NBSIR 77-1221

i>'

Proceedings of a Symposium:

Communicating for Product

Improvement October 13-14,

1976

Sponsored by:

Experimental Technology Incentives Program

National Bureau of Standards

Federal Supply Service

General Services Administration

National Association of State Purchasing Officials

National Institute of Governmental Purchasing

Final Report

February, 1977

Prepared by

Experimental Technology Incentives Program

U. S. DEPARTMENT OF COMMERCE

NATIONAL BUREAU OF STANDARDS
THE EXPERIMENTAL TECHNOLOGY INCENTIVES PROGRAM

Three premises underlie the Experimental Technology Incentives

Program (ETIP)

• Technological change is a significant contributor to

social and economic development in the United States.

• Federal, State, and local government policies can

influence the rate and direction of technological

change

.

• Current understanding of this influence and its impact

on social and economic factors is incomplete.

ETIP seeks to affect public policy and process to facilitate technological change in the private sector. The program does not pursue

technological change per se . Rather, its mission is being accomplished by examining and experimenting with government policies

and practices in order to identify and remove government-related

barriers and to correct inherent market imperfections that impede

the innovation process.

ETIP assists other government agencies in the design and conduct

of policy experiments. Key agency decisionmakers are intimately

involved in these experiments to ensure that the results are

incorporated in the policymaking process. ETIP provides its

agency partners with both analytical assistance and funding for

the experiments while it oversees the evaluation function.

Because all government activities potentially can influence the

rate and direction of technological' change, ETIP works with a wide variety of agencies, including those that have regulatory,

procurement, R&D, and capital subsidy responsibilities. Programs

are currently underway with the General Services Administration,

Food and Drug Administration, Veterans Administration, Federal

Power Commission, Environmental Protection Agency, Occupational

Safety and Health Administration, Small Business Administration,

and other federal agencies as well as various State and local

Agencies

.

The accompanying report was prepared by the ETIP program of the

National Bureau of Standards. Statements contained in this

document represent the views of the originating organization

and do not necessarily reflect those of the National Bureau of

S tandards

.

Director

Experimental Technology

Incentives Program

National Bureau of Standards

U.S. Department of Commerce
NBSIR 77-1221

PROCEEDINGS OF A SYMPOSIUM:

COMMUNICATING FOR PRODUCT

IMPROVEMENT OCTOBER 13-14,

1976

Sponsored by:

Experimental Technology Incentives Program

National Bureau of Standards

Federal Supply Service

General Services Administration

National Association of State Purchasing Officials

National Institute of Governmental Purchasing

Final Report

February, 1977

Prepared by

Experimental Technology Incentives Program

U.S. DEPARTMENT OF COMMERCE, Juanita M. Kreps. Secretary

Dr. Betsy Ancker-Johnson, Assistant Secretary for Science and Technology

NATIONAL BUREAU OF STANDARDS. Ernest Ambler. Acting Director

CONTENTS

Page

PLENARY SESSION

Robert S. Walleigh, Acting Deputy Director,

National Bureau of Standards 3

General Wallace H. Robinson, Jr., Commissioner,

Federal Supply Service, General Services

Administration 5

Daniel S. Wilson, Special Assistant to the

Administrator, Office of Federal Procurement

Policy, Office of Management and Budget 9

Charles Gularson, President, Professional

Associates of Organization Science 14

WORKSHOP TOPICS 21

WORKSHOP REPORTS 2 5

Product Improvement System 26

User Need and Industry Response 32

Procurement Incentives and Techniques 38

Role of Professional Organizations 41

PARTICIPANTS/ATTENDEES BY WORKSHOP 43

l
SYMPOSIUM OBJECTIVES

e To establish a continuing dialogue between private

industry and government agencies on the ways and

means of product improvement, placing particular

emphasis on methods of communicating specific

product needs to manufacturers and making purchasing

offices more responsive to these needs at the

Federal, State and local level.

11
PLENARY SESSION

COMMUNICATING FOR PRODUCT IMPROVEMENT

Sponsored by

Experimental Technology Incentives Program (ETIP)

National Bureau of Standards, U.S. Department of Commerce

Federal Supply Service (FSS)

General Services Administration

National Association of State Purchasing Officials (NASPO)

National Institute of Governmental Purchasing (NIGP)

*****

Robert S. Walleigh

Acting Deputy Director

National Bureau of Standards

It's a pleasure for me to welcome this group to the National

Bureau of Standards. NBS has joined with the Federal Supply

Service, The National Association of State Purchasing Officials and The National Institute of Governmental Purchasing

in sponsoring this, the fourth ETIP Procurement Symposium.

The NBS Experimental Technology Incentives Program (ETIP)

was established to develop and test governmental policies

that will provide incentives to the private sector of the

economy to invest in innovation and technological change.

In reality, what we are doing is attempting to stimulate a

more rapid transfer of technology from the laboratory to

the marketplace.

Our activities are carried out through four different program/

policy areas: procurement, regulatory, civilian research and

development, and economic assistance.

This Symposium is a product of the activities within the

Procurement Programs area of ETIP which is headed by your

Symposium Chairman, Joe Berko. And Joe, I must tell you

that I am very pleased to be able to welcome this group

because of my long interest in the field of procurement.

For 21 years I served as the Associate Director for Administration. In this capacity I managed the procurement of a wide variety of products for the Bureau.

As a result of that experience, I can attest to the validity

of your Symposium title: "Communicating for Product Improvement." It is my feeling that open communication between

government buyers and private sellers is the key factor in

3
any successful interaction. And with improved communications

should come improved products.

As you discuss possible resources for the development of the

communication system, let me mention several on-going NBS

activities that could be of use to you. Within our Center

for Consumer Product Technology we have an Energy Conservation Labeling Program, in cooperation with FEA, which is

intended to develop test methods for measuring performance

of appliances in terms of energy efficiency or the amount

of energy required to accomplish a specific function.

Also within the Center for Consumer Product Technology we

have a Law Enforcement Standards Laboratory which is developing equipment performance standards and procurement guidelines which are then adopted by the Department of Justice

to help local governments and police departments in making

cost-effective equipment procurement decisions.

We have a Standards Application and Analysis Division, within

the Institute for Applied Technology, whose goals include:

® To assist in maintaining uniform weights and measures

regulations and procedures throughout the U.S.;

@ To provide information on domestic and international

standards and to assist in the development of needed

voluntary product standards

® To assist laboratories .in developing criteria and

procedures for testing materials and products; and

® To develop a system for accrediting testing laboratories in the U.S.

Our Standards Information Service operates as a general

clearinghouse. During Fiscal Year 1975, we added 8,200

standards to our data base bringing the total to over

200,000 standards published by more than 500 domestic,

foreign and international standards organizations. We

share this information resource with scientists, government

agencies, representatives of industry and the public.

Many NBS activities are active, ongoing resources which

can be used in developing the communication system for

improved product performance. I do not want to take up

your time by detailing these various programs here. Instead,

r shall suggest that if you do want more material -- see

your Symposium Chairman, Joe Berke

This morning I have the double pleasure of both welcoming

you and introducing your first speaker. Wallace H. Robinson,

4
Jr., was appointed Commissioner of the Federal Supply Service

of the General Services Administration in February of 1976.

His organization is responsible for providing nearly $3 billion worth of goods and services annually to more than 40

Federal agencies.

A retired Marine Corps Lieutenant General, he spent five

years as Director of the Defense Supply Agency with responsibility for providing logistic support to military services

worldwide. During the 35 years General Robinson served in

the Marine Corps, he held many top level command and staff

positions, including assignments as Command General of the

worldwide inventory control point for the Marine Corps and

Quartermaster General of the Marine Corps.

May I present General Wallace H. Robinson.

General Wallace H. Robinson, Jr.

Commissioner

Federal Supply Service

General Services Administration

Thank you very much, Mr. Walleigh.

Ladies and gentlemen, I am very happy to be able to assist in

kicking off this meeting of the next two days and have the

opportunity to speak to all of you on the Federal Supply

Service role in the ETIP program. This is the third procurement symposium that the Federal Supply Service has co-sponsored

since our long association with ETIP. The first was held in

May of 1974 and it was quite successful. In January of 1975,

along with ETIP, NASPO and NIGP, we co-sponsored another

symposium. I would like to assure you that the recommendations

and ideas that come out of these meetings result in a great

deal of action in the Federal Supply Service. They have contributed to improving our mission accomplishment and, of

course, this is a basic objective of the Experimental Technology Incentives Program -- improvement.

ETIP means to discover appropriate government policies and

practices which could stimulate the development, application,

and transfer of science and technology to strengthen this

country's economy and improve the quality of life of our

citizens. In other words, it is a vehicle for testing government procurement in an attempt to stimulate product improvement

and for using government procurement to effect product improvement in the consumer area.

5
The success of this experiment depends on many things, but

certainly one of the most important is the theme of this

meeting today and tomorrow, the establishing of a continuing

dialogue between private industry and government agencies

on the ways and means of product improvement. In the next

two days you will actively participate through the workshops

in this exchange. I hope that from this experience you will

see why we in the Federal Supply Service view these symposiums

as not merely a twor-day-gathering , but as useful and valuable

tools for stimulating improvement and constructive change

for the longer term.

