This study examines whether First Article Testing (FAT) requirements are frequently misapplied to Defense Logistics Agency (DLA) contracts, resulting in excessive acquisition costs. Guided by three objectives and two research questions, the study employs a mixed methodology combining a qualitative review of secondary governmental and scholarly literature with a survey of thirteen DLA engineers and acquisition employees. The literature review covers DLA's mission, global logistics scope, and the regulatory framework governing FAT under the Federal Acquisition Regulation (FAR) and the Defense Logistics Acquisition Directive (DLAD). Survey findings indicate that a large majority of practitioners believe FAT requirements are frequently misapplied, and the study concludes with recommendations to consolidate regulatory guidance, develop best practices, and reduce acquisition waste.
This paper demonstrates the effective use of primary and secondary data triangulation. By combining a qualitative review of governmental regulations and case law with quantitative survey data from active DLA practitioners, the author strengthens the credibility of the central claim—that FAT requirements are frequently misapplied—beyond what either method alone could support. The reciprocal interpretation synthesis technique (Noblit and Hare, 1988) is explicitly identified, showing awareness of methodological precedent.
The paper follows a formal five-chapter research structure: Chapter 1 defines the problem, hypothesis, research questions, and key terms; Chapter 2 reviews secondary literature on the DLA and FAT regulatory framework; Chapter 3 explains the mixed methodology; Chapter 4 presents data analysis in three parts—regulatory documents, case law summaries, and survey results; and Chapter 5 synthesizes findings and provides actionable recommendations. Appendices supply the survey instrument, case summaries, and a process flowchart reference, supporting replication and transparency.
The Defense Logistics Agency (DLA) Acquisition (J7) Directorate is tasked with the management, establishment, and oversight of overall procurement policy for DLA's approximately 5.2 million managed items (DLA mission, 2014). According to the DLA's website, "With nearly $35 billion in annual sales, DLA buys, stores and distributes food, fuel, uniform apparel, pharmaceutical, medical and surgical products and equipment and weapons system repair parts for the military services and other customers worldwide" (DLA mission, 2014, para. 3). The Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics (OUSD [AT&L]) Guide for Performance-Based Service Acquisition and the Seven Step Process (ACQ 265) (2009) describes the first article testing requirements for the DLA: "Production testing is planned, conducted, and monitored by the materiel developer. FAT includes preproduction and initial production testing conducted to ensure that the contractor can furnish a product that meets the established technical criteria" (p. 120).
In sum, first article testing and approval ensures that the contractor can furnish a product that conforms to all contract requirements for acceptance (First article testing and approval, 2014). Defense Logistics Agency (DLA) acquisition costs, however, are often excessive because First Article Testing (FAT) requirements are frequently misapplied to DLA contracts. This problem is investigated through a systematic review of the secondary peer-reviewed, scholarly, and governmental literature based on the research objectives and hypothesis outlined below.
The overarching objectives of this study were three-fold:
1. To determine the frequency of misapplication of First Article Testing requirements to Defense Logistics Agency contracts;
2. To determine Engineering Support Agency and Defense Logistics Agency employee interpretations of First Article Testing requirements; and
3. To provide Engineering Support and Defense Logistics Agency employees with First Article test requirement discriminators that will assist with appropriate First Article Test requirement application to Defense Logistics Agency contracts.
This study's hypothesis was that first article test requirements are not appropriately applied to Defense Logistics Agency contracts. The corresponding null hypothesis was that first article test requirements are appropriately applied to Defense Logistics Agency contracts. This study was also guided by the following research questions:
1. What major factors do engineers and Defense Logistics Agency employees consider prior to applying First Article Test requirements to contracts?
2. What specific discriminators can be applied to the First Article Test requirement decision-making process?
For the purposes of this study, it was assumed that the surveys completed by the respondents were truthful, that the secondary data reviewed was accurate, and that the findings emerging from the literature review were sufficient to confirm or refute the study's guiding hypothesis.
DoD: This acronym refers to the U.S. Department of Defense (DLA at a glance, 2014).
DLA: This acronym stands for "Defense Logistics Agency" (DLA at a glance, 2014).
DLAD: This acronym stands for "Defense Logistics Acquisition Directive" (DLA at a glance, 2014).
FAR: This acronym stands for "federal acquisition regulation" (Gourley, 2009).
FAT: This acronym stands for "first article testing" (Gourley, 2009).
First Article: This term includes preproduction models, initial production samples, test samples, first lots, pilot models, and pilot lots. Approval involves testing and evaluating the first article for conformance with specified contract requirements before or during the initial stage of production under a contract (Guide for performance-based acquisition, 2009).
This study was limited by the fact that, although the Department of Defense is mentioned frequently in the secondary literature, there remains a paucity of timely and relevant studies concerning first article testing requirements and their corresponding effects on the costs of DoD acquisitions. The findings that emerged from this study are delimited to DoD acquisitions.
