a

GAO

United States Government Accountability Office

Report to the Senate and House 

Subcommittees on Defense, 

Committees on Appropriations

December 2004 DEFENSE 

INVENTORY

DOD and Prime 

Contractors Adhered 

to Requirements in 

Selected Contracts 

for Overseeing Spare 

Parts Quality

GAO-05-73
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-73.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact William M. Solis 

at (202) 512-8365 or solisw@gao.gov. 

Highlights of GAO-05-73, a report to the 

Senate and House Subcommittees on 

Defense, Committees on Appropriations 

December 2004

DEFENSE INVENTORY

DOD and Prime Contractors Adhered to 

Requirements in Selected Contracts for 

Overseeing Spare Parts Quality 

GAO’s review of the 15 contracts showed that quality assurance personnel 

within the Defense Contract Management Agency (DCMA)—DOD’s primary 

organization for providing quality assurance oversight—generally followed 

established policies, guidance, regulations, and contract requirements in 

performing oversight and enforcement over spare parts prime contractors. 

This oversight ranged from conducting physical inspection of parts, such as 

testing the measurements and functions of a part to evaluating contractor 

production processes to observing the outer appearance and counting the 

number of parts for compliance with contract requirements. When one of the 

prime contractor’s processes and another contractor’s parts did not meet 

contract requirements, DCMA used its enforcement system by issuing 

requests for corrective action by the prime contractors. 

GAO found that the 11 prime contractors reviewed provided quality 

assurance oversight over their subcontractors’ work in accordance with 

industry standards and contract requirements. The contractors used at least 

two and up to four methods in providing quality assurance oversight over 

their subcontractors. These methods included evaluating potential 

subcontractors for placement on an Approved Supplier List, requiring 

certifications of parts and processes, testing parts and processes, and 

tracking and monitoring subcontractor’s performance. The primary methods 

of oversight were evaluating subcontractors for placement on an Approved 

Supplier List and requiring certifications that parts and processes conform to 

contractual specifications. Establishing an Approved Supplier List served to 

identify subcontractors capable of producing needed parts or processes in 

accordance with industry standards and contractual specifications. 

In GAO’s review of the 15 contracts, DCMA held prime contractors 

accountable for their subcontractors’ work by requiring that the prime 

contractors adhere to contract clauses concerning oversight responsibility. 

Most of the contracts included either clauses stating that the prime 

contractor shall provide supplies that conform to contract requirements or 

clauses related to other quality requirements. When nonconformance was 

reported, DCMA quality assurance personnel and the prime contractor 

determined if the deficiency was due to contractor nonconformance and 

assigned responsibility for corrective action. GAO identified one deficiency 

from the 15 contracts that the prime contractor was responsible for and 

DCMA held the prime contractor accountable for the part. 

While GAO did not identify any major deficiencies from the contracts and 

practices it reviewed, GAO recognizes that the risk of nonconforming spare 

parts reaching end users exists. Compliance by contractors, DCMA, and 

other DOD agencies with established internal controls helps mitigate against 

this risk. 

In the 2004 Defense Appropriations 

Act, Congress mandated that 

GAO examine and report on the 

oversight of prime contractors by 

the Department of Defense (DOD) 

and the oversight of subcontractors 

by the prime contractors. Contract 

quality assurance oversight is 

intended to assess whether 

contractors are capable of and are 

providing supplies or services that 

meet contract quality and technical 

requirements. Providing effective 

oversight is challenging. DCMA 

recognizes that the risk of 

nonconforming parts reaching end 

users exists, given the diversity of 

contracts, parts, and products used 

to meet weapon systems 

requirements and uses a risk 

management process to guide its 

efforts. For fiscal year 2003, 

government quality assurance 

oversight was required for 

approximately 273,000 contracts. 

GAO determined (1) whether 

DOD provided quality assurance 

oversight and enforcement over its 

spare parts prime contractors, (2) if

prime contractors provided quality 

assurance oversight over their 

subcontractors, and (3) how DOD 

held prime contractors accountable 

for overseeing the subcontractors’ 

work. To address these objectives, 

GAO judgmentally selected and 

reviewed 15 contracts awarded to 

11 prime contractors by the 

services and the Defense Logistics 

Agency. 

In commenting on a draft of this 

report, DOD provided one 

technical comment, which GAO 

incorporated as appropriate. 
Page i GAO-05-73 Defense Inventory 

Letter 1

Results in Brief 4 

Background 6 

DCMA Provided Quality Assurance Oversight and Enforcement 

over Contractors 7 

Prime Contractors Adhered to Industry Standards in Providing 

Quality Assurance Oversight over Subcontractors 12 

DCMA Held Prime Contractors Accountable by Requiring 

Adherence to Contract Clauses 14 

Concluding Observations 16 

Agency Comments and Our Evaluation 17 

Appendix I Scope and Methodology 18 

Appendix II DCMA Offices and Contractors Reviewed 22 

Appendix III Comments from the Department of Defense 23 

Appendix IV GAO Contact and Staff Acknowledgments 24 

Tables 

Table 1: Types of Inspections Performed by DCMA Quality 

Assurance Specialists for the Contractors We Reviewed 8 

Table 2: Methods of Quality Assurance Oversight over 

Subcontractors Provided by the Prime Contractors We 

Reviewed 12 

Contents 
Page ii GAO-05-73 Defense Inventory 

Abbreviations 

DCMA Defense Contract Management Agency 

DLA Defense Logistics Agency 

DOD Department of Defense 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-05-73 Defense Inventory 

