Overview
FAR 46.202 establishes a four-tiered hierarchy of contract quality requirements tailored to the complexity, risk, and value of the acquisition. It defines the extent to which the Government relies on a contractor’s internal quality systems versus imposing specific Government-mandated inspection standards.
Key Rules
- Commercial Items: For commercial products and services, the Government relies on the contractor’s existing quality assurance systems. Government in-process inspections are only permitted if they align with customary market practices.
- Simplified Acquisition Threshold (SAT): For acquisitions at or below the SAT, the Government generally relies on the contractor’s internal testing and inspection. However, the Contracting Officer (CO) may require Government testing if justified by the nature of the product, potential risk of loss, or cost-effectiveness.
- Standard Inspection Requirements: Under standard clauses, contractors must maintain an inspection system acceptable to the Government, allow Government in-process inspections, and maintain detailed inspection records available for Government review.
- Higher-Level Quality Standards: For complex or critical items, agencies require compliance with specific high-level standards (e.g., ISO 9001, AS9100, or ASME NQA-1). These are used when technical requirements necessitate strict control over design, work operations, and documentation.
- Risk-Based Determination: The level of quality requirement is determined by assessing the likelihood and impact of nonconformance, the complexity of the item, and the adequacy of the contractor's internal processes.
Practical Implications
- Contractors performing below the SAT or providing commercial items have primary responsibility for quality assurance, but they must still maintain records to prove conformance upon delivery.
- Firms seeking contracts for critical technologies or complex hardware must be prepared to obtain and maintain expensive third-party certifications (like ISO 9001 or AS9100) to meet "higher-level" contract requirements.