In the package that was handed out today, there is included

a document entitled "Report on the Federal Supply Service

Responses to ETIP Symposium Recommendations." A total of

fifty-three recommendations have come out of these symposiums

and are included in the report. Twenty-seven recommendations

in the procurement area, fifteen in standards and specifications,

nine in communications, and two in organization. Each of

the recommendations was carefully assessed by the Federal

Supply Service and while we did not totally agree with all

of the recommendations, we have implemented many of the recommendations and most of the recommendations we agree fully

with. And so, this morning I would like to report briefly

on some of the actions we have taken as illustrative of our

part in this program.

One recommendation was to adopt the use of life cycle costing.

We've made substantial progress in this regard in the Federal

Supply Service. Procurements pn a life cycle cost basis

have been made on air conditioners, water heaters, refrigeratorfreezers, gas and electric ranges, and high speed printer

ribbons. In the most recent award for refrigerator-freezers,

we estimate that the use of the life cycle costing technique

results in savings of nearly a half-million dollars and an

energy saving of nearly 25 percent over the fifteen year

product life. I personally believe that, in the long run,

the energy saving aspect of this program is more valuable

than the dollar saving.

Another part of our life cycle costing program is training.

We have developed a week-long training course in life cycle

costing techniques and this course is also available to state

and local government personnel as well as to Federal personnel.

In fiscal year 1976 we taught fourteen courses around the

country and for 1977 we have planned fourteen more courses.

The location of the courses is available to you.

We are very enthusiastic about life cycle costing. Not only

because it means the government is buying a better product

but also because industry is experiencing some valuable spinoff which is a direct objective of the program. In the case

6
of one company, for example, because of a life cycle procurement made on water heaters, that company was able to offer

for the first time in the United States an energy cost-efficient water heater they had long sold in Europe, where energy

costs have always been much higher. With examples like this,

and there are others, we plan to add more procurements under

life cycle concept to our list of successful application

of this procedure in the very near future.

Another recommendation from the report dealt with organization

Specifically, a recommendation was made to establish a market

research group within the Federal Supply Service. I think

it has been stated many times that the Federal Supply Service

and I am sure state and local government agencies, cannot

embark on a program of procurement of items unless these

items are desired and needed by the customer. And so, a market research group within the Federal Supply Service,

among its other duties, is commissioned to find new products,

new demands, from the federal agencies to which we can apply

the life cycle techniques and which we can include in our

ETIP program. The market research division is headed by

an Assistant Commissioner, Mr. Don Mitchell in the Federal

Supply Service, directly supervised by Mr. Peter Boulay.

The Division is divided into three branches, a Marketing

Branch, a Market Research Branch, and a Supply Catalog Branch.

I would invite anyone who is interested to contact these

individuals to see what they are finding out that the Federal

sector requires in the way of equipment and supplies to which

we can apply these concepts. This unit has been formed and

is working full time on market research, trying to find out

what Federal agencies need and how best we can provide these

items

.

A second significant change which came out of one of these

meetings was the creation of the Experimental Technology

Division in the Federal Supply Service. One of the most

important reponsibilities of this group of course is to manage

and coordinate all of the ETIP projects that are under way

in the Federal Supply Service or which are being planned

for the Federal Supply Service.

Another recommendation concerned using value incentive clauses

The Federal Supply Service now includes a value incentive

clause in all supply contracts over $100,000 in value which

involve some type of specification. The clause allows a contractor to share in procurement cost savings realized

through implementation of his value change proposal. In other

words, if a contractor comes up with an idea to provide you

with a product of equal quality that will perform the job

desired by changing some part of the specification by changing

some of the methods that he uses or in some other way then

7
he is permitted to share in whatever savings are achieved.

This clause even allows for savings if the cost of the item

goes up, provided the life cycle costs are reduced. One

of the approved value change proposals on household shipping

containers resulted in a savings of over $7 million in the

ten-year time frame computed.

Another recommendation was to make maximum possible use of

performance specifications. We are doing this at every opportunity. Our newest ETIP project on upholstered furniture,

for example, strives to develop performance-type specifications in an area which has been traditionally oriented towards

design specifications.

There also has been indicated in prior meetings a substantial

interest in the use of multiple awards. During the period

from July of 1974 to the end of December in 1975, fifteen

new multiple award schedules were added to the program covering

items such as storage cabinets, water purification equipment

and paint.

Regarding organization, again, there was a recommendation

to improve our laboratory testing facilities. In order to

improve utilization of equipment and facilities we have now

centralized much of our laboratory capability. For example,

paint testing is now done in New York, Fort Worth and Auburn,

Washington. Testing on hand tools is done exclusively in

Kansas City.

Another recommendation dealt with improving the effectiveness

of communications by using trade journals more frequently.

At the Federal Supply Service we have developed articles

which have appeared in many trade publications including

Chemical Marketing Reporter, Air Conditioning News, and Modern

Floor Covering.

While this Conference is on the subject of communications,

I think that numerous recommendations would be welcome relative

to how better we can publicize our efforts in life cycle

costing. Aside from the training class I referred to earlier,

we have made available case study documentations of actual

LCC procurement. I am sure many of you know what these look

like. But every life cycle cost ETIP project that we undertake

ends up with a case study and these case histories start

out with the background selection of the item, computations

relative to energy savings and so forth. These would be

excellent documents to use as a basis for understanding how

this program works in the Federal Supply Service.

We also had a recommendation to reorganize along a productgroup concept. And so the Federal Supply Service has responded

here also. We have now established what is known as National

8
Commodity Centers —in furniture, in automotive products,

and in tools. These centers bring together specification,

procurement and inventory management personnel under a common

manager and provide a concentrated focus for commodity management. We have an initiative underway to continue with this

concept and this plan will be announced within the next few

months

I could go on for the report, as I said, had many, many recommendations. I think that, however, we should begin the symposium and many of the efforts that the Federal Supply Service

has underway as a result of prior meetings will be made known

to you then. I hope that just as many recommendations come

out of this meeting. I would like to mention one other item.

That is the Product Improvement Intervention System, which

is known as PRIM. This is a system designed for the Federal

Supply Service for actively soliciting, evaluating, and implementing ideas for product improvement. Many of the concepts

which are scheduled to be discussed in the next two days

were developed for PRIM.

I again want to assure you that the Federal Supply Service

not only totally believes in the ETIP program but we are

completely devoted to attaining the objectives and to making

the ETIP program work and spread. I would hope that ETIP,

as a program, perhaps some day can be dissolved and the ETIP

concepts and procedures can become standard operating procedure. Our participation and involvement have produced both

measurable and un-measurable results, with many benefits.

I am sure that ETIP can be responsible for fostering a climate

that is conducive to creativity, innovation and constructive

change

I certainly hope you find this symposium rewarding and would

like to see you top the number of recommendations that come

out of this one over the previous ones. I thank you very

much for allowing me to come here to give you a brief report

on what has come out of these meetings in the past and also

for the Federal Supply Service and the General Services Administration to participate in the sponsoring of this program.

Daniel S. Wilson

Special Assistant to the Administrator

Office of Federal Procurement Policy

Office of Management and Budget

Good morning. Just to get a slight feel for the audience,

could you in industry raise your hands so that I can get

an idea of how many of you are here? Government? Other

non-government? Well, I too have a couple of challenges to

9
present to you before the end of my short address. You

know what a short address is? It's like a dress--long enough

to cover the vital points but short enough to stimulate inter - est! I hope I can stimulate your interest in the area of

acquisition of commercial products. I thank you for the

opportunity to make this presentation and also, on behalf of

Honorable Hugh E. Witt, the Administrator for Federal Procurement Policy, Office of Management and Budget.

Several months ago. May 24, 1976, to be exact, the Administrator for Federal Procurement Policy issued a policy on the

acquisition of commercial products. Coincident with the

policy he established an inter-agency steering group to

develop implementation procedures. Briefly, I'll quote the

policy and give you an idea of our thinking and of our plans:

"The Government will purchase commercial, off-theshelf products, when such products will adequately

serve the Government's requirements, provided such

products have an established commercial market

acceptability. The Government will utilize commercial distribution channels in supplying commercial products to the user."

This is a horrendous undertaking that is very complex, but

it's one that we should be optimistic about in accomplishing

a successful implementation. We should take this big step

because one is indicated. After all you can't cross a chasm

in two small jumps. So it's big! The interagency steering

group has been working since last June to find a way to

start this program. The group's labors are approaching

fruition

First of all we are selecting items that are in stock, that

have Government specifications, and have a sufficient volume to make it worthwhile to analyze. We are also working

on some guidelines to issue to the various agencies to promote coordinated analysis; i.e., the Department of Defense,

General Services Administration and the Veterans Administration. We expect to complete the work on the guidance and the

items within the next couple of weeks so that we can start

the planning and analysis phase of implementing the policy.

Just to give you an idea of what we are talking about as far

as guidance is concerned. To begin with, we have to be user

oriented. After all, if we didn't have a user we wouldn't

have a customer and we wouldn't be here. So, we want to be

as least disruptive to the user as possible. Hence, the user continues to work through his existing mechanisms until such

time as improvements are forthcoming. Also, contracting

oi f ices will continue to work with existing mechanisms —

10
with their procedures, regulations and statutes, and so forth,

until such time as we can direct innovative improvements.

Consistent with the theme of your symposium and workshops is

the idea of communication. We have to find the way to develop

realistic requirements from the standpoint of the user and

communicate those requirements to the manufacturing source.

This is a challenge! Whenever feasible, if we purchase, for

example, an item of equipment, we ought to include support by

the source. If we can get a source that will also furnish

the support, with a distribution system to do so including

maintenance support, then there is little need to stock that

item in the depot system. This is a thought which must be

communicated

.