December 20, 2004 

The Honorable Ted Stevens 

Chairman 

The Honorable Daniel Inouye 

Ranking Minority Member 

Subcommittee on Defense 

Committee on Appropriations 

United States Senate 

The Honorable Jerry Lewis 

Chairman 

The Honorable John Murtha 

Ranking Minority Member 

Subcommittee on Defense 

Committee on Appropriations 

House of Representatives 

Military personnel rely upon weapon systems such as aircraft and tanks to 

successfully perform their missions on the battlefield. These systems 

contain numerous individual parts and assemblies produced by many 

different contractors and subcontractors. For example, an engine for an 

F-15 aircraft has approximately 16,000 parts and 1,600 different part 

numbers.1

 Although there is one prime contractor responsible for 

producing this engine, there are numerous subcontractors supplying the 

parts and assemblies required to build the engine under numerous 

contracts, and quality assurance is required throughout the production 

process. While the military services’ contracting offices oversee a small 

percentage of the Department of Defense’s (DOD) contracts for acquiring 

the parts, the Defense Contract Management Agency (DCMA), through its 

quality assurance specialists, provides quality assurance oversight over the 

majority of these contracts. Quality assurance oversight is defined as the 

various functions, including inspections, performed to determine whether 

a contractor has fulfilled the contractual obligations related to quality 

and quantity. This oversight is intended to assess whether contractors are 

 1

 A part number is a combination of numbers, letters, and symbols assigned by a designer 

and used by a manufacturer or vendor to identify a specific part or item of material. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-73 Defense Inventory 

capable of and are providing supplies or services that meet contract 

quality and technical requirements. 

Providing effective oversight is challenging, and DCMA recognizes that 

the risk of nonconforming parts reaching end users exists, given the 

diversity of contracts, parts, and products used to meet weapon 

systems requirements. For fiscal year 2003, DCMA was responsible for 

performing government quality assurance oversight over approximately 

273,000 contract actions.2

 To help mitigate risks inherent with spare parts 

acquisitions, DOD developed a risk management guide that discusses risk 

and risk management, examines risk management concepts, and provides 

a practical reference for dealing with acquisition risk. DCMA used this 

guide in developing its Risk Assessment and Management Program that is 

used to assess the risk of a contractor providing nonconforming parts. 

According to DCMA officials, for the majority of spare parts prime 

contractors that had contracts requiring oversight by DCMA and used 

subcontractors in providing the parts, DCMA relied upon the prime 

contractors to oversee their subcontractors. In accordance with the 

Federal Acquisition Regulation, DCMA is only responsible for providing 

quality assurance oversight over subcontractors when required to do so in 

the government’s interest. When DCMA provides quality assurance 

oversight over subcontractors, the prime contractor is not relieved of any 

quality assurance oversight responsibilities under the contract. 

This report responds to the mandate in section 8143 of the 2004 Defense 

Appropriations Act that GAO examine and report on the oversight of 

prime contractors by DOD and the oversight of subcontractors by prime 

contractors.3

 Our review focused on whether DCMA and spare parts prime 

 2

 Contract actions include issuing new contracts, purchase orders, or basic ordering 

agreements; modifying existing contracts; and issuing orders for parts included in existing 

contracts. In this report, we refer to all of these actions as contracts. 

3

 The act (Pub. L. No. 108-87, § 8143 (2003)) also mandated that the Secretary of Defense 

report by March 31, 2004, on (1) how to implement a system for tracking safety-critical 

parts so that parts discovered to be defective can be identified and found; (2) appropriate 

standards and procedures to ensure timely notification of contracting agencies and 

contractors about safety issues including parts that may be defective, and whether the 

Government Industry Data Exchange Program should be made mandatory; (3) efforts to 

find and test airplane parts that have been heat-treated by companies alleged to have done 

so improperly; and (4) whether contracting agencies and contractors have been notified 

about alleged improper heat treatment of airplane parts. The Secretary’s report was 

submitted on June 30, 2004, and included numerous actions DOD had taken or plans to 

take to address the issues included in the mandate. 
Page 3 GAO-05-73 Defense Inventory 

contractors are fulfilling their quality assurance oversight responsibilities 

as required by regulations, policies, procedures, and contract provisions. 

Specifically, our objectives were to determine whether: 

1. DCMA provided quality assurance oversight and enforcement over its 

spare parts prime contractors in accordance with established policies, 

procedures, and guidance; and 

2. prime contractors provided quality assurance oversight over their 

subcontractors’ work related to producing spare parts in accordance 

with industry standards and contract requirements. 

We also reviewed how DCMA held prime contractors accountable for 

overseeing their subcontractors’ work. 

To address our objectives, we reviewed regulations, policies, and 

procedures related to the quality assurance oversight over spare parts 

contractors provided by DCMA and prime contractors and the 

enforcement actions available to assure compliance. In addition, we 

reviewed 15 contracts awarded to 11 prime contractors and any reports on 

product quality deficiency for these contracts.4

 Specifically: 

• To assess whether DCMA provided quality assurance oversight over the 

prime contractors, we compared the quality assurance provisions included 

in the 15 contracts to oversight actions performed by DCMA quality 

assurance specialists.5

 In assessing whether DCMA used enforcement 

actions, we looked for instances of spare parts nonconformance related to 

these contracts and determined if DCMA levied any enforcement actions 

against the prime contractors. 

• To assess prime contractors’ oversight of their subcontractors, we 

interviewed representatives from the 11 prime contractors and determined 

if the prime contractors used subcontractors. For those that used 

subcontractors, we held discussions with prime contractor personnel 

related to the level of quality assurance oversight they performed over the 

subcontractors and reviewed their processes for managing suppliers and 

subcontractors. We also gathered documentation from the prime 

contractors on test results of parts produced by subcontractors. 

 4

 Details about our selection of the contracts are included in the scope and methodology 

section of this report. 

5

 DCMA has issued broad guidance, referred to as the One Book, to assist quality assurance 

specialists in executing their oversight responsibilities. 
Page 4 GAO-05-73 Defense Inventory 

• To assess how DCMA held prime contractors accountable for the work of 

their subcontractors, we reviewed the 15 contracts to determine if they 

included clauses holding the prime contractor responsible for the spare 

parts provided to the government. For the instances of nonconforming 

parts reported against these contracts, we reviewed how DCMA handled 

the reported nonconformance and whether DCMA held the prime 

contractor responsible for correcting the nonconformance. More detailed 

information about our scope and methodology is contained in appendix I. 

We conducted our review from November 2003 through October 2004 in 

accordance with generally accepted government auditing standards. 

