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imposed by other specifications and publications and incorporate them by reference. Commission studies traced through the first three levels of references in the specification for one product, the light bulb. The results are shown in table 4.
TABLE 4. SPECIFICATIONS REFERENCED IN
W-L-00101G, LIGHT BULBS
Number referenced Type
18t level 2nd level 3rd level Federal Specifications
24 Federal Standards Military Specifications
9 Military Standards
28 Military Handbooks Other
86 215 Source: Same as table 1.
In the table, the reference documents on the first level are listed directly in Federal Specification W-L-00101G. The second-level documents are those listed in first-level Federal specifications and standards only. The "other" first-level document is American National Standard C78 Electric Lamps, which may be purchased for $82.60. The Federal specifications and standards would cost the supplier $47.65. The military documents are free if ordered directly from the depot. No attempt was made to price the other documents. It required more than three weeks for the Commission to find and obtain the first- and secondlevel Federal specification documents. From this experience it appears that complete identification of all documents referenced in most specifications is virtually impossible.
Of the 313 documents concerning light bulbs (table 4) that the Commission could find, most pertain to packaging, packing, and marking. On the average, a supplier generally must ask three offices for specification-type documents in order to be able to bid responsively. It is extremely difficult and very costly to maintain a current set of reference documents since many of the specifications also cite industry standards. Firms doing business with the Government regularly have complained of this problem. New companies, and those who bid on Government work infrequently, are not familiar with these requirements and therefore may be at a disadvantage.
In addition to the cited problems: • Purchase of items under a Federal specific cation when comparable commercial products are available usually results in greater cost to the Government. • Use of Federal specifications that prescribe specific designs may deny the Government the benefit of technological progress because the high cost of testing alternate designs discourages industry. • Overly strict interpretation of specifications for commercial products forces producers out of Government work, thus reducing competition. • Since specifications establish a minimum quality level, the offering of a better quality is not encouraged.
Federal specifications have certain advantages. They advance the public interest by providing a basis for standardization, for establishing quality levels, and for competitive procurement.
Obviously, real savings through the use of specifications and standardization only occur if the resulting product meets the level of performance required by the user. Central procurement offices contend that specifications establish "optimum quality levels." This can also be defined as the minimum quality required for the average user or the minimum level that meets the needs of most users. Specifications and standards inherently involve some averaging or grading of user requirements in order to prevent proliferation of grades and types of products. They may require a regular producer to make special production runs solely to satisfy some detail of the specification. When applied to commercial items, specifications tend to become broad rather than specific. This leads to specifications that do not always recognize the specific need of the user.
If specifications are obsolete, many commercial products do not meet their requirements. This in effect limits competition, defeats the intent of the Government, and deprives it of the advantages of the technologically dynamic open market.
In attempting to satisfy the needs of the average user through standardization, a single
quality line is provided. Unfortunately, user needs do not average out. Some users have lower quality requirements than provided in the standard; others have stiffer quality requirements. The result is that all users with needs below the average are brought up to it, and those with needs above the average fill their requirements by exception.
The Federal supply catalog system very often lists products that have commercially available counterparts. Many of these counterparts meet or exceed Government specifications, but some do not. Usually the needs of civilian agencies can be met by available commercial products, whereas the needs of military agencies often cannot.
The military use millions of commercial items that are bought through use of agencyprepared purchase descriptions. The need for specifications and standards is not necessarily due to lack of commercially available products that will meet the Government's needs. Primarily, specifications and standards are used to provide a standard way of describing, cataloging, and qualifying products for purchase, stock, and issue.
Industry believes the Government should normally buy commercial products rather than items made to Federal specifications. Manufacturers state that Government contracts and specifications are not only unnecessarily complex but prevent users from buying satisfactory commercial products generally available in their area. Others state that reliance on Federal specifications results in a more expensive and slower method of procuring items that may be less cost-effective than their commercial counterparts.
Benefits to the Government in improved pricing, greater competition, and possibly better quality through the use of Federal specifications should be evaluated against costs and alternatives. Development and use costs should include costs of Government and industry coordination, additional inspection requirements, and updating of the specifications. Benefits should be evaluated on the basis of net savings through formal advertising and central procurement.