The guidance document points out that centrally managed

supply systems will continue to function as they do today

but with increased management attention to the commercial

product acquisition policy. In this respect, warehouse

inventories will have to be examined by management for nondisruptive phaseout. In addition, large volume procurements

may require improved mechanisms for obtaining volume discounts.

In other words, we can still manage an item but not have that

item in the Government depot system since we will be using a commercial distribution source.

One of the key areas that we feel will grow of necessity is

marketing research in gathering data on products to include

quality, prices, producers, distribution channels and equitable formula for determining qualified products. Also, we

must improve the management of warranties. Too many times

a warranty has expired by the time it gets to the user

because it has been sitting on a shelf somewhere.

One of the other key areas on which guidance is being given

is specifications. Why key? We hear people say that "your

main objective is to eliminate Federal specifications."

That's hogwash! We're not attempting to eliminate Federal

specifications. We are striving to eliminate those unnecessary and/or overly stringent Federal specifications that are

preventing effective competition of commercial products.

Also, the elimination of the "hodge-podge" type specification

that takes a few characteristics from different types of products and merges them into a specification the likes of which

restrict competition because commercial sources marketing the item won't bid. We have to develop the way to ask for the item from industry in language that industry knows. So how

do we do that? This is something we will have to be examin- ing in considerable detail for it will require a closer inter- face among requirements developers, specif ication writers,

and the private sector.

11
As far as the policy is concerned, Government specifications

which unnecessarily fragment features of market accepted

commercial products and thereby create a commercial type item

are not acceptable. Therefore, we must determine simply, how

to ask for a commercial product without the embellishment

that makes it lose its commercial identity. Generally, we.

found in many cases, that a major part of a specification is

in the packaging of the item, primarily for stockage purposes.

We have received severe criticism from some circles regarding

the volumes of pages in Government specifications. For

example, the Lord's Prayer contains 56 words, Lincoln's

Gettysburg Address contains 256 words, and the Declaration

of Independence contains 3,000 words. Yet there is a Government regulation on the sale of cabbage that contains a total

of 26,911 words. I don't want to be overly critical of the

people who are working in the system, but we really don't

need a specification that is 21 pages long for a T-shirt that

we can buy commercially, or a 23-page specification for pencil sharpeners. Again, this is not to criticize the people

who are working on specifications because the system under

which we work has promoted the way we do things today. As

you know, we have a statute that says that the preferred

method of procurement is formal advertising and that statute

also promotes the fact that in order to formally advertise

you have to have a definitive specification and this increases

competition but it doesn't always. We can go on and on into

others but a quote by Mark Twain amply expresses our thinking

relative to our inflexibility -- "loyalty to petrified opinions

never yet broke a chain or freed a human soul in this world and

never will." This is true when you think about it. We must

become more progressive in finding that simple method in

describing a commercial item — in the language that industry

understands. In other words, let go of the old traditions.

Actually, the procurement process also has to be thoroughly

examined to develop more flexibility than we have currently,

in the procurement of a commercial product. Do we need

today's volume of paper work -- that big procurement package -- when, undoubtedly, there is a simpler way. This may

require a change in the statutes or changes to regulations

or procedures or even our thinking! We've got to think commercial if we want to buy commercial products through other

than the staid old Government practices. If this has to be

done appropriate action will be taken.

The ultimate goal of implementation will be reached through

extensive analyses and recommendations by the operations

people who are working in the functional groupings being

examined. Let me give you an idea of some of the items,

areas and functions referred to in the guidance document:

12
first of all, requirements forecast planning , very important,

this runs in line with your communications theme to the contracting sources; commercial distribution channels , we don't

know what these are at this particular stage for all the

items involved, we do know the various sources have different

types of distribution channels, some have a corporate channel,

some have independent distributors and wholesalers of which

there are thousands all over the country, and there are those

producers sans distributor outlets; how to obtain accurate

demand data for maximum fill; very important, marketing research , so we can search out the products that are essential

to the user need; the transition and draw down of inventories , at what point is it economical to do this, we have billions

of dollars in inventory which makes it impossible to turn off

a faucet and say forget about it, we're going on to the new;

what's the optimum procurement methodology that we can apply

to this big maze; and of course, specifications . Not to be

forgotten is the impact on blind and other severely handicapped-made products, prison-made products, labor surplus

area set asides, small business, and so forth.

We also have to determine the constraints that are opposing

the implementation of this policy. These constraints could

be a regulation, a policy, a procedure, could be anything.

We've got to examine these constraints so that we can either

make the change or effect the start of a change. Even something that's apparently simple but may not be so, how do we

pay for an item that we get through a commercial distribution

channel. Method of billing and payment becomes very important.

The procurement data that we have to create and get out of

this entire mass of information that has to be developed is

very important. These are just a few of the things that we

have to analyze. Wc shall carry on these analyses, perhaps,

for the next six months so that we can develop some patterns

that will aid in developing procedural changes that will

expand the implementation of the policy.

I had mentioned earlier that I had several challenges to the

Government and to the private sector.

Challenges to the Federal Government are: (1) to develop

the realistic requirements leaning toward commercial products

wherever appropriate; (2) eliminate the burdensome and obsolete Federal specifications and build a bank of descriptions

with an update system that makes it easy to buy commercial

products competitively; (3) simplify the procurement of commercial products, and (4) draw down the inventories of com- mercial products in favor of direct commercial distribution

and support to the user.

13
Some of the challenges to the commercial sector are: (1) con

tribute to the building and sustaining in the Government of

a current bank of commercial descriptions that promote buying commercial products competitively; (2) feed us ideas on

how to simplify the procurement process for commercial products, and (3) determine your potential for direct distribution and support, as appropriate, of the user requirements

for commercial products that are centrally managed and bought

in bulk.

What we are looking for is innovation and the modernization

of hide bound customs and traditions in the way we buy and

also in the way we distribute and support commercial products

Let me leave you with this thought best expressed by Stephen

Grellet -- a French born Quaker who died in New Jersey in

1855 --

"I shall pass through this world but once. Any good

that I can do, or any kindness that I can show as a human being, let me do it now and not defer it, for

I shall not pass this way again."

Let's substitute, as appropriate, the word " opportunity " -- the OFPP policy passes to us, the manager, the "opportunity"

to improve through creative and innovative approaches tKe

way we buy and supply commercial products. Let us not defer

this " opportunity , " for technology does not wait for us to

get the best from it. It might pass us byl Thank you.

PRoduct iMprovement Intervention System

(PRIM)

Charles Gularson

President

Professional Associates of Organization Science

Introduction

It is a privilege to be addressing this symposium. I think

I have one of the most challenging tasks today -- I have to

take these two 500 page GSA manuals which contain the operating instructions for the GSA Product Improvement Intervention

System (PRIM) , and present an overview of that system in the

next fifteen minutes. In the workshops today we will discuss

the PRIM System in greater detail and describe how the PRIM

System actually operates. However, my purpose here is to

give you a brief overview of the PRIM System and expose you

to the concept.

14
I don't think I've ever heard a good new product story, but

Johnny Carson happened to mention an article in the paper

last night. The article read like this: It was announced

that a manufacturer had come up with a great new product idea:

An all electric four door sedan for $700.00. However, the

clincher was the last line. It said, as an option, you could

purchase the plug and cord for $20,000.

One of the most challenging aspects in communicating product

improvement ideas is the identification of valid product

improvements and new product ideas. We are going to discuss

communicating product improvement ideas and needs through

the PRIM System. We purposely added the word needs because

there are two aspects to any kind of a product idea system.

You not only have to identify the ideas, but as it was mentioned by both General Robinson and Dan Wilson today, you

must also be able to identify the client's needs. Then you

need to match up your product improvement ideas with those

client needs to have a meaningful impact on the market.

During the next few minutes, I am going to discuss the evolution of the PRIM process, the basic objectives behind the

PRIM System, and the operational components of the System.

My emphasis will be on both product improvement ideas and the

identification of client needs using the PRIM System.

Evolution of the PRIM System

The evolution of the PRIM System was mentioned in several

previous speeches. The need for the system evolved from the

President's 1972 message on Science and Technology. That

message addressed the use of government procurement and purchasing power to improve technology and then transfer that

technology into the marketplace. This lead to the formation

of the Experimental Technology Incentives Program (ETIP)

within the National Bureau of Standards (NBS) . This group

was charged with supplementing the President's message.

ETIP has sponsored various experiments, including hot water

heaters, air conditioners, etc. It soon became apparent that

a logical process to systematically and continuously review

and screen product improvement ideas for potential ETIP experi

ments was needed. The Federal Supply Service (FSS) was select

ed as the lead agency to systematize the process of identifying product improvement ideas. Federal Supply Service then

contracted ORSA, Professional Association of Organization

Science (PASO) (of which I am the President) , the Gallup

organizations, and the Battelle Memorial Institute to design

a system to simulate technological transfer through the use

of government procurement methods.

15
Objectives of the PRIM System

The first task was to define the objectives of the System.

All the concepts in the world are meaningless unless the

operational elements are clearly defined. The main objective

of the PRIM System was to facilitate technological transfer.

But how do we handle new ideas? How do we put these ideas

into effect (an example being the hot water heater)? Exactly,

how do we transfer that technology out into the marketplace?

In other words, how do you best implement the new idea so as

to make it operational, ultimately getting it back into the

common marketplace? The system had to address this objective

during its design.

The second objective evolved during the conduct of the project.