In our review of the 15 contracts, DCMA quality assurance specialists 

followed established policies, procedures, and guidance in performing 

quality assurance oversight and enforcement over the spare parts prime 

contractors. DCMA’s oversight was provided through inspections that 

included: (1) physical inspection of parts such as testing the 

measurements and functions of parts, (2) evaluation of the prime 

contractors’ processes to determine compliance with established contract 

requirements and production procedures, and (3) observation of the outer 

appearance of spare parts and taking a physical count of the parts to 

ensure that the proper number of parts are being shipped to the end user. 

When one of the prime contractor’s processes and another contractor’s 

parts did not meet contract requirements, DCMA used an enforcement 

system that involved issuing requests for corrective action by the prime 

contractors. Corrective actions involved requiring the prime contractor to 

make corrections or changes to the production process and demonstrating 

how processes would be improved to prevent further instances of 

nonconformance. According to DCMA, it was not necessary to levy severe 

enforcement actions such as penalties and debarment from conducting 

business with the federal government against any of the contractors that 

we reviewed. 

The prime contractors we reviewed provided quality assurance oversight 

over their subcontractors’ work related to producing spare parts in 

accordance with accepted industry standards and contract requirements. 

Based on industry standards, prime contractors used at least two and up 

to four methods in providing quality assurance oversight over their 

subcontractors’ work. These methods included (1) evaluating and visiting 

potential subcontractors for placement on a list of approved suppliers for 

a particular part, (2) requiring certifications from the subcontractors that 

the parts or processes were produced in accordance with established 

Results in Brief 
Page 5 GAO-05-73 Defense Inventory 

industry standards and contract requirements, (3) performing periodic 

testing of parts produced by subcontractors, and (4) tracking and 

monitoring approved subcontractors’ past performance. The primary 

methods of oversight used were evaluating subcontractors for placement 

on the prime contractor’s Approved Supplier List and requiring 

certifications that their parts and processes conform to contractual 

specifications. Establishing an Approved Supplier List served to identify 

qualified subcontractors capable of producing needed parts or processes 

in accordance with industry standards and contractual specifications. 

Industry standards, developed and voted upon by a group of technical 

experts representing standards organizations such as Aerospace Standards 

and International Organization of Standardization, allowed prime 

contractors flexibility in providing quality assurance oversight over 

subcontractors considering the type and size of the organization and the 

product(s) produced. 

In our review of the 15 contracts, DCMA held prime contractors 

accountable for overseeing their subcontractors’ work by requiring that 

the prime contractors adhere to contract clauses concerning oversight 

responsibility. Most of the contracts we reviewed included either the 

Federal Acquisition Regulation clause stating that the prime contractor 

shall tender to the government for acceptance only supplies that conform 

with contract requirements or other clauses related to quality assurance 

requirements. When instances of product quality deficiency were reported, 

the DCMA quality assurance specialist and the prime contractor 

determined if the deficiency was due to contractor nonconformance and 

assigned responsibility for corrective action. For the 15 contracts we 

reviewed, we identified one deficiency that was determined to be the 

responsibility of the prime contractor and DCMA held the prime 

contractor accountable for the part. DCMA also performed reviews of 

subcontractors’ certifications to the prime contractor that the parts and 

processes produced by the subcontractor were manufactured in 

accordance with the contract requirements. These reviews served as a 

check by DCMA to determine whether the prime contractors’ quality 

assurance systems were adequate for oversight of their subcontractors’ 

work. During our review, service officials provided us with examples of 

other contracts in which nonconforming parts reached end users. DCMA 

followed its procedures for evaluating the causes of these nonconforming 

parts. The reasons for the nonconformance varied for each part. 

We are not making any recommendations in this report. While we did not 

identify any major deficiencies from the contracts and practices we 

reviewed, we recognize that the risk of nonconforming spare parts 
Page 6 GAO-05-73 Defense Inventory 

reaching end users exists. Compliance by contractors, DCMA, and other 

DOD agencies with established internal controls helps mitigate against 

this risk. 

In written comments on a draft of this report, DOD provided one technical 

comment, which we incorporated as appropriate. The department’s 

comments and our evaluation are on page 17 of this report. 

The Federal Acquisition Regulation is the primary regulation for use by 

all federal agencies in acquiring supplies and services. Sections 46 and 52, 

which discuss and set forth quality assurance and contract clauses, 

respectively, provide guidance in determining quality assurance 

responsibilities. According to the Federal Acquisition Regulation, 

government contract quality assurance is defined as the various functions, 

including inspections, performed by the government to determine whether 

a contractor has fulfilled the contract obligations pertaining to quality and 

quantity. These inspections can either be conducted at the contractor’s 

place of manufacture and production (source) or at the receiving location 

for the parts (destination). 

DCMA is DOD’s primary organization for performing quality assurance 

oversight for contracts and this oversight responsibility typically only 

covers prime contractors. DCMA’s execution of its quality assurance 

responsibility is primarily through its source inspection program. Source 

inspections are defined as inspections at the point where goods are 

manufactured or assembled. There are three types of source inspections: 

physical inspection; contractor process reviews; and kind, count, and 

condition. Physical inspection involves inspecting parts by comparing the 

parts to a specification, drawing, or other instruction. Contractor process 

reviews are inspections of processes and procedures for establishing 

confidence that the procured parts will produce a desired outcome. 

Inspections involving kind, count, and condition are inspections intended 

to visually identify and verify the quantity and exterior appearance of 

a part to determine if it visually meets contract specifications. 

During fiscal year 2003, DCMA was responsible for government source 

inspection for approximately 273,000 contracts. The Federal Acquisition 

Regulation requires that contracts include inspection and other quality 

requirements that will protect the interest of the government. It also 

provides guidance in establishing which clauses to include in the various 

types of contracts. The clauses included in each contract dictate the type 

Background 

DOD’s Quality Assurance 

Oversight for Contracts 

Is Provided Primarily 

by DCMA 
Page 7 GAO-05-73 Defense Inventory 

and level of quality assurance oversight to be performed. DCMA quality 

assurance specialists are expected to follow the inspection and 

acceptance provisions in each contract in determining whether they are 

required to perform quality assurance oversight. If the contract states that 

inspection and acceptance will be at destination, then DCMA does not 

perform any quality assurance oversight. End users within military units, 

such as Army battalions and Air Force squadrons, perform inspection and 

acceptance for these contracts. 

