upon completion of the site visit, the CSS/CSM will provide the Division Safety & Manager with a report detailing the results of the site visit.  The request should be coordinated with the Director, Contract Safety Branch.
            4.5.1.3. During regularly scheduled contractual surveillance, Contract Safety personnel will be alert for, record and report any unsafe and healthful condition(s) observed that pose actual or potential hazard(s) to DCMA personnel working in a contractor's facility.
            4.5.1.4.  When a letter of delegation (LOD), memorandum of agreement (MOA), memorandum of understanding (MOU) or similar request for DCMA work performance contains or details any Safety and Occupational Health support, it shall be forwarded to the responsible Division Safety & Health Manager for review, coordination, and performance.

  4.6.  Management Review.

        4.6.1.  CSS/CSMs are geographically dispersed.  It is essential that the Team Chief review the CSS/CSM technical performance and provide assistance to resolve problems.  The Team Chief should utilize the DCMA Portal to review the CSS/CSM documentation of assigned work. On-site or telephonic management reviews may be conducted by the Team Chief in conjunction with quarterly, mid-year or annual performance reviews.
        4.6.2.  Conduct of review.  The Individual Performance Plan (IPP) is the primary measurement tool of employee performance.  All performance reviews shall include an evaluation of the employees’ performance against rated criteria contained in the IPP.  The information gathered during reviews are used by the supervisor to rate the employee performance.  Supervisory reviews will ensure the following areas are covered in-depth:

            4.6.2.1.  Demonstrated knowledge of contract management process.
            4.6.2.2.  Review of contracts and identification of survey workload.
            4.6.2.3.  Pre-award survey and PAOC identification and participation.
            4.6.2.4.  Application of risk assessment system and levels of surveillance.
            4.6.2.5.  Technical expertise of the CSS/CSM. One or more surveys of significant contractor facilities will be conducted during the review if performed at the CSS/CSM's location.
            4.6.2.6.  Conduct of safety surveys is in accordance with requirements of this instruction.
            4.6.2.7.  Ability of the CSS/CSM to interface with contractor personnel.
            4.6.2.8.  Preparation and distribution of survey reports in accordance with this instruction.
            4.6.2.9.  Timely performance of required follow-up actions.

5.  Risk Documentation:

    5.1.  Post-award Safety Survey Report.  The documentation of the post-award safety survey is important as the survey preparation and performance.  The documentation provides a record of description and evaluation of the contractor's current operations and safety status.  It must be thorough and accurate since it provides the basis and justification for all contractual actions and forms the historical data for future pre and post-award surveys.  The survey report will be used to document the contractor's current safety status and will contain the following as a minimum. 

        5.1.1.  Contractor name and location(s).
        5.1.2.  Assigned risk level (DoD Risk Model).
        5.1.3.  Type of survey performed.
        5.1.4.  Date of survey.
        5.1.6.  Name of Surveyor.
        5.1.7.  Personnel contacted Government and contractor. 
        5.1.8.  Identify contracts reviewed, item nomenclature, and safety clause(s).
        5.1.9.  Descriptions of hazardous contract processes reviewed, the potential and actual hazards involved, and controls. In place.

    5.2.  Findings.  The CSS/CSM must list the areas reviewed, e.g., management, facility and operations, and provide an evaluation of each. 

        5.2.1.  Actual nonconformities (observed violations of contract requirement) will be specifically described for each area surveyed and requirements referenced.  The status of nonconformities noted during previous must be evaluated.
        5.2.2.  Corrective actions taken by the contractor during the survey must also be described and evaluated.