The objective was to assist the FSS in expanding identification of needs in user agencies. For a product improvement

system to be meaningful and operational, some standard operating procedure must be developed to meet the objectives of the

host agency. Whether it be a state agency, a local school

board, or in the case of the design of this system, the Federal Supply Service. The main objective we had in mind was

not only the potential for technological transfer, but a system that would assist the Federal Supply Service in expanding identification of the needs of the user agencies. As procurement people you can appreciate how key this is. You have

to be exposed to the clients' needs and specifically identify

these needs within the agencies. Then, you match up the various product improvement ideas to meet those needs. If you

satisfy your user agencies, then you start to increase your

sales and you start becoming a more beneficial procurement

operation. Therefore, identification of the needs of FSS

user agencies became the key objective to meet in the design

of the system.

Operation of the PRIM System

One of the purposes of this seminar today is to discuss how

we can better communicate product improvement ideas to one

another. (Exhibit L summarizes the concept for improving

the communications of product improvement ideas) . In the

normal system, most of the communication of product improvement ideas and government needs occurs between the marketeer

from the industry and the procurement officer within the

government. The industry salesman approaches the government

procurement officer and says, "I have a brand new product

idea that I W£int to market to you, do you have a need for

it?" The procurement officer in return says, "these are my

agency needs. These are some of the needs that I have and

that have been communicated to me from other Federal agencies."

16
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17
Now, how does the marketeer get his product improvement ideas?

Usually these ideas are formed in the research and development department. The manufacturer then takes the idea into

the new product management department within the corporation.

There is new product research. The next evolution of the

idea in the corporation goes to product development. Then

the product concept goes to market research. From the market

research arm of a corporation it goes to the marketeer who

presents the idea to the government procurement officer.

This is the way the communication network operates.

One of the fundamental things we tried to do in PRIM is to

answer the question, "How can we expand and supplement the

communication of product improvement ideas?" As I said, I won't get into the details of PRIM until we get into the

workshops but I can give you an overview of the system with

regard to how we have expanded this communication process.

The current communication process will always continue and

must continue. PRIM does not interfere with the existing

communication channels. Rather, PRIM was designed to supplement it. What we have tried to do in communicating product

improvement ideas is to get industry and Federal Supply

Service people communicating more frequently and quickening

the pace of communication through PRIM. In this way R&D

departments can communicate directly into the PRIM System,

as can new product departments, marketeers, and the market

research department. Within the Federal Government, the

procurement officers can communicate directly with the Federal

agencies. Through this process, we can get key industry

new products people communicating directly to the Federal

user through PRIM.

Frankly, I've been quite simplistic in this discussion. The

size of the PRIM operating manuals indicates that it is a much more involved process than has been described here.

The main point we wanted to leave with you today is that

through the PRIM System, we are centralizing and systematizing the communication of product ideas while centralizing the

identification of user needs. The faster we get the right

people communicating, the faster the Federal Supply Service

can increase their sales and achieve one of their primary

objectives -- meeting user agency needs.

Results of the Field Test of Prim

Your next question might be: "Does It Work?" "Is it Operational?" In order to refine the concepts that Gallup,

Battelle and PAOS have developed, we conducted a field test

of the PRIM System using power hand tools. The first step

18
was to identify sources of new product ideas. These included

internal FSS sources, sources in other Federal agencies, and

various external sources. With the help of the Gallup organization, we designed a sampling technique including over 700

idea sources. We then sent letters requesting the sources

provide us with any ideas on power hand tools. In other

words we were actively, through the PRIM System, taking the

initiative to stimulate product improvement ideas. We were

not merely passively waiting for ideas to come in.

We expected to get about 30 ideas based on normal mail

sampling results of three to four percent. We finished the

field test with fifty healthy ideas from both government and

industry. For example, we received a need request from a man working on an assembly line in a large Fortune 500

company who stated that there was a need for a power hand

drill that could do a specific function because there is

nothing available on the market. Another idea had to do with

a need for a special drill to facilitate working on various

government construction sites. We had ideas for specific

tools drawn on the back of the survey form, complete with

sketches of not only what was needed, but how the suggestor

thought it should be put together. So, when I say fifty

ideas I'm not talking about a superficial return of forms.

I'm talking about real, hard returns and with good ideas.

The PRIM System does more than merely solicit ideas and

needs. It also screens and evaluates these ideas to identify

those with the best potential. All of the ideas we received

went through a screening process designed by Battelle and

PAOS . Three were identified as being potential candidates

for ETIP experiments.

As in any screening process, you can only go so far with a mechanistic system. To be effective you must get into the

management decision-making aspect. As you know, procurement

is a very complex area. It takes detailed knowledge not only

in procurement but in marketing and specification; the various major elements involved in the Assistant Commissioner's

level of Federal Supply Service. Through the process of

management review two ideas were selected for development into

ETIP procurement projects.

I can't relate at this time what those final ideas were,

but I can tell you that they are fascinating. One of the

most recent ideas solicited by PRIM is going through the

screening process right now. It is a power hand drill that

has a cone shaped nozzle to be slipped over the drill bit.

The cone is made of a collapsible clear plastic. When you

drill into some material, this nozzle catches all the droppings, be they wood or metal. Hence, the work area is

19
cleaner and safer. Just a little collapsible cone on the

front of the drill. Those are the type of ideas we are

getting in. We haven't put this idea entirely through the

system as yet to see the pragmatics of being able to market

that particular idea, but our initial review has been very

favorable

Several other by-products came out of the field test. We

spoke with several industry people and they've become

excited enough about PRIM that they are contemplating shifting the field testing of several new product lines from

Europe to the United States. These multi-national companies

initially wanted to go to Europe because they felt the

European governments are a bit more cooperative in the

field testing of new products. We said no, that's not the

way it is any more. The United States Government is taking

a lead in field testing. Would you be interested in conducting your field test here? They said, "Wow, that's

really great, but we need a few more facts before we can

commit ourselves. We do want to sit down and talk."

I wanted to take the time to go through this illustration

of some field test results to show you PRIM's capabilities.

The system is not completed yet. We are still field testing

and we are still refining. And, there are still problems

that we have to overcome. However, the results of the field

tests are highly encouraging.

Summary

In summary, we discussed how the PRIM System evolved from

the President's message of 1972. We discussed how the PRIM

System was spurred by ETIP and how it was developed in conjunction with FSS to meet the dual objectives of technological transfer and expanding the identification of FSS user

agency needs. We can get an idea into the Federal Supply

Service that has all the potential of transferring technology

but if the Federal Supply Service doesn't buy it, the idea is

in the wrong agency. The first thing we did was to try to

meet the objectives of the Federal Supply Service. If we can

also transfer technology, all the better. We've met the

objective of the study. In summary, the PRIM system is

evolving to be a basic link between the user product needs

of the various agencies and the industry product development

capabilities. This is PRIM, it is an alternative that is

being presented to you today to expose you to what is being

done at the Federal level. Through your comments over the

next two days, the Federal Supply Service will be able to

refine this sytem and improve its operation. Another byproduct of this symposium would be to help the state and local

agencies learn about the PRIM System so that it can be put

into effect at the state level.

20
WORKSHOP TOPICS

The cycle of new product development begins with an idea.

For that idea to have practical value, it must be translated

into product specifications. And before that product can be

developed, it must first be deemed marketable.

This, then, is the process three of the Symposium workshops

examined. flow can Federal, State and local government agencies

work in conjunction with industry to (1) stimulate new product

ideas; (2) evaluate those ideas; and (3) provide a market for

the resultant new product? The fourth Workshop looked at the

the complementary role of the professional or trade association

in this same process.

The Workshops were designed as forums for free and open discussion. Since chairpersons and co-chairpersons were drawn

from Federal, State and local government, as well as from

industry, it was hoped that a broad spectrum of opinions would

be represented in each group. At the conclusion of the Symposium, the chairperson of each Workshop prepared the reports

which begin on page 25 , reflecting the conclusions and

recommendations voiced by participants for presentation to

the Symposium as a whole. Following are the Workshop objectives

as set forth in the Symposium brochure.

Workshop 1: Product Improvement System . The government purchasing officer is often the focus of communication from both

user agencies demanding new or improved products and manufacturers attempting to sell product innovations.

This Workshop will examine the ways in which the purchasing

office serves as a conduit between governmental customers and

private industry. It will also suggest means of enlarging

this role to stimulate new product development. For example,

the program will demonstrate ways of identifying actual users

of specific products and obtaining product quality feedback

from these users. It will look at trade shows, association

seminars and industry exhibitions as a means of keeping

abreast of changes in the marketplace. And, it will examine

the barriers encountered by contractors who solicit new product ideas from the governmental customers.

Participants will be encouraged to take a broad look at the

methods of soliciting innovative product ideas to determine:

• What product categories are the best candidates for

improvement

.

• What is the feasibility of inviting product suggestions

from general consumers as well as governmental users; and

21
« What, if any, screening process should be used to evaluate

ideas?

Workshop 2: User Need and Industry Response . Once a product

need has been identified, it is necessary to draw some parameters around it to enable industry to make an appropriate

response. The task will be the focus of this Workshop.

Specifically, the program will follow an innovation from

need perception through finished product. The process involves

two basic steps.

First, the need must be translated into a statement of product

requirements. This would include the level of performance

the product would be expected to attain, safety and efficacy

tests it would be required to meet, the probable scope of

the product's use and its estimated procurement volume.

Secondly, there must be a means of evaluating industry response to these requirements. Since industry proposals may

involve products in three distinct phases of marketing --

(1) items currently available on the commercial market;

(2) items in advanced stages of development or pre-market

testing; (3) engineering proposals or plans to develop new

items -- testing and evaluation procedures appropriate for

each condition will be examined separately in the Workshop.