Today, the Defense Logistics Agency (DLA) is the contracting agency responsible for the logistical supply of all basic supplies used by the U.S. military, ranging from "weapons to fuel, and everyday items such as silverware and sandbags" (Harnitchek, 2014, p. 11). Although relatively low-profile when compared to many other Department of Defense organizations, the DLA provides mission-critical logistics services to the nation's armed forces. As the agency's director, Vice Admiral Mark Harnitchek, reports: "As America's combat logistics support agency, the Defense Logistics Agency provides the Army, Navy, Air Force, Marine Corps, other federal agencies, and combined and allied forces with the full spectrum of logistics, acquisition and technical services" (2014, p. 11).
The DLA is currently responsible for procuring and redistributing virtually all of the items consumed by the country's armed forces, including materiel such as construction and barrier equipment, medical supplies, food, uniforms, fuel, and more than 85% of the spare parts required by the U.S. armed forces (Harnitchek, 2014). Beyond these responsibilities, the DLA also administers reused military equipment, provides document automation and production services, and maintains catalogs and other logistics information products (DLA at a glance, 2014). Although services are provided in 48 states, the agency is tasked with providing logistics support to the U.S. military wherever forces may be deployed, making the DLA a truly global organization (DLA at a glance, 2014).
Some salient facts concerning the DLA include the following:
No civilian company performs the same type of mission as the DLA, so direct comparisons are not possible. In fiscal year 2013, the DLA provided $39 billion in sales and revenue — a figure that would rank the agency in the top 15th percentile of the Fortune 500.
The DLA employs more than 25,500 civilian and military employees; supports roughly 2,400 weapon systems; manages nine supply chains and nearly 6 million items; and operates in 48 states and 28 countries. The DLA processes an average of 98,475 requisitions and more than 9,000 contract actions per day, and manages 25 distribution centers worldwide. Co-locating with warfighters puts supplies where they are most needed, improving military readiness and decreasing customer wait time and cost.
The DLA also leads DoD's efforts to supply the military services with alternative fuel and renewable energy solutions. In addition, the DLA supports humanitarian relief efforts at home and abroad, including the 2011 Japanese earthquake and Hurricanes Isaac and Sandy in 2012. For Hurricane Isaac, the DLA provided 2,138,000 meals and 1,853 gallons of diesel fuel to the Federal Emergency Management Agency. Sandy support included 6 million meals, 48 pallets of bottled water, 171,000 blankets, and more than 9 million gallons of fuel for first responders. Fiscal year 2013 Foreign Military Sales totaled $2.1 billion, supporting the security of 113 allied nations (DLA at a glance, 2014).
The primary level field activities for the DLA are as follows: DLA Land and Maritime (Columbus, Ohio) handles maritime and land weapons system supply chains; DLA Aviation (Richmond, Virginia) handles the aviation supply chain; DLA Troop Support (Philadelphia) handles subsistence, clothing and textiles, medical, and construction and equipment supply chains; DLA Energy (Fort Belvoir, Virginia) manages fuel, energy support and services, and bulk petroleum; DLA Distribution (New Cumberland, Pennsylvania) operates a worldwide network of 25 distribution depots and nine map support offices; DLA Disposition Services (Battle Creek, Michigan) oversees reutilization, transfer, demilitarization, and environmental disposal and reuse; DLA Strategic Materials (Fort Belvoir, Virginia) manages the strategic and critical raw material stockpile that supports national defense needs; DLA Logistics Information Services (Battle Creek, Michigan) manages a wide range of logistics information and identification systems; DLA Document Services (Mechanicsburg, Pennsylvania) provides automated document production, printing services, digital conversion, and document storage; and DLA Transaction Services (Wright-Patterson AFB, Ohio) handles editing and routing of logistics transactions, network interoperability, and eBusiness services.
Current DLA regional commands include DLA Europe & Africa (Kaiserslautern, Germany), the focal point for U.S. European Command's and U.S. Africa Command's theaters of operations; DLA Pacific (Camp Smith, Hawaii), the focal point for U.S. Pacific Command's theater of operations; and DLA Central (MacDill AFB, Florida), the focal point for U.S. Central Command's theater of operations.
Notwithstanding these broad-ranging responsibilities, the DLA's director recently advised that demand for the majority of the commodities that the agency acquires and redistributes to the U.S. military has diminished in recent months, corresponding to the drawdown of U.S. military forces from Afghanistan. According to Harnitchek, "The trend mirrors the reeling in of logistics supply chains in the wake of every major U.S. war. In terms of the history of the military, this is really no different than what you see at the end of every conflict" (2014, p. 11).