Questions have been raised about the efficiency of DCMA’s quality 

assurance oversight program. In October 2003, the DOD Inspector General 

reported that of the 518 contracts requiring DCMA source inspection that 

they reviewed, at least 172 of the inspections provided either nominal or 

no value to the DOD quality assurance process.6

 The DOD Inspector 

General also pointed out concerns in the DOD quality assurance program, 

including (1) ambiguity in the level and extent of requested source 

inspections; (2) inconsistent and unclear application of items defined as 

critical or having a critical application; (3) inconsistent implementation of 

inspection procedures for items considered commercial, off-the-shelf; and 

(4) arbitrary and inconsistent inspection procedures for items purchased 

from distributors. 

In our review of 15 contracts awarded to 11 contractors, DCMA provided 

quality assurance oversight and enforcement over these spare parts prime 

contractors. DCMA used three types of inspections to perform quality 

assurance oversight over the contractors. DCMA adhered to the Federal 

Acquisition Regulation, contract quality requirements, and DCMA 

guidance in providing quality assurance oversight over these prime 

contractors. Federal Acquisition Regulation clauses included in the 

contracts guide whether or not DCMA would perform quality assurance 

oversight. DCMA provides oversight for those contracts requiring 

inspection at the place of manufacture of the parts. Enforcement of spare 

parts quality and safety during the production process was achieved 

through the issuance of corrective action requests. 

 6

 ACQUISITION: Government Source Inspections (D-2004-011) October 15, 2003. 

DCMA Provided 

Quality Assurance 

Oversight and 

Enforcement over 

Contractors 
Page 8 GAO-05-73 Defense Inventory 

DCMA quality assurance specialists followed established policies, 

procedures, and guidance in performing their oversight over the spare 

parts prime contractors in our review. As shown in table 1, the quality 

assurance specialists performed one or a combination of three types of 

inspections over prime contractors. The three types of inspections include: 

physical inspection to measure the dimensions of parts or to test the parts; 

process reviews; or an observation of the kind, count, and condition of the 

parts. At 7 of the 11 contractor locations , DCMA quality assurance 

specialists performed both process reviews and physical inspections. 

Table 1: Types of Inspections Performed by DCMA Quality Assurance Specialists for the Contractors We Reviewed 

 Prime contractor Physical inspection Process reviews Kind, count, & condition 

1 Contractor A X X 

2 Contractor B X X 

3 Contractor C X X 

4 Contractor D X X 

5 Contractor E Xa

6 Contractor F X X X 

7 Contractor G X 

8 Contractor H X X 

9 Contractor I X 

10 Contractor J Xb

11 Contractor K X X 

Source: GAO analysis. 

a

Various types of inspections were performed at subsidiaries of this contractor. 

b

This contractor is a distributor of parts made by other manufacturers. 

For physical inspection of spare parts, the quality assurance specialist 

selects a sample of the parts from various production runs and inspects 

them by comparing the parts to a specification, drawing, or other 

instruction. For example, at one location, the prime contractor had 

procured the part from a subcontractor and required the subcontractor to 

provide test data related to the part. The quality assurance specialist 

reviewed the test data and compared it to the part specifications. Also, the 

quality assurance specialist inspected the number imprinted on the parts, 

exterior painting, and workmanship of the received parts to ensure they 

complied with contract specifications. 

The second type of inspection involves evaluating the prime contractors’ 

processes to determine compliance with established contract 

DCMA Used Three Types 

of Inspections to Perform 

Quality Assurance 

Oversight over Contractors 
Page 9 GAO-05-73 Defense Inventory 

requirements and production procedures. During these inspections the 

quality assurance specialist assesses the prime contractor’s processes and 

production line procedures in relation to established industry practices 

and provides the contractor an early opportunity to make corrections or 

improvements, if necessary. For example, at one prime contractor 

location, the quality assurance specialist monitored the prime contractor’s 

key processes during the production, including the cleaning, painting, 

welding, and final quality inspection of the product. To help ensure a 

comprehensive quality assurance check, the quality assurance specialist 

performed his daily quality checks at different phases of the production 

process. Also, the quality assurance specialist reviewed the prime 

contractor’s procedures for selecting its subcontractors to determine if the 

subcontractors were certified in accordance with the applicable industry 

standards. 

The third type of inspection consists of observing the kind, count, and 

condition of the parts. Observation of the kind of part includes visual 

identification of at least one part for each different part being procured 

under the contract and verifying the part number against the number 

required in the contract. Counting the parts involves visual confirmation of 

the contents of one package per line item and counting the number of 

packages received. The quality assurance specialists verify the physical 

appearance of the parts to assess their condition. For example, at one 

location, the quality assurance specialist performed a kind, count, and 

condition inspection to confirm that the contractor had the correct part by 

verifying the part number, checking to ensure the contractor had the 

proper quantity of parts, and inspecting the outward appearance of the 

parts. 

DCMA’s quality assurance oversight over the 11 spare parts prime 

contractors in our review was in accordance with the Federal Acquisition 

Regulation, contract quality requirements, and DCMA’s One Book 

guidance. Each contract we reviewed designated the location of 

inspection and acceptance by contract line item. Contracts that were 

designated for inspection and acceptance at the contractor’s place of 

manufacture and production received DCMA quality assurance oversight. 

When contracts are designated for inspection and acceptance at the 

receiving location for the parts, the end user is responsible for inspecting 

the procured part and the DCMA quality assurance specialist typically 

does not get involved with the contract. 