Some topics for consideration would include:

® The adequacy of available test methods to measure improvement in the product.

• Cost and time necessary for objective testing vs. subjective testing.

® Criteria for evaluating test methods.

« Composition of tost panels.

© When, where and how of field testing, prototype testing.

Special consideration will be given to organizing for effective

performance, particularly at the state and local levels where

the procurement process is highly fragmented. Current and

potential capability of existing organizations will be considered along with alternative methods.

Workshop 3: Procurement Incentives and Techniques . An essential element in the product improvement process is the use of

procurement incentives by government purchasing offices to

stimulate suppliers to offer new products. The traditional

22
method of awarding supply contracts on the basis of low price

bids tends to discourage product innovation, while procurement incentives such as life cycle costing, performance

specifications and value incentive provisions can reward

suppliers for product improvement.

This Workshop will first deal with a comprehensive review of

existing incentive techniques and then develop a framework

for the selection and use of the different incentives.

Included in this discussion will be a brief review of the

incentives used thus far in ETIP sponsored projects and

supplier reaction to these incentives.

Workshop 4: Role of Professional Organizations . There is

increasing evidence that trade associations, professional

associations, regulatory and licensing groups and public

interest groups play an important role in the innovation

process at the Federal, State and local levels of government.

One area of increasing importance is the role of these associations and groups in the procurement process, including the

identification of product needs, research and development,

commercialization of an innovation and the problems of getting

a new product onto the market.

This Workshop will examine the part professional organizations

play:

• In the development of purchase specifications.

• As a conduit between industrial R&D and the governmental

marketplace

• As a participant in the design, development and use of new

procurement incentives for the process.

23
'
WORKSHOP REPORTS

1. PRODUCT IMPROVEMENT SYSTEM

Co-chairpersons: Peter C. Boulay

Director, Market Research and

Marketing Division

Federal Supply Service

General Services Administration

Charles II. Gularson

President, Professional Associates

of Organization Science

2. USER NEED AND INDUSTRY RESPONSE

Co-chairpersons: Allan Beres

Value Management Division

Federal Supply Service

General Services Administration

Charles Travis

Consultant, Experimental Technology

Incentives Program

National Bureau of Standards

3. PROCUREMENT INCENTIVES AND TECHNIQUES

Co-chairpersons: Einar Windingland

Procurement Policy Division

Federal Supply Service

General Services Administration

Keith Wardell

Professional Associates of

Organization Science

4. THE ROLE OF PROFESSIONAL ORGANIZATIONS

Co-chairporsons: J. David Roessner

Division of Policy Research and

Analysis

National Science Foundation

Fred S . Knight

Assistant Director, Management

Development Center

International City Management

Association

25
.

'
Workshop 1

PRODUCT IMPROVEMENT SYSTEM

The goal of the Product Improvement System Workshop, as set

by the symposium designers, was to suggest methods by which

government procurement officers and representatives of

industry can work together in improving products. Among the

specific problems cited in the symposium agenda were: how

does the government purchasing officer bridge the gap between

government end users and industry? How can this role be

expanded, particularly in regard to product line improvement?

How does government obtain product improvement ideas from end

users and how does it evaluate such ideas? What process can

be used to assure proper handling of new/improved product

ideas and to stimulate industry to produce to fill the government need?

Inasmuch as the Product Improvement System Workshop chairpersons were the designers of a system—the Product Improvement Intervention System, PRIM-- for accomplishing these

purposes, the Workshop centered its discussion on PRIM. Participants included, besides the chairpersons, 13 representatives

of industry or consulting firms, two representatives of state

or local governments, and seven representatives of the federal

government

Overview of the PRIM System

The PRIM system was summarized in this manner:

The two objectives of the PRIM system are: (1) to provide

new and improved products to the FSS $3 billion annual market

represented by government agencies buying centrally; and

(2) to encourage growth and the economic vigor of the private

sector firms that offer these products to Federal Supply.

The PRIM System is based on innovation theory, diffusion theory

of new ideas, concepts and products, and technology-transfer

theory. The system assumes that incentives can be provided

across a wide range of product development activities involving innovation, diffusion, and technology-transfer. It also

assumes that these incentives can be tailored to assist and

encourage private sector firms to emphsize these areas.

Four subsystems comprise the PRIM System: (1) the Suggestion

Subsystem; (2) the Procurement Techniques Subsystem; (3) the

Implementation Subsystem; and (4) the Assessment Subsystem.

The Suggestion Subsystem is designed to elicit ideas for needed

now products and product improvements from a variety of sources.

These suggestions are solicited in areas determined by Federal

Supply management. Methods of soliciting ideas include distri27
bution of product idea kits , sponsorship of product improvement

and procurement technique seminars , and surveying customers

and potential customers. A series of screening criteria are

used to narrow the suggestions to those most likely to prove

successful

.

The Procurement Techniques Subsystem is intended to provide

proven procurement techniques for spurring innovation, new

technology, technology transfer, new product development,

and product improvements. The subsystem also provides for

developing new procurement techniques, or combinations of

techniques. Some will serve particular product or commodity

areas while others may serve particular types of present or

prospective suppliers (e.g., small or minority businesses).

This subsystem matches procurement technique as an incentive

to the particular product or commodity area selected for

further development.

The Implementation Subsystem visualizes using the Federal

Supply Service's buying power, marketing, communications

and distribution system in experiments to help participating

private sector firms test the demand for their new or

improved products. This would be done by running experiments

to test the demand for the product concept and delivery and

its acceptability for use by Federal Supply's customer

agencies

.

The Assessment Subsystem provides for current-information

feedback and evaluation of the success of the marketing

experiment. Experiments, generally, run for one year.

During this period, quarterly progress reports would be

provided. A final evaluation report would be prepared at

the conclusion of the experiment.

Discussion of the PRIM System

Participants in the Workshop generally discussed key points

without direct reference to the PRIM system. That is, while

we were aware'' of PRIM's existence, and of its general composition, we felt it was beneficial to arrive independently at

answers to two of PRIM's general concerns: what criteria

should be used in selecting products and product categories

for intense product improvement efforts, and what criteria

should be used in screening product improvement ideas submitted by government employees, industry or consumers

generally?

Criteria for Selecting Product Categories

On the former question, participants agreed the key criteria

for selecting product categories would include:

28
1. Environmental concerns. Selection of products whose

technological improvements can fulfill national environmental priorities.

2. National energy goals which can be partially met by

product improvement.

3. Improvement of safety features.

4. Potential for utilizing shifting trends in raw material

sources, where such shifts represent potential energy or

dollar savings, or better utilization of natural resources.

5. Management goals, such as better service, economy or

efficiency, which can be met by improved products.

6. Product efficiency, maintainability and design.

It was recognized that the above list represented no specific

order of priority, but that these criteria were among those

that would have to be considered important to anyone concerned

with product improvement.

Participants were aware that the PRIM list of product selection criteria went far beyond these major statements, in

providing an exhaustive list of criteria. It was noted that

the PRIM criteria were exhaustive in order to meet any contingency, but that many of these criteria would not be

applicable in each attempt to select products for improvement.

Criteria for Screening Suggestions

Once ideas have been solicited, it is necessary to screen them.

Two important considerations were discussed. First, of

course, it is necessary to screen product improvement ideas

systematically in order to select those that offer the best

potential for meeting the criteria for a particular set of

expo r i men ts . In addition, it was pointed out that screening

can produce' a desirable side-effect, namely, the systematic

rejection of ideas with lower potential in such a manner

that suggestors feel that their ideas were carefully considered

and are inclined to participate in future calls for suggestions.

In order to screen ideas, the Workshop participants felt it

was important to group suggestions into product or commodity

categories and assemble qualified persons from product areas

to consider them. Product ideas should be judged in terms

of their operational effectiveness, cost effectiveness and

user need. Once past these hurdles, the product idea must

be for a realistic, producible product.

29
Other considerations include the product idea's relevance to

one or more agencies, the need that can be demonstrated for

such a product, and legal and safety requirements.

Recommendations

Having established these general criteria for product selection and screening, the Workshop offered two major recommenda

tions in its concluding session:

1. That there be established in Federal Supply Service a separate entity with the precise purpose of: (a) stimulating new/improved product suggestions; (b) screening

ideas; and (c) recommending new/improved product procurement experiments. Such an entity should identify

and communicate with other technological and product

improvement centers in the government. It should be

fully supported, both in human and economic resources

and should have top management support.

It was felt that a three-year pilot test of such an

office would provide adequate evaluation data. While

Workshop participants did not favor mention of the

PRIM System as the sole possibility for such an entity,

it was clear that PRIM was an existing system fully capable of fulfilling the intent of this recommendation.

At the time of the Workshop, PRIM had been completely

designed, but not yet implemented.

2. That there be established as a result of the Symposium

an implementation committee to evaluate each of the

recommendations made in the final session by all the

workshops. Such a committee should be composed of three

representatives from industry or consulting firms and

two representatives from government. The basis for this

recommendation was the strong feeling that former

Symposium recommendations had been monitored in a somewhat haphazard manner. In particular, agencies responsible for implementation of recommendations had been

permitted to offer hazy general statements regarding

their progress and this tended to obscure the implementation status. It was recommended that the implementation

committee be responsible for:

a. periodic review of all recommendations made at the

1976 Symposium.

b. assignment of responsibility to specific agencies or

individuals for implementation of all recommendations

30
c. an evaluation of progress made and a formal report to

the 1977 Symposium which critiques each responsible

agency for its progress to date.