The elimination of duplication and obsolescence is the responsibility of the operating agencies that develop the specifications, but responsibility for policy and coordination of the overall standards and specifications program should be assigned to a central point of authority. The following actions could greatly reduce some of the problems:
• Development of Government standardization documents should be justified on the basis of all costs involved in their development, promulgation, maintenance, and use in relation to the benefits obtained. • All standardization documents should be reviewed at fixed periods. • Commercial product specifications, when used, should exclude packaging, packing, and marking requirements. All packaging, packing, and marking requirements should be reviewed for economy and efficiency in accordance with current commercial practices. • Packaging requirements for military items should be completely separated from all other standardization activities.
The Government standardization effort is a responsibility of several agencies. No single agency has total responsibility, and the degree of coordination among agencies is poor. Many specifications have become too complex for the need and inhibit or exclude the use of commercial products.
To fulfill a user's need, commercial products must be of the required quality. The steps taken to assure quality always cost something and very often add enormously to the cost of procurement. Although quality assurance measures are sometimes inadequate, frequently they are overly elabcrate and unnecessarily expensive. To serve the user best and to minimize the total unit cost of procurement, both extremes must be avoided.
* For example, see the Associated Equipment Distributors position report, Appendix B.
Commercial Quality Programs
Most Government contracts for commercial products provide for inspection of the products before they are accepted by the Government. Some commercial items may be simple enough to permit inspection and acceptance on delivery, but for more complex equipment and products there often is a need for an in-plant inspection or quality assurance program. The type of product, requisite product reliability, size of purchase, statutory requirement, or availability of qualified personnel are factors considered in selecting the method used to assure delivery of quality products. In most cases the selection is based on more than one of these factors.
The competitive forces in the market for commercial products compel a manufacturer to maintain a program of quality assurance. Economy and efficiency dictate that the Government, in buying commercial products, usually should rely on these quality programs; however, the Government may be justified in making its own in-plant inspection in cases where the contractor makes a production run solely for the Government and may permit a lower product quality than his commercial standard.
When contract specifications require special production runs, conformity, including interpretation of specifications, must be established and determined for each run; hence, the extent of in-plant inspection for commercial products is affected by the size of the purchase and the degree to which the products vary from standard production items.
Other exceptions to reliance on manufacturers' quality assurance programs occur when special products, statutory requirements, or the public health and safety are involved.
ture, and the Food and Drug Administration. All of these agencies can offer quality control services within their capabilities to other agencies.
GSA and DSA have an extensive quality control program to support the Government procurement function. GSA's Quality Control Division has operating offices in each of the ten GSA regions. Contractor quality control in DSA is operated through DSA's 11 Defense Contract Administration Services Regions (DCASR),10 whose primary objective is to provide quality control and field contract administration for Federal agencies.
GSA and DSA each provides a range of inspection and quality assurance programs, depending on the terms of the contracts and the products involved. Use of these inspection programs by civilian agencies is optional. Where plant cognizance is assigned to a military department, inspection services are also available to other DOD and civilian activities.
The Veterans Administration performs quality control inspections on medical items for which it is responsible, and the Department of Agriculture and the Food and Drug Administration operate extensive inspection programs in support of public health and safety. Other Government agencies also have quality control programs to protect the health and safety of Government personnel. For example, the Defense Personnel Support Center (DPSC) has a medical laboratory to develop safe drug specifications and programs for testing their quality.
What is lacking in the executive branch is an integrated program to disseminate information on the quality control programs of the individual agencies and a policy to maximize the use of the existing services by all Government procurement organizations."
Government Quality Programs
In attempting to satisfy the needs of users, the Government must assure through some
Several Federal agencies have programs to assure delivery of quality products and services procured by the Government. Foremost among these agencies are the General Services Administration, Defense Supply Agency, Veterans Administration, Department of Agricul
General Services Administration, Quality Control Operations. paper presented to Study Group 13A, Sept. 17, 1971.
10 Defense Supply Agency, An Introduction to DSA, Jan. 1971, p. 85.
11 See further discussion, Part A, Chapter 10.
kind of inspection procedure that products meet quality requirements. Good business practice dictates that, in buying commercial products, the Government should not impose inspection requirements beyond those normally needed to assure quality in the commercial marketplace.
Government inspection units have been criticized because they sometimes accept shoddy products, duplicate effort, and perform different types of inspection for similar products.
The Government has not coordinated its quality assurance programs required by contract with its various inspection functions required by law or regulation, nor has it promoted the full use of existing quality capability in lieu of each procurement organization performing its own inspection. The system within DOD and the informal arrangements between some agency procurement organizations provide a framework for achieving this objective, as recommended in Part A, Chapter 10.