Although the significant downsizing of the DLA was not unusual following such a major drawdown in military forces, the trend has special implications for the agency's foreseeable future. As the DLA director emphasized: "We're going to be a lot smaller in terms of our people, our infrastructure, our inventory and our financial footprint. We have to be ready to significantly improve support at a whole lot less cost" (Harnitchek, 2014, p. 11). Prior to the terrorist attacks of September 11, 2001, the DLA provided between $18 billion and $20 billion worth of military supplies to the armed forces annually, with a peak in fiscal year 2011 when services totaled $46 billion. That total declined to $35 billion for fiscal year 2014, and the DLA has committed to identifying another $13 billion in reductions by fiscal year 2019 (Harnitchek, 2014). According to Harnitchek, "There is a big effort here to right-size our inventory and then right-size the infrastructure that supports all those distribution chains" (2014, p. 11).
The deputy undersecretary of defense for logistics, Roger W. Kallock, noted that the foregoing figures roughly equate to about $200 million per day for logistics support, with all resources invested in order to "buoy the passion of supporting the war-fighter with the right materiel at the right place, at the right time and at the right cost" (cited in Kutner, 2009, p. 53). As the deputy director of the Defense Logistics Agency, Navy Rear Admiral Raymond A. Archer III, emphasized, the U.S. Department of Defense may not have fully comprehended what is entailed in the acquisition and distribution of billions of dollars' worth of commodities and materiel on a global basis: "I think our focus in the logistics community today is supporting the warfighter. It was not that way five years ago. I can remember sitting in meetings where the goal was the [size of the] inventory... We were chasing the wrong goal" (cited in Kutner, 2009, p. 53).
Archer further noted the centrality of the logistics function in ensuring that warfighters have the commodities and materiel they need on the battlefield: "War-fighters are not enamored with logistics lingo. They just want to know where the stuff is. And I think that is all they need to worry about" (cited in Kutner, 2009, p. 53). Taken together, it is clear that the Defense Logistics Agency is an important part of the nation's defense network, and one of its primary evaluation mechanisms for the acquisition of commodities and materiel is first article testing.
First article testing (FAT) is used to determine whether products conform to required contractual specifications (Frame, 2002). For the Department of Defense, the FAT process likewise serves this purpose, but identifying first article testing requirements for the enormous array of commodities and materiel procured by the Defense Logistics Agency can be a challenging enterprise. At present, Subpart C of the relevant regulatory guidance contains the FAR and DLAD clauses and provisions that apply when first article test requirements are specified in the solicitation and a manual evaluation and award will be made.
The key clauses and provisions include the following: FAR 52.209-03 (Sep 1989) applies when first article approval is required and testing will be performed by the contractor; FAR 52.209-04 (Sep 1989) applies when first article approval is required and testing will be performed by the Government; DLAD 52.209-9016 (Mar 2009) applies when FAR 52.209-4 applies and the Government's testing cost will be used as a factor in evaluating offers; DLAD 52.209-9016, Alt I (Mar 2009) applies when FAR 52.209-3 applies and the Government's cost to review the contractor's First Article Test Report will be used as a factor in evaluating offers; DLAD 52.209-9017 (Nov 2013) applies when first article approval is required and testing will be performed by the contractor; DLAD 52.209-9017, Alt III (Sep 2008) similarly applies when testing is performed by the contractor; DLAD 52.209-9018 (Nov 2011) applies when first article approval is required and testing will be performed by the Government; DLAD 52.209-9018, Alt VI (Sep 2008) likewise applies when testing is performed by the Government; and DLAD 52.209-9020 (Sep 2008) applies when FAR 52.209-3 or 52.209-4 is applicable and it has been determined that the first article test and approval requirements will be waived for the awardee.
These clauses and provisions apply to solicitations that include a First Article Test requirement. Offerors are required to read and understand the full text of each clause, provision, or notice and provide any required information as applicable. These clauses and provisions are only applicable when a manual award is being made that includes a first article test requirement.
Under FAR Subpart 9.3 — First Article Testing and Approval, "approval" means the contracting officer's written notification to the contractor accepting the test results of the first article (9.301). First article testing and approval ensures that the contractor can furnish a product that conforms to all contract requirements for acceptance. Before requiring testing and approval, the contracting officer shall consider: (a) the impact on cost or time of delivery; (b) the risk to the Government of foregoing such testing; and (c) the availability of other, less costly methods of ensuring the desired quality (9.302).
Testing and approval may be appropriate when: (a) the contractor has not previously furnished the product to the Government; (b) the contractor previously furnished the product to the Government, but there have been subsequent changes in processes or specifications, production has been discontinued for an extended period of time, or the product acquired under a previous contract developed a problem during its life; (c) the product is described by a performance specification; or (d) it is essential to have an approved first article to serve as a manufacturing standard (9.303).
Normally, testing and approval is not required in contracts for: (a) research or development; (b) products requiring qualification before award (e.g., when an applicable qualified products list exists); (c) products normally sold in the commercial market; or (d) products covered by complete and detailed technical specifications, unless the requirements are so novel or exacting that it is questionable whether the products would meet the requirements without testing and approval (9.304).
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