At the concluding session, the Symposium chairman, Mr. Joseph

Berke, appointed Mr. Peter C. Boulay to establish and lead

the implementation committee. However, in later private discussion Mr. Boulay indicated the intent of the Workshop was

to provide an external source of evaluation and that his work

in the design of the PRIM system ought to be a basis for

eliminating him. Mr. Berke therefore agreed to appoint

another person to set up and chair the implementation committee .

31
Workshop 2

USER NEED AND INDUSTRY RESPONSE

Workshop Objective

Once a product need has been identified, it is necessary to

draw some parameters around it to enable industry to make an

appropriate response. Specifically, this workshop was to

examine the communications required between user and industry

from the time of a user's perception of an innovation requirement through to the procurement of the finished product.

Scope

With the time constraint of the workshop, the scope was

limited to the development of a framework to insure complete

understanding between all parties: users, purchasing officers

and manufacturers. Accurate and timely communications are

essential to the success of the development and acquisition

of product innovations.

Thus, the workshop did not delve into many of the technical

aspects of the product innovation process, such as test

methods, evaluation criteria, field testing, etc.

Assumptions

Before developing ideas and recommendations it was necessary

to make some basic assumptions. There was a workshop consensus on three assumptions:

1. There is a need for product improvements;

2. User needs can be determined; and

3. Product improvements can be obtained from industry.

Recommended Framework for Communications

As a basis for an organized discussion, the focus was placed

on the development of a framework for communications to

result in product improvements. A series of action areas

or sequential steps were identified as necessary to insure

meaningful communications

Step 1. Determine User Needs for Product Improvement

In order to determine these needs, the user must be informed

that the governmental purchasing office is actively seeking

his ideas for improved products to be used in accomplishing

his job.

The following are some of the conditions on which users will

express a desire for product improvement.

32
1. A need for a higher quality and reliability than

that of the products to which he has been exposed.

2. A need for a higher quality and reliability than

contained in any product in the market place.

3. A need for a functional characteristic that is not

available in products to which he has been exposed.

4. A need for a functional characteristic that is not

available in any product in the market place.

5. A need for an item to reliably perform a function

at a lower cost (item price and oprating costs)

than existing products.

Each of these and other possible conditions could require a different series of steps to be taken in the total communications process. For example, the need for an item to perform a new function could involve the evaluation of technical drawings and the acquisition and testing of prototypes.

Step 2. Describe User Needs in Terms of Function and

Performance

The users' initial description of a need may be expressed

generically, such as, a portable battery powered saw. This

type of general description may be sufficient to initiate a query to industry to determine their interest. However, the

more complete the description in terms of the required basic

function, desired performance level and operating environment,

the greater is the opportunity for an initial favorable

response from industry.

The responsible public purchasing officials, including the

specifications personnel, would be able to phrase the user

requirements in functional terms and to ascertain the significant characteristics of his operating environment. Further

clarification of the user needs would take place in Step 3.

Step 3. Communications Between Industry and Buyer

The manner in which this step is carried out will determine

the success of the entire process. Naturally, there has always

been some communication between industry and governmental

purchasers in the procurement process. However, to achieve

product improvement that satisfied both the functional and

cost parameters of the user, great emphasis must be placed on

roundtable type discussions among all the parties that could

contribute, through brainstorming techniques, to the objective.

In addition to manufacturers who are potential bidders and

the governmental purchaser, user and technical expert, other

attendees should include representatives of the appropriate

33
trade associations and professional groups, and a member of

an interested university laboratory and research facility.

The objective of bringing together this talent is to clarify

the user's functional and performance needs and then to

establish a milestone plan to be followed in reaching the

actual purchasing plateau.

Manufacturing representatives have stated that the best way

to get new or improved products is to ask for them. This

step is designed to indicate a genuine interest from all

parties to participate in this effort. Manufacturers would

welcome some basic market information from the government,

such as, estimates of the potential demand, number of customers

and interest of other governmental purchasing entities. The

absence of such estimates should not be a deterrent to submitting new requirements to industry, since manufacturers will

attempt to assess the potential commercial market for the

proposed product improvement.

Step 4. Develop Product Evaluation and Contract Award

Criteria

This action area is perhaps the most difficult and yet the

most critical in terms of the procurement mechanism ensuring

that product improvements are evaluated in such a way that

the government will make the "best buy." The evaluation criteria is an essential topic for the roundtable discussion of

Step 3. It is felt that the knowledge and experience of

industry, professional groups and university researchers

could contribute to the development of the criteria that

would ultimately determine the successful bidder.

There are innumerable techniques and variations that could

be applied. Where applicable, use should be made of industry,

e.g., ASTM, and other acceptable test methods. In many cases

new evaluation techniques would have to be developed in order

to insure that the government would receive the functional

and performance characteristics it needs.

Procurement techniques such as life cycle costing, which allow

the government to evaluate costs other than bid price, should

be considered in the evaluation criteria.

Similarly, it is important to determine the existing capability

to conduct the required tests or evaluations. The development

of such a capability and by whom must be considered.

It is important that industry be exposed to such criteria as

early in the acquisition process as possible.

34
Step 5. Accomplish the Procurement

With the preceding progressive communications among the

parties, and with the results progressively disseminated,

the final awarding of the contract can be accomplished.

From the open communications would come a refined statement

of requirements to be used in the invitation for bids. The

statement of requirements would contain, in explicit terms,

the item's required function(s), the performance levels,

the testing and evaluation techniques to be applied, any

cost factors to be used, and the award criteria or formula.

The method of procurement and the procurement techniques

employed will vary depending on the industry, the type of

product required, and the results of the roundtable discussions. The important point is that through the progressive

communications, everyone is aware of the ultimate procurement objective and the rationale behind the development of

the final procurement document.

Step 6. Post Contract Award Product Performance Evaluation

The objective of this communications framework is to obtain

product improvements and innovations. As such, it is necessary to formalize, as an integral part of the process, the

methods and techniques to be used to insure that the product

received continues to perform its functions as required in

the contract.

The emphasis of this approach is cooperation between all the

interested parties. Since all parties have a stake in the

success of the procurement of the product improvement, they

also are vitally involved in the end user's experience in

the use of the product. Tracking of the product's operation

can be used to provide incentive or penalty clauses under the

contract, but more importantly, to refine the future statement of requirements for a better procurement.

Stop 7. Publicize Results of Product Improvement

To achieve greater interest and to spur similar efforts, the

progressive results and the final accomplishment of the procurement should be given wide publicity through trade, professional and purchasing publications. The greater the

awareness of such efforts, the greater is the likelihood

of similar attempts in new product areas or by different

purchasing entities. In addition, it will focus interest

on the improved product, both for the government user and

the potential consumers in the commercial market.

35
Recommended Aggregation of State/Local Capabilities

It was recognized at the outset that there is no single,

central point at the state and local level of procurement

through which user needs or industry proposals can flow. It

is unlikely and perhaps undesirable that such a point be

established. However, it was generally agreed that the capability to define requirements, develop evaluation criteria,

conduct the evaluation and perform other functions involved

in the initial procurement will vary extensively among these

purchasing entities. Therefore, it was proposed that a cooperative aggregation of capabilities among these entities,

on a regional or similar basis, would significantly improve

the performance of these functions in an effective and timely

manner

.

It was felt that a centralized or regionalized effort in the

development and expression of needs would offer advantages

for the states and localities as well as providing manufacturers the prospects for a large market for the improved product. However, it was not felt that a new organization would

be required to perform this function. The communications

framework would be developed and used within or among existing

organizations such as NASPO, NIGP, Urban Consortium, etc.

Recommended Approach

It is recommended that this framework for communications be

developed as ETIP experiments for the Federal purchasing

sector and for the state and local purchasing sectors, utilizing the regional or central approach of the preceding recommendation . Products which already have been recommended for improvement through the PRIM system or by organizations such as

NASPO, NIGP or PTI should be screened and selected for these

experiments. Consideration should be given to items which

have a high potential demand commercially and in the government, and which are of interest to Federal, state and local

purchasing entities.

The experiments should proceed through the steps outlined in

the report, with the development of milestone plans and

the assignment of tasks among industry and government participants . General Comments

Multi-year contracts and follow-on contracts were discussed

briefly. The position is that one year and shorter contract

periods are a hurdle to product innovation. The obvious

36
reason is the risk industry must assume in investing in both

research and development and initial production capability.

Since this subject had been covered at previous symposia, it

was not explored any further.

37
Workshop 3

PROCUREMENT INCENTIVES AND TECHNIQUES

Purpose

The Procurement Incentives and Techniques Workshop considered

the use of procurement incentives by government purchasing

offices to stimulate suppliers to offer new products and

product improvements.

To establish a dialogue between government and industry on

the use of procurement incentives and techniques. To develop

recommendations on the use of incentives and techniques for

procurements on the Federal, state, and local levels.

Discussions

Discussion began with the meaning of procurement incentives.

Most participants felt that profit is the basic idea behind

most incentives. However, incentives can take many forms

such as prestige, increased capability, and to test the

market

A presentation of procurement incentives used and related

experience within the Federal Supply Service was made by

representatives from that agency. An explanation was made

of current efforts to improve the use performance specifications in the procurement of furniture. Under the present

procurement practices specifications are used in combination

with a photograph and awarding to the low bidder. Effective

performance specifications can provide a greater control over

the quality of the product. A review was made of some of the

lessons learned by FSS in the use of life cycle costing in the

procurement of water heaters, ranges and refrigerators.