DCMA Adhered to the 

Federal Acquisition 

Regulation, Contract 

Quality Requirements, and 

DCMA Guidance in 

Providing Quality 

Assurance Oversight over 

Prime Contractors 
Page 10 GAO-05-73 Defense Inventory 

Of the 15 contracts we reviewed, DCMA provided quality assurance 

oversight for the 13 contracts that were designated for inspection and 

acceptance at source. The other two contracts were designated for 

inspection and acceptance at destination and did not require DCMA 

quality assurance oversight. In accordance with the One Book guidance, 

quality assurance specialists performed inspections and acceptance for 

its customers to ensure supplies were in compliance with contract 

requirements. According to a DCMA official, this guidance allows DCMA 

quality assurance specialists flexibility in providing quality assurance 

oversight over prime contractors. For example, the guidance does not 

include standard requirements for the number of tests, site visits, or 

inspections that the DCMA quality assurance specialists should perform 

while providing quality assurance oversight. When contracts were 

designated for inspection and acceptance at source, quality assurance 

specialists typically reviewed contract requirements, assessed the 

contractor’s risks of producing nonconforming parts, determined what 

needed to be done to mitigate the risks, and applied quality assurance 

oversight, including inspections, based on the contractor’s risk level. 

During the production process, when a prime contractor’s processes or 

spare parts did not meet contract requirements, DCMA used an 

enforcement system that involved issuing requests for corrective action by 

the prime contractor. According to the Federal Acquisition Regulation, 

contractors must be given an opportunity to correct or replace 

nonconforming supplies. Contractors are notified about nonconformance 

through corrective action requests issued by DCMA or product quality 

deficiency reports issued by the end user. When there is contractual 

nonconformance during the production process, DCMA may issue the 

prime contractor a corrective action request to formally communicate the 

deficiency and request corrective action on the part of the prime 

contractor. When the prime contractor does not take corrective actions, 

contractual remedies available to procuring contracting officers include 

suspension of progress payments, termination for default, and penalties 

such as suspension or debarment from holding contracts with the 

government. 

Only 2 of the 11 prime contractors that we reviewed received corrective 

action requests related to the contracts in our review. According to DCMA 

officials, the remaining contractors did not warrant corrective action 

requests related to the contracts we reviewed. Our review of DCMA files 

related to these contractors also did not identify any need for corrective 

actions by the prime contractors. Corrective actions identified by the two 

Enforcement of Spare 

Parts Quality and 

Safety during the 

Production Process 

Was Achieved 

through Corrective 

Action Requests 
Page 11 GAO-05-73 Defense Inventory 

contractors involved the prime contractor making corrections or changes 

to its production processes and demonstrating how processes would be 

improved to prevent further instances of nonconformance. For example, 

DCMA issued a corrective action request to a prime contractor identifying 

loose insulation, an inactive gear, poor painting quality, and parts that did 

not meet surface finish specification requirements as nonconforming 

items. The prime contractor corrected the nonconformance and DCMA 

accepted the product. To prevent reoccurrence of the deficiencies, the 

prime contractor reported that it had taken the following actions: 

(1) discontinued the use of material that caused the loose insulation, 

(2) instructed operators to ensure that gears were properly adjusted, 

(3) arranged a meeting with all contractor paint personnel advising them 

on the importance of attention to detail, and (4) agreed to provide their 

quality assurance representatives with acceptable and unacceptable finish 

samples as visual standards to meet customer expectations. 

For the other prime contractor, DCMA issued a corrective action request 

because the contractor used the wrong procedure to receive approval for a 

major waiver from contract requirements.7

 The request for major waiver 

was supposed to go through an array of signatures and DCMA approvals, 

whereas a minor waiver could be submitted and approved electronically, 

requiring fewer signatures and approvals. However, the prime contractor 

downgraded the waiver request from major to minor without the 

appropriate concurrence and approval of DCMA and submitted the request 

through the electronic system. According to the prime contractor, their 

personnel had conflicting procedures describing how to process waivers. 

To prevent reoccurrence of incorrect processing of major waivers, the 

contractor planned to review its current procedures for processing 

waivers. Also, the contractor planned to train its quality assurance staff to 

ensure they understand the correct procedures for processing waivers. 

 7

 A waiver is a deviation from contract requirements and can be considered major or minor. 
Page 12 GAO-05-73 Defense Inventory 

The prime contractors in our review adhered to industry standards in 

providing quality assurance oversight over their subcontractors’ work. 

Based on industry standards, prime contractors performed at least two or 

up to four methods to provide quality assurance oversight over their 

subcontractors, as shown in table 2. The primary methods of oversight 

used were evaluating subcontractors for placement on an Approved 

Supplier List and requiring certifications of parts and processes. Industry 

standards, such as the International Organization for Standardization 9001 

and Aerospace Standards 9100, require that an organization have a quality 

management system in place to ensure that it will produce high quality 

products that will serve their intended purpose. The standards are broad 

and are intended to be applicable to all organizations, regardless of type, 

size, and product provided. 

Table 2: Methods of Quality Assurance Oversight over Subcontractors Provided by the Prime Contractors We Reviewed 

Prime 

contractor 

Evaluated potential 

subcontractors for their 

approved supplier list 

Required 

certifications 

Tested parts 

and processes 

produced 

Tracked and monitored 

subcontractors’ 

performance 

1 Contractor A X X X 

2 Contractor B X X X 

3 Contractor C X X X 

4 Contractor D X X X 

5 Contractor E X X X X 

6 Contractor F X X X X 

7 Contractor G X X X X 

8 Contractor H X X X X 

9 Contractor I X X X X 

10 Contractor J X X 

11 Contractor K X X X 

Source: GAO analysis. 

All of the prime contractors that we reviewed evaluated potential 

subcontractors prior to the contract award for placement on their 

Approved Supplier List. The purpose of establishing an Approved Supplier 

List is to identify qualified subcontractors capable of producing needed 

parts or processes in accordance with industry standards and contractual 

specifications. When evaluating a potential subcontractor for inclusion on 

their Approved Supplier List, some prime contractors periodically visited 

their subcontractors’ production facilities, requested that subcontractors 

complete surveys containing questions regarding the subcontractors’ 

capabilities and qualifications necessary to produce parts and processes, 

Prime Contractors 

Adhered to Industry 

Standards in 

Providing Quality 

Assurance Oversight 

over Subcontractors 
Page 13 GAO-05-73 Defense Inventory 

or examined information about the technical skills and qualifications of 

subcontractor personnel, past performance for producing similar 

products, and applicable certifications related to the subcontractors’ 

operations. Six of the 11 prime contractors said they periodically visited 

potential subcontractors prior to contract award. 