    5.3. Recommendations.  All recommendations for contractor corrective actions must be directed to determine the root cause of contractual noncompliance observed as well as to the actual violation.  The report must also state clearly what corrective action request (CAR) level will be pursued by the CSS/CSM, and the action that will be required of the ACO and CSS/CSM to verify completion of the corrective action taken.
    5.4. Conclusion.  The CSS/CSM must include an assessment of the contractor’s current safety status in relation to the requirements of the contract.  The conclusion must indicate whether the contractor is or not in compliance with the contractual safety requirements as identified by the findings documented in the report at the time of the surveillance review. The CSS/CSM shall also designate a follow-up date at the conclusion of the out-brief and tentatively scheduled it with the contractor's representative.
    5.5.  A statement of conclusion of each report shall be inserted stating that "During this review no violations of State or Federal OSHA requirements were identified that would pose a threat to government employee." If there are other violations noted they will be described along with references and a report copied to the government's employees supervisor and DCMA Safety and Health.
    5.6.  Contract Safety Survey Report Distribution.  The CSS/CSM must write and submit the safety survey report within 10 days of the date of the survey to the ACO and copies to: 

        5.6.1.  Contract Safety Team Leader.
        5.6.2.  Contract Safety contractor file in the team portal as well as the hard copy file.
        5.6.3.  CSS/CSM cognizant of the prime contractor when the survey involves subcontractor (as required by delegation).
        5.6.4.  Other concerned contract management elements as applicable.

    5.7.  Facility Data Sheet.  The facility data sheet is used to record information that remains relatively constant and eliminates the need to document this information on every post-award survey report.  The CSS/CSM will prepare and/or update the facility data sheet for each contractor facility requiring a post-award safety survey. Copies of the facility data sheet will be maintained in the contractor file stored on the DCMA Homepage (portal), and changes to the facility data sheet shall be made in a timely manner.

Note:  The Contract Safety surveys and correspondence associated with the surveys are government data. For Official Use Only correspondence and the release of contract safety survey reports will be in accordance with DCMA Freedom of Information Program.

    5.8.  Coordination with the ACO.  When an ACO receives a safety report from the CSS/CSM, the ACO shall review the content of the report and its applicability to the terms and conditions of the contract.  If the report recommends the ACO to request the contractor to take corrective action. The CSS/CSM will coordinate with the ACO to ensure that the issues are clearly identified to the contractor and establish the appropriate suspense date for response.  The suspense date is 30 days from the date of the survey and is dependent upon the nature of the finding noted.  The contractor’s response shall reflect root cause analysis, action taken or proposed to gain compliance.  The CSS/CSM will coordinate with the ACO to clarify or resolve any issues and request copies of all correspondence related to the corrective actions and their resolution.
    5.9.  The Contract Safety Branch will prepare an operating program each fiscal year.  The plan will contain management  and administrative actions to ensure effective program implementation and will contain workload data and contractor survey schedules.  Additionally, the plan will contain the Contract Safety workload summary of workload data.  The intent of the plan is to properly identify workload, assign surveillance levels, track workload accomplishment, and determine resources necessary for proper program implementation. A copy of the plan will be provided to DCMAC-J for informational purposes only, no later than 15 October of each fiscal year.

        5.9.1.  Risk Plan Format.  Each Team Chief will maintain a plan for his team.  The plan will be organized as described below:

            5.9.1.1.  Planned formal/informal development of Contract Safety staff.      
            5.9.1.2.  Workload data.
            5.9.1.3.  Contractor survey schedules.

        5.9.2.  Workload Data.  The anticipated workload for the Contract Safety Branch will be presented in the format below.

            5.9.2.1.  Estimated Annual Workload.

                                               Scheduled Post-award Safety Surveys              # Surveys                 # Facilities

                5.9.2.1.1.  A&E.
                5.9.2.1.2.  Aircraft.
                5.9.2.1.3.  Industrial.
                5.9.2.1.4.  NASA.
                5.9.3.1.5.  Other.

            5.9 2.2.  Number of scheduled surveys by quarter         1^st      2^nd      3^rd       4^th      Total    
            5.9.2.3.  Unscheduled Surveys/Visits/Workload                             Estimated Number    

                5.9.2.3.1.  On-site pre-award surveys.
                5.9.2.3.2.  Desk audit pre-awards.
                5.9.2.3.3.  Post-award conferences.
                5.9.2.3.4.  Pre-operational reviews.
                5.9.2.3.5.  Other Contract Safety visits.
                5.9.2.3.6.  Site and construction plan reviews.
                5.9.2.3.7.  Contract Safety requirement waiver reviews
                5.9.2.3.8. Contract safety and health assist visits 
                5.9.2.3.9. Indemnification reviews.