To show how products and incentives can be systematically

matched, Mr. Keith Wardell of the Professional Associates of

Organization .Science presented the Master Matrix, which was

developed for the Federal Supply Service Product Improvement

Intervention System (PRIM) . The Master Matrix is designed to

relate product characteristics to certain types of incentives.

A discussion of the Master Matrix and its use in the PRIM

System followed. It was explained that the basis of the PR]M System relies on the use of incentives to helo industry

Goals

can enable the Marketing Division to become aoduct line. It

one stop source

PRIM

38
of information on the nature of agency needs. Through the

Potential Users File, the Purchasing Patterns and Market

Potential File, and the PRIM System, market information can

be supplied to industry to help them sell to the Federal

government. This information thus becomes an incentive to

industry

.

Recommendations

The final session was spent discussing specific recommendations for the use of incentives in government procurement.

The group felt that one incentive for industry to deal with

the government and bring new products to the government would

be to eliminate some of the existing disincentives as well as

introduce new incentives. The following nine recommendations

developed in the workshop reflect this approach.

1. The concept of PRIM as related to procurement incentives

and techniques is endorsed, but it is recommended that

the PRIM approach be expanded to include an overall rating

feature as to the quality, benefits to the government,

and acceptability of the improved product.

2. It is recommended that the PRIM approach to achieving

product improvement be fully correlated with existing

FSS approaches used to include new and improved products

in its supply system.

3. The Federal Supply System of contracting could further

incentivize contractors to participate if existing commercial practices (such as selling on FOB origin basis

and making payment under normal commercial practices)

were adopted by the government. It is recommended that

this be studied by FSS.

4 . As an additional approach for providing incentives in

government contracting, it is recommended that the existing disincentives (e.g., complex contract documentation,

temporary price reduction provisions, etc.) be reduced

or eliminated. If this cannot be done for all products,

make special accommodations for new and improved products.

5. To provide further incentives to contractors, it is recommended that the government exercise discretion in its

testing and retesting practices of identical products

that were previously furnished and tested under previous

contracts (or in previous deliveries) which are not always

considered necessary and are objectionable because of the

resulting delays in shipment, additional costs, and

delays in payment. Expansion of the quality assurance

system should be considered and used, where feasible.

39
6. It is recommended that the government publicize its

system of conducting market research to enhance communication with industry. Organization charts and names of

persons that can be contacted in follow-up considerations

should be made readily available to contractors.

7. A feasibility study is recommended to determine the better

of the two reporting systems (e.g., the General Services

Administration and Defense Supply Agency) used in reporting sales made to the Government. Would it be possible

to include Federal Stock Numbers in Federal Supply

Schedules and thereby allow the reporting system to be

more exact as to sales per item/versus sales per group of

items?

9. Due to inflationary factors and changing market conditions,

it is recommended that Federal Supply Service review its

maximum order limitations and minimum order limitations

now used in multiple award Federal Supply Schedules to

reflect industry practices in addition to government

considerations

10. It is recommended that consideration be given to amending

the Scope of Contract clause used in Federal Supply

Schedule contracts and eliminate the exceptions some

agencies now have to required use of the schedules.

40
Workshop 4

THE ROLE OF PROFESSIONAL ORGANIZATIONS

I. The activities which intermediary organizations can play

in Communicating for Product Improvement:

a. identify, evaluate, and disseminate information about

best practices.

b. develop standards for products with emphasis upon

performance rather than structural or design con-"

siderations to reduce barriers which standardization

can impose.

c. serve on design committees which can advise Federal

agencies on programs and product specifications.

d. serve as media for communicating new product information to their members via newsletters, journals,

articles and annual meetings.

e. legitimize and reduce risk taking on the part of the

Association members through certification, recognition and accreditation procedures.

f. evaluate the efficacy of new products and communicate

findings to Association members.

g. serve as a source of "professional" input to decisionmakers when subjective and value-laden judgments are

germane to a public decision.

h. assist members in gaining access to and information

about Federal programs and product needs

II. Basic issues involved in the roles played by intermediary

organizations in the innovation process, but not resolved

in our Workshop.

a. How can the intermediary organization maintain credibility with its members, and independence from its

funding sources?

b. How can the Federal agencies identify the most appropriate intermediary organization for any given problem?

c. Given the tendency for large organizations to be conservative, how can intermediary organizations be

encouraged to undertake more risk taking with respect

to new products?

41
III. Recommendations

a. The Federal Government should provide increased

support for sending agency personnel to training

programs run by professional associations, and to

annual meetings of professional groups and trade

associations

b. Professional and trade associations should actively

encourage Government participation in their training

programs and meetings by identifying and conducting

appropriate Federal officials, and by setting aside

blocks of time in their annual programs for Federalmembership interactions

c. These intermediary organizations should play a larger role in developing industry standards.

Federal support of such activity is a possible

strategy, provided that appropriate safeguards

for preserving the independence of the association

and the sponsoring Federal agency.

d. The Federal agency should provide the means for

their personnel to be active in these kinds of

industry standard setting groups, especially via

representation in technical groups.

e. The complexity and varied nature of intermediary

organizations and their role requires that a separate symposium be organized which functions

on the dynamics of 'intermediary associationgovernment interaction. This symposium will require

careful planning which accounts for differences in

the goals and resources of the different intermediary

organizations and the different need of Federal

agencies

42
PRODUCT IMPROVEMENT SYSTEM

* Charles H. Gularson

President, Professional Assn.

of Organization Science

1211 Conn. Ave . , N.W.

Washington, DC 20036

(202) 223-3405

Norman C. Anderson

U.S. Forest Service

Dept, of Agriculture

3905 Vista Avenue

Boise, ID 83705

(208) 384-9807

Edward V. Blanchard

Research Triangle Inst.

Raleigh, N 27703

(919) 549-8311

*Peter C. Boulay

Director, Market Research

and Marketing Div. (FFM)

FSS , GSA

Washington, DC 20406

(703) 557-8530

Stanley B. Durkee

Office of Noise

Abatement, EPA

Arlington, VA 20460

(703) 557-8292

Edward W. Erne

Bureau of Standards of

Pennsylvania

2221 Forster Street

Harrisburg, PA 17025

(717) 787-3860

Otis E. Finley

District Manager

Eastman Kodak Co.

500 12th St. , S .W.

Washington, DC 20024

(202) 554-9300

James D. Gibson

Castle Company

Priest Bridge Bus. Pk

2125 Baldwin Ave.

Crofton, MD 21114

(301) 261-6314

* Co -chairper son

Philip T. Haines

Office of ACMD for Extended

Care

Veterans Administration

Washington, DC 20420

(202) 389-3854

Marc Henderson

Stanford Research Institute

Menlo Park, CA 94025

(415) 326-6200

James L. M. King

Washington Executive Group

1725 K Street, N.W.

Washington, DC 20006

(202) 452-5400

Robert C. Lesino

Business Service Center

General Services Administration

Washington, DC 20406

(202) 472-1804

A. S. Libman

Experimental Technology

Incentives Program

National Bureau of Standards

Washington, DC 20234

(301) 921-3465

Beryl A. Lanterman

Bendix Corporation

1400 Taylor Ave.

Baltimore, MD

(301) 825-5200

43
Donald A. Loren

Central Purchasing Div.

Prince George's County

Upper Marlboro, MD 20780

(301) 952-3774

Robert J. Martell

Union Carbide Corp.

300 First Ave

Needham Heights, MA 02194

(617) 444-5400

James McNallen

Market Research and

Marketing Division

FSS , GSA

Washington, DC 20406

(703) 557-8530

L. R. Merhaut

Government Sales Manager

Power Tool Division

Rockwell International

131 Park St. , N.W.

Vienna, VA 22180

(703) 281-4388

John L. Pye

Continental Copper & Steel

12 Commerce Drive

Cranford, NJ 07016

(201) 272-3850

Diane Ross

Business Service Center

General Services Admin.

Washington, DC 20407

(202) 472-1804

Frieda O. Stukes

Social Security Admin.

Baltimore, MD 21235

(301) 594-0283
USER NEED AND INDUSTRY RESPONSE

*Allan Beres

Value Management Div.

FSS , GSA

Washington, DC 20406

(703) 557-1583

Thomas M. Bostick

Asst. State Purchasing

Officer

300 Gervais St.

Columbia, SC 29202

(803) 758-2531

Paul Braun

Chief, Market Research

FSS, GSA

Washington, DC 20406

(703) 557-0661

Leslie Breden

Center for Fire Research

Natl. Bureau of Standards

Washington, DC 20234

(301) 921-2342

Thomas A. Camp

Director, Hard Lines

Product Engineering

Sears, Roebuck & Co.

925 S. Homan Ave

.

Chicago, IL 60607

(312) 265-4074

John M. Campbell

Canadian Dept, of Supply

and Services

Canadian Embassy

2450 Mass. Ave., NW

Washington, DC 20008

(202) 483-5505

Roxanne S. Chatman

School of Packaging

Michigan State Univ.