All of the prime contractors that we reviewed required certifications such 

as independent, third-party certifications or certificates of conformance 

from their subcontractors to certify that their parts and processes are in 

accordance with contract requirements and industry standards.8

Independent, third-party certifications and certificates of conformance 

served as verification that the subcontractors could produce parts and 

processes that conformed to contractual specifications. Prime contractors 

required certifications from their subcontractors for different phases of 

the production process. For example, one contractor used steel to 

fabricate parts and required a certification from the steel subcontractor 

that the steel had been produced according to specifications. In this 

instance, the prime contractor did not use the steel provided by the 

subcontractor until they received the certificate of conformance verifying 

that the product was in accordance with industry standards and 

contractual requirements. 

Eight of the 11 prime contractors we reviewed periodically tested parts or 

processes produced by their subcontractors. Prime contractors tested the 

subcontractors’ parts or processes at either the manufacturing site or the 

receiving point to determine whether products or processes met 

contractual specifications. For example, one prime contractor performed 

mechanical and electrical tests on all materials received from 

subcontractors to ensure that the materials met contract specifications. If 

the materials did not meet contract specifications, the prime contractor’s 

review board, which included the government quality assurance specialist, 

made a determination concerning the disposition of the materials. 

Disposition options included using the material “as is” or scrapping it. 

Seven of the prime contractors that we reviewed tracked and monitored 

the performance of their subcontractors by establishing performance 

goals, assessing and rating the subcontractors’ performance, or 

 8

 Third-party certification is performed by a registered external auditing organization and 

provides verification and assurance that products or processes are consistent with 

established standards. 
Page 14 GAO-05-73 Defense Inventory 

recommending corrective and preventive actions when subcontractors 

produced nonconforming parts. The seven prime contractors established 

performance goals and rated their subcontractors on a routine and 

periodic basis using various performance metrics, such as product quality 

and on-time deliveries. For example, one contractor kept track of the 

number of nonconforming parts provided by each subcontractor in 

relation to the total number of parts provided. When a subcontractor’s 

nonconformance rate exceeded the prime contractor’s acceptable goal, 

the prime contractor placed the subcontractor on probation. 

In our review of the 15 contracts, DCMA held prime contractors 

accountable for overseeing their subcontractors’ work by requiring that 

prime contractors adhered to contract clauses concerning oversight 

responsibility. When instances of nonconformance were reported through 

product quality deficiency reports, the DCMA quality assurance personnel 

and the prime contractor determined if the deficiency was due to 

contractor nonconformance and assigned responsibility for corrective 

action. For the 15 contracts we reviewed, one deficiency was determined 

to be the responsibility of the prime contractor and DCMA held the prime 

contractor accountable for the part. During our review, service officials 

provided us with examples of other contracts in which nonconforming 

parts reached end users. DCMA followed its procedures for evaluating the 

causes of these nonconforming parts. The reasons for the 

nonconformance varied for each part. 

Most of the 15 contracts we reviewed included Federal Acquisition 

Regulation clause 52.246-2, Inspection of Supplies—Fixed Price, which 

states that the prime contractor shall tender to the government for 

acceptance only supplies that have been inspected in accordance with the 

inspection system and found by the contractor to be in conformity with 

contract requirements. This contract clause also states that the contractor 

is not relieved of its oversight responsibility when government quality 

assurance over subcontractors is required. The remaining contracts 

included other quality clauses or did not specify quality requirements 

because the contractors had quality systems that had been previously 

approved by the procuring contracting officers. 

DCMA also performed reviews of subcontractors’ certifications to the 

prime contractor that the parts and processes produced by the 

subcontractor were manufactured in accordance with the contract 

requirements. DCMA quality assurance specialists periodically reviewed 

third-party certifications and contractors’ documents related to site visits, 

DCMA Held Prime 

Contractors 

Accountable by 

Requiring Adherence 

to Contract Clauses 
Page 15 GAO-05-73 Defense Inventory 

receiving inspections, and other oversight of subcontractors. These 

reviews provided a technique for DCMA to determine whether the 

contractors’ quality assurance systems were adequate for oversight of 

subcontractors. For example, at one contractor location, the quality 

assurance specialist obtained copies of certifications that steel was 

produced and heat-treated in accordance with standards. The specialist 

also reviewed copies of test records maintained by the contractor during 

the production process. 

After parts are provided to end users within military units, such as Army 

battalions and Air Force squadrons, instances of nonconforming parts are 

reported through product quality deficiency reports. End users issue 

product quality deficiency reports to identify deficiencies in parts that may 

indicate nonconformance with contractual or specification requirements. 

When the end user identifies a nonconforming product, the user issues a 

product quality deficiency report that is sent to the applicable DCMA 

contract management office and distributed to the quality assurance 

specialist responsible for overseeing the contractor that produced the 

item. The quality assurance specialist notifies the contractor of the report. 

The contractor may request that the part be returned to its facility for 

testing to determine whether the problem that has been identified by the 

user can be duplicated. The DCMA quality assurance specialist and the 

prime contractor also determine if the deficiency was due to contractor 

nonconformance with contract requirements and assign responsibility for 

corrective action. DCMA writes the final disposition of the product quality 

deficiency report based on the results of the tests completed by the 

contractor and the assessment of who was responsible for the deficiency. 

In those cases where the deficiency was determined to be the 

responsibility of the prime contractor, DCMA held the prime contractor 

accountable for the part. If the cause of the deficiency was tied back to a 

subcontractor, DCMA held the prime contractor responsible for correcting 

the deficiency and ensuring that the subcontractor’s processes were 

modified to correct the cause of the nonconformance. 

During our review, service officials provided examples of other contracts 

in which nonconforming parts reached end users for various reasons. 