            5.9.2.4. Total scheduled and unscheduled surveys/visits/workload.

    5.10.  Workload reports.

        5.10.1.  LATEST CHANGE  Monthly Workload Reporting.  Each CSS/CSM will prepare a monthly report summarizing workload data for that month with regard to current Contract Safety Performance Indicators. The monthly report will enable the CSS/CSM to track workload accomplishment and determine when a problem exists with workload accomplishment and is reported through Metrics Studio. 
        5.10.2.  Quarterly Contract Safety Report (QCSR). Each CSS/CSM will submit a QCSR to the supervisor for consolidation. The Team Chief will forward the QCSR director by the end of the month following each quarter. The information will include the workload accomplished on the RHP versus the workload projected. A description of reason must be included as to why the workload projected was not (i.e., no current work on contract, contractor representative unavailable, postponed due to pre-award survey, etc.).  The RHP will be updated each quarter to reflect changes made.  A notes section will include information pertinent to changes made during the past quarter. 

    6.1.  Follow-Up Actions.

        6.1.1.  The CSS/CSM will establish a follow-up system with a suspense date to monitor the contractor responses to recommended corrective actions and ACO/PCO correspondence.  Each contractor response will be thoroughly analyzed to assure that all corrective actions are adequate and address the root cause(s) of the nonconformities, not just the noted occurrences.
        6.1.2.  Within 30 days after receipt of the contractor's response to a request for corrective action or of the survey out briefings, if no formal response is requested, the CSS/CSM will conduct follow-up when doubt exists that corrective actions are satisfactory or if recurrence of conditions that caused deficiencies is considered likely.
        6.1.3.  In cases where the nonconformities are serious and a high potential for an accident exists, The CSS/CSM must not delay follow-up until receipt of contractor formal responses.  The CSS/CSM must establish corrective action timeframes with the contractor during the exit interview and schedule a follow-up visit at the end of that time period.
        6.1.4.  Each CSS/CSM must be knowledgeable of the corrective action levels in order to discuss them with the ACO, the PA, GFR and the QAS.

• FAR 4.802/DFARS 204.802, Contract Review
• FAR 9.106-1, Conditions for Pre-Award Surveys
• FAR 42.302 (a) (39), Ensure contractor compliance with contractual safety requirements  
• FAR 42.503, Postaward Conferences
• FAR 46.105, (7) (8) Contractor Responsibilities
• DFARS 242.503, Post Award
• DFARS 252.223-7002, Safety Precautions for Ammunition and Explosives
• DFARS 252.223-7003, Change in Place of Performance--Ammunition and Explosives.
• DFARS 252.228-7001, Ground and flight risk
• DFARS 252.228-7002, Aircraft Flight Risk
• DOD 4145.26-M, Contractors, Safety Manual for Ammunition and Explosives
• DCMA Instruction 8210.2, Aircraft Operations
• Air Force Indemnification Guide
• 29 CFR 1910 Occupational Safety and Health Standards instructions
• 29 CFR 1960 basic program Elements for Federal Employees instructions

• Process Indicator/s:
  • Preaward Safety Requests
  • Contract Safety Indemnification
• Workload Indicator/s:
  • TBD
• Resource Indicator/s:
  • TBD
• Supplier Indicator/s:
  • Aircraft Ground Safety Mishaps
  • Ammunition and Explosives Mishap Rate

• PLAS Process code:  

• Flowchart
• (EDW) - Contract review documentation
• CRR - Contract receipt and review
• QA/PA - Delegation documentation
• Pre-award safety survey system
• EDA Contract Deficiency Report - Contract Safety Data Recommendation

• Contract Safety Portal