East Lansing, MI 48824

(517) 355-9580

* Co -chairperson

James R. Cosby

Environment and Process

Instrument Division

Bendix Corporation

1400 Taylor Ave.

Towson, MD 21204

(301) 825-5200

Walter V. Cropper

Director of Dev. Operations

American Society for

Testing and Materials

1916 Race St.

Philadelphia, PA 19103

(215) 299-5476

Charles W. Devereux

Standards Development

Services Section

Natl. Bureau of Standards

Washington, DC 20234

(301) 921-2356

Larry Frost

Marketing Branch

FSS, GSA

Washington, DC 20406

(703) 557-8520

Stephen Garrity

Experimental Technology

Incentives Program

Natl. Bureau of Standards

Washington, DC 20234

(301) 921-3171

Denny G. Hale

Karastan Rug Mills

Eden , NC

(919) 623-2141

II. D. Ilarback

Electric Machinery and

Instruments Branch

FSS, GSA

Washington, DC 20406

(703) 557-7575

45
Jay Harms

General Product Manager

A. 0. Smith Corp.

P. 0. Box 28

Kankakee IL 60901

(815) 933-8241

Claude J. Hartridge

Professional Associates

of Organization Science

1211 Conn. Ave . , N.W.

Suite 212

Washington, DC 20036

(202) 223-3405

Sue Mclver

Marketing Branch

FSS , GSA

Washington, DC 20406

(703) 557-8520

Egils Milbergs

Stanford Research Inst.

333 Ravenswood Ave.

Menlo Park, CA 94025

(415) 326-6200

*Charles Travis

Consultant - ETIP

4617 Randolph Drive

Annandale, VA

(703) 354-8848

Robert L. Ulrich

National Automotive Center

FSS, GSA

Washington, DC 20406

(703) 557-5390

Stanley I. Warshaw

Director, Center for Consumer

Product Technology

Natl. Bureau of Standards

Washington, DC 20234

(301) 921-3751

Terry D. West

National Furniture Center

FEH , GSA

Washington, DC 20406

(703) 557-3245

John A. Mizicko

Marketing Center

Veterans Administration

P.0. Box 76

Hines, IL 60141

(312) 343-2818

Michael J. O'Connor

National Institute of

Governmental Purchasing

1001 Conn. Ave., N.W.

Washington, DC 20036

(202) 331-1357

Bruce Steinthal

Public Technology Inc.

1140 Conn. Ave., NW

Washington, DC 20036

(202) 452-7837 *Co-chairperson

46
PROCUREMENT INCENTIVES AND TECHNIQUES

William F. Baxter

S.C.M. Corp.

500 E St. , S. W.

Washington, DC 20024

(202) 554-0400

George W. Grimsley

Karastan Rug Mills

1009 Tanley Rd.

Silver Spring, MD 20904

(301) 622-0727

Thomas S. Bednar

White Consolidated Ind.

910 17th St. , N.W.

Washington, DC 20006

(202) 296-4296

Dorothea Gross

Stanford Research Institute

1611 N. Kent Street

Arlington, VA 22209

(703) 524-2053

Philip H. Brown

Systems and Assignments

Division, FSS, GSA

Washington, DC 20406

(703) 557-0283

Wallace G. Hill

Manufactor's Wholesale Co.

7700 Leesburg Pike

Suite 406

Falls Church, VA 22043

(703) 821-6680

Gordon A. Cauley

Supply Division

National Bureau of

Standards

Washington, DC 20234

(301) 921-2525

Robert M. Cornett

Charles Hulick

Procurement Program

Experimental Tech. Incentives

Program, NBS

Washington, DC 20234

(301) 921-3171

Natl. Assn, of State

Purchasing Officials

P.O. Box 11910

Lexington, KY 40511

(606) 252-2291

Henry A. Kyhos

Eastman Kodak Company

343 State Street

Rochester, NY 14650

(716) 724-4501

Pierre L. Deponai

Social Security Admin.

P.O. Box 7696

Baltimore, MD 21043

(301) 594-4859

Philip S. McMullan, Jr.

Research Triangle Institute

P.O. Box 12194

Research Triangle Park, NC 27709

(919) 549-8311

Robert Fitzgerald

Policies and Procedures

Branch, Office of

Procurement, GSA/FSS

Washington, DC 20406

(703) 557-7644

Mary Ellen Mogee

Congressional Research Service

Library of Congress

Washington, DC 20550

(202) 426-6030

Howard J. Gobstein

441 G St. , N.W.

General Accounting Office

Washington, DC 20548

(202) 275-2591

Carroll Oldham

Organization Resources Systems

and Advisors, Inc.

1211 Conn. Ave . , N.W.

Washington, DC 20036

(202) 452-1446

47
Bert Rosen

Mister Cubicle Co., Inc.

234 46th St.

Brooklyn, NY 11220

(212) 439-8303

J. A. Sawdye

Union Carbide Corp.

270 Park Ave

.

New York, NY 10017

(212) 551-4126

Louis D. Sorrentino

Vice President - Corporate

Marketing Services

Johns-Manville

1600 Wilson Blvd.

Arlington, VA 22209

(703)524-9250

William D. Thomas

Market Research and

Marketing Division

FSS , GSA

Washington, DC 20406

(703) 557-1615

*Keith Wardell

Professional Assn, of

Organization Science

1211 Conn. Ave., N.W.

Washington, DC 20036

(202) 223-3405

Ivan L. Weinstock

Government Product News

614 Superior Ave. West

Cleveland, OH 44113

(216) 696-0300

Ann T. Whitcomb

Natl. Furniture Ctr.

FSS, GSA

Washington, DC 20406

(703) 557-0990

* Co -chairperson

*Einar Windingland

Procurement Policy Division

FSS, GSA

Washington, DC 20406

(703) 557-8344

48
THE ROLE OF PROFESSIONAL ORGANIZATIONS

*Fred S . Knight

Asst. Dir., Mgmt . Development

Center

Internatl . City Mgmt. Assn.

1140 Conn. Ave . , N.W.

Washington, DC 20036

(202) 293-2200

Robert M. Schwaner

Natl. Furniture Center

FSS , GSA

Washington, DC 20406

(703) 557-3895

John C. Adams

Office of Design

Dept, of Industry, Trade

and Commerce

Ottawa, Ontario CANADA

(613) 992-4494

Sanford L. Bordman

Director, Center for

Tech. Assessment

New Jersey Institute of

Technology

323 High Street

Newark, NJ 07102

(201) 645-5273

Stephen B. Gordon

Natl. Inst, of Governmental Purchasing

1001 Conn. Ave., N.W.

Washington, DC 20036

(202) 331-1357

Lois Green

Market Research and

Marketing Division

FSS, GSA

Washington, DC 20406

(703) 557-8530

Jack Hoffman

Washington Exec. Group

1725 K St . , N.W.

Washington, DC 20006

(202) 452-9100

Bryan Karr

Manufactors Wholesale Co.

7700 Leesburg Pike

Suite 406

Falls Church, VA 22043

(703) 821-6680

Fred

Martin Siegel

Director, Special Projects

Capital Systems Group, Inc.

6110 Executive Blvd.

Suite 250

Rockville, MD 20850

(301) 881-9080

*J. David Roessner

Div. of Policy Research and

Analyses

National Science Foundation

Washington, DC 20550

(202) 632-4091

Donald Vitz

Public Technology, Inc.

1140 Conn. Ave., N.W.

Washington, DC 20036

(202) 452-7740

* Co -chairpersons

49

(5-114A (REV. 7-73)

U.S. DEPT. OF COMM.

BIBLIOGRAPHIC DATA

SHEET

1. PUBLICATION OR REPORT NO.

NBS I R 77-1221

2. Ciov’t Accession

No.

3. Recipient’s Accession No.

TITLE AND SUBTITLE

Proceedings of a Symposium:

Communicating for

Product Improvement

October 13-14, 1976

5. Publication Date February, 1977

6. Performing Organization Code

AUTIIOR(S)Charles Hulick - Editor

.

8. Performing Organ. Report No.

PERFORMING ORGANIZATION NAME AND ADDRESS

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, D.C. 20234

10. Project/! ask/Work Unit No.

11. ( -ontract/Grant No.

|l. Sponsoring Organ i/. nr ion Name and C omplete Address (Street, City, State, ZIP)

<perimental Tech. Incentives Program, NBS , DC 20234

bderal Supply Service, Gen. Services, Admin, DC 20406

atl. Assn, of State Pur. Officials, Lexington, KY 405

atl^ Inst. of Govt. Pur.. 1001 Conn . . nr

13. Type of Report & Period

Covered

Final

•£4|. Sponsoring Agency C ode

5. SUPPLEMENTARY NOTES

6. ABSTRACT (A 200-word or less factual summary of most significant information. If document includes a significant

bibliography or literature survey, mention it here.)

The general objective of the conference was to establish a

continuing dialogue between private industry and government

agencies on the ways and means of product improvement,

placing particular emphasis on methods of communicating

specific product needs to manufacturers and making purchasing

offices more responsive to these needs at the Federal, State

and local level. Workshops were organized to consider

Product Improvement System, User Need and Industry Response,

Procurement Incentives and Techniques, and The Role of

Professional Organizations. Reports and recommendations

of these Workshops are included.

7. KEY WORDS (six to twelve entries ; alphabetical order; capitalize only the first letter of the first key word unless a proper name; separated by semicolons

)

procurement incentives; product improvement system; product innovatio

user need

19. SECURITY CLASS 21. NO. OF PAGES

(THIS REPORT)

^9 UNCLASSIFIED

Office 20. SECURITY CLASS 22. Price

(THIS PAGE)

(NITS)

UNCLASSIFIED

$4.00

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' 1' or Ollici.il Distribution. Do Not Release to NT1S

| | Order I rum Sup. ol Doc., IJ.S. Oovcmment Drill Washington, D.C . 20402, SD ( at. No. < 1 3

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