DCMA and prime contractors followed their procedures in evaluating 

causes for the nonconformance. For example, in March 2004 one prime 

contractor was notified that five wiring harnesses, manufactured by one of 

their approved subcontractors, were defective. Investigations showed that 

the prime contractor’s quality oversight system did not detect the problem 

because its personnel were unfamiliar with drawings, specifications, or 

electrical wiring harness fabrications. After the problem was identified, 
Page 16 GAO-05-73 Defense Inventory 

the prime contractor provided training related to drawings and proper 

manufacturing processes to its quality assurance personnel as well as 

subcontractor personnel. However, according to the prime contractor, the 

subcontractor still could not produce the wiring harnesses correctly. As a 

result, the prime contractor selected another subcontractor to 

manufacture the wiring harnesses. 

In another case, the contract was for a survival kit that included critical 

safety items. The nonconformance related to an O-ring lubricant that was 

allowing oxygen pressure to be released prematurely. Based on the 

deficiency report, the contractor began using another lubricant for the 

O-ring that eliminated the problem. For this contract, DCMA 

recommended that government source inspection be added at the 

subcontractor level because no prior government source inspection 

was required. 

Yet in another example, an axle component manufactured by a 

subcontractor broke on an aircraft landing gear because the dimensions of 

the axle component were incorrect. Incorrect dimensions resulted from 

the subcontractor’s improper grinding process; yet, the subcontractor 

never reported the discrepancies to the prime contractor. Since the 

incident, the prime contractor has placed the subcontractor on probation 

within the prime contractor’s quality approval system. The subcontractor 

will remain on probation until an audit is performed by the end users of 

the axle to verify that all corrective actions are in effect. 

DCMA and the prime contractors we reviewed utilized a number of 

processes to provide quality assurance oversight over the production of 

spare parts for the military. The processes included conducting physical 

inspections of parts produced by contractors, reviewing prime 

contractor’s processes, evaluating potential subcontractors for placement 

on an Approved Supplier List, requiring certifications of parts and 

processes, testing parts and processes, and tracking and monitoring 

subcontractor’s performance. These processes are founded upon 

contractual requirements, DCMA policies, and industry standards for 

quality assurance. In addition, there are enforcement procedures that 

DCMA uses when nonconforming spare parts reach end users. 

However, despite these quality assurance controls, some risk still exists. 

For example, while we did not identify any major deficiencies from the 

contracts and practices we reviewed, service officials provided examples 

of nonconforming parts related to contracts not included in our review 

that reached end users for various reasons. Furthermore, given the vast 

Concluding 

Observations 
Page 17 GAO-05-73 Defense Inventory 

number of contracts and contractors involved in providing spare parts to 

the government, we recognize that the risk of nonconforming spare parts 

reaching end users exists. Compliance by contractors, DCMA, and other 

DOD agencies with established internal controls helps mitigate against 

this risk. 

In written comments on a draft of this report, DOD provided one technical 

comment, which we incorporated as appropriate. DOD did not provide any 

additional comments. DOD’s written comments are reprinted in their 

entirety in appendix III. 

We are sending copies of this report to the Secretary of Defense; the 

Secretaries of the Army, the Navy, and the Air Force; the Director of the 

Defense Contract Management Agency; the Director of the Defense 

Logistics Agency; and other interested parties. We will also make copies 

available to others upon request. In addition, the report will be available at 

no charge on the GAO Web site at http://www.gao.gov. 

Please contact me at (202) 512-8365 if you or your staffs have any 

questions concerning this report. Major contributors to this report are 

included in appendix IV. 

William M. Solis, Director 

Defense Capabilities and Management 

Agency Comments 

and Our Evaluation 
Appendix I: Scope and Methodology 

Page 18 GAO-05-73 Defense Inventory 

To address our objectives, we judgmentally selected for review 

11 contracts awarded to 11 prime contractors. During the course of our 

review, Defense Contract Management Agency (DCMA) and the prime 

contractors provided four additional contracts awarded to some of these 

same contractors that had nonconforming parts that reached end users, 

bringing the total number of contracts we reviewed to 15. Given the small 

number of contracts we reviewed, our results cannot be used to make 

inferences about the entire population of contracts requiring government 

quality assurance. We included the following kinds of contracts as 

candidates for our study: contracts, purchase orders, basic ordering 

agreements, delivery orders against existing contracts, and contract 

modifications for existing contracts. We included contracts that were large 

and small dollar value, from DCMA’s East and West regions, and from the 

Army, Navy, Air Force, and the Defense Logistics Agency (DLA). Eleven of 

these contracts were judgmentally selected: three from information 

provided by the Navy and Air Force on nonconforming parts and 8 from 

DCMA. To select the eight contracts, we obtained a query from DCMA’s 

Mechanization of Contract Administration Services system of contracts for 

October 1, 1999, through September 30, 2003. Because of the large number 

of contracts in the database and because we wished to examine recent 

contract quality assurance oversight practices, we sorted the query to only 

identify contracts for fiscal year 2003. From this query, we sorted the 

contracts into four groups according to whether they were associated with 

the Army, the Navy, the Air Force, or the Defense Logistics Agency. We 

randomly sampled contracts from each of these four groups. Then, we 

judgmentally selected a subset of contracts from our random samples in 

such a way to obtain a set of eight contracts that spanned the various 

military commands and DCMA’s East and West regions. The breakout of 

the eight contracts included three Army, two Air Force, two Navy, and one 

Defense Logistics Agency. 

To assess the reliability of data from DCMA’s Mechanization of Contract 

Administration Services system we (1) performed electronic testing of 

required data elements, (2) reviewed existing information about the data 

and the system, and (3) interviewed agency officials knowledgeable about 

the data. We determined DCMA’s Mechanization of Contract 

Administration Services system data to be reliable for the purposes of 

our review. 

To assess whether DCMA provided quality assurance oversight and 

enforcement over its spare parts prime contractors in accordance with 

established policies, procedures, and guidance, we compared contract 

quality assurance provisions and requirements to oversight actions 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 19 GAO-05-73 Defense Inventory 

performed by DCMA for the 15 contracts. Specifically, we reviewed the 

Federal Acquisition Regulation, the DCMA One Book, and the contracts to 

determine quality assurance oversight responsibilities and enforcement 

actions available to assure contractor compliance. We compared these 

policies, procedures, and contract requirements to the three types of 

inspections performed by DCMA quality assurance specialists to assess if 

DCMA provided appropriate oversight. For each of the contracts, we met 

with officials at the DCMA contract management offices identified on the 

contracts to determine quality assurance oversight actions performed by 

DCMA personnel. As part of this assessment, we determined which of the 

three types of inspections were performed for each contractor. We sent 

letters to officials at the DOD contracting offices to obtain and review 

documentation related to the pre-award process, quality assurance 

requirements, and the contracting officers’ interaction with DCMA prior to 

contract award. In assessing whether DCMA used enforcement actions, we 

reviewed the product quality deficiency reports included in our review to 

determine if DCMA levied enforcement actions against the prime 

contractor when necessary. We also reviewed prior DOD and GAO reports 

related to DCMA’s execution of its quality assurance oversight over prime 

contractors and DOD’s implementation of its deficiency reporting system. 

To assess whether prime contractors provided quality assurance oversight 

over their subcontractors’ work related to producing spare parts and 

followed industry standards and contract requirements, we identified 

prime contractor quality assurance oversight actions performed over 

subcontractors. We reviewed Aerospace Standard 9100 and prime 

contractor quality manuals to determine requirements for establishing 

contractor quality management systems and ensuring that their 

subcontractors are providing quality parts.1

 We visited and interviewed 

representatives at the prime contractor locations as shown in appendix II, 

and determined whether the prime contractors used subcontractors. For 

those that used subcontractors, we identified the level of quality assurance 

oversight performed by these prime contractors over the subcontractors. 

We discussed whether the prime contractors performed supplier ratings of 

their subcontractors, tested parts or processes provided by their 

subcontractors, or conducted site visits at their subcontractors’ facilities. 

At the prime contractor facilities, we observed the prime contractors’ 

processes for manufacturing or repairing parts to determine the quality 

 1

 Aerospace Standard 9100 includes the International Organization for Standardization 9001 

quality assurance requirements. 
Appendix I: Scope and Methodology 

Page 20 GAO-05-73 Defense Inventory 

assurance performed by the prime contractor throughout the production 

process. 

To assess how DCMA held prime contractors accountable for the work of 

their subcontractors, we reviewed the 15 contracts to determine if the 

contracts included clauses holding the prime contractor responsible for 

the spare parts provided to the government and whether instances of 

nonconformance had occurred. For the reported instances of 

nonconformance, we looked at whether DCMA held the prime contractor 

responsible for correcting the nonconformance and what types of actions 

were performed by DCMA. We also reviewed the Federal Acquisition 

Regulation to determine contract clauses that require the prime contractor 

to ensure that parts furnished to the government conform to contract 

requirements. We reviewed the contracts to determine if they included 

clauses that the prime contractor was responsible for the spare parts being 

provided. 

We also visited or obtained information from representatives at the 

following organizations: 

• U.S. Air Force, Office of the Assistant Secretary, Contracting Operations 

Division, Rosslyn, Va.; 

• U.S. Air Force Materiel Command, Wright Patterson Air Force Base, Ohio; 

• U.S. Army Materiel Command Headquarters, Fort Belvoir, Va.; 

• U.S. Army, Aviation and Missile Command, Redstone Arsenal, 

Redstone, Ala; 

• U.S. Army, Communications Electronics Command, Fort Monmouth, NJ; 

• U.S. Army, Research Development and Engineering Command, Armament 

Research, Development and Engineering Center, Rock Island, Ill.; 

• U.S. Army, Research Development and Engineering Command, Edgewood 

Chemical Biological Center, Rock Island, Ill.; 

• U.S. Army, Secretary of the Army for Acquisition, Logistics, and 

Technology, Arlington, Va.; 

• U.S. Army, Tank Automotive and Armaments Command, Warren, Mich.; 

• U.S. Navy, Naval Air Systems Command, Patuxent River Naval Air Station, 

Patuxent River, Md.; 

• U.S. Navy, Office of the Assistant Secretary, Research, Development, and 

Acquisition, Washington, D.C.; 

• U.S. Defense Logistics Agency Headquarters, Fort Belvoir, Va.; 

• U.S. Defense Contract Management Agency Headquarters, Alexandria, Va.; 
Appendix I: Scope and Methodology 

Page 21 GAO-05-73 Defense Inventory 

• Office of the Under Secretary of Defense for Acquisition, Technology, and 

Logistics, Alexandria, Va.; and 

• Aerospace Industries Association, Arlington, Va. 

We performed our review from November 2003 through October 2004 in 

accordance with generally accepted government auditing standards. 
Appendix II: DCMA Offices and Contractors 

Reviewed 

Page 22 GAO-05-73 Defense Inventory 

 DCMA Contract Management Offices DCMA District Prime contractor Number of contracts

1 Boston East Contractor K 1

2 Dayton East Contractor H 2

3 Long Island East Contractor G 1

4 Maryland East Contractor C 2

5 Philadelphia East Contractor B 3

6 Philadelphia East Contractor F 1

7 South Florida East Contractor J 1

Total East Region contracts 11

8 Long Beach West Contractor E 1

9 Los Angeles West Contractor D 1

10 Phoenix West Contractor A 1

11 Santa Ana–Irvine West Contractor I 1

Total West Region contracts 4

Source: GAO analysis. 

Appendix II: DCMA Offices and Contractors 

Reviewed 
Appendix III: Comments from the Department 

of Defense 

Page 23 GAO-05-73 Defense Inventory 

Appendix III: Comments from the 

Department of Defense 
Appendix IV: GAO Contact and Staff 

Acknowledgments 

Page 24 GAO-05-73 Defense Inventory 

David A. Schmitt (757) 552-8124 

In addition to the individual named above, Connie W. Sawyer, Jr.; 

Tracy Whitaker; Leslie West; Renee McElveen; Minette Richardson; 

Kenneth Patton; Sidney Schwartz; and Douglas Cole made key 

contributions to this report. 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Acknowledgments 

(350460) 
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