Page 2 Attachment, ADC 430 

ADC 430 

Timeframe Change for SA SDR Requests for Reconsideration 

1. ORIGINATING SERVICE/AGENCY AND POC INFORMATION: 

 a. Technical POC: AFSAC/IARGB, DSN 986-1984, (937) 656-1984, 

 b. Functional POC: AFSAC/IARGB, DSN 986-1984, (937) 656-1984, 

2. FUNCTIONAL AREA:

 a. Primary/Secondary Functional Area: FMS SDR Submission for Reconsideration 

 b. Primary/Secondary Functional Process: SDR Exhibits 

3. REFERENCES: 

a. DLA Logistics Management Standards Office Memorandum, subject: Approved DLMS 

Change (ADC) 293, Revised Time Standards, Codes, and Procedures for Reporting and 

Processing of Supply Discrepancies (Staffed as PDC 316), dated August 13, 2008. 

b. DoD 4000.25-M, Defense Logistics Management System (DLMS) Manual, Volume 2, 

May 19 2009 Change 5A, C17.5.7.1. 

c. DSCA Memorandum subject: Time Standards for Reconsideration of Supply 

Discrepancy Reports (SDRs), Policy Memo 10-44, dated October 21, 2010. 

4. BACKGROUND: 

 a. General. The time standards used in the reconsideration of SDRs were reduced from 

90 calendar days to 45 calendar days effective May 19, 2009. This was established by an ADC 

that resulted from an SDR Continuous Process Improvement Event conducted in July 2008 (see 

reference 3.a). With the advances in information technology, it was determined there was no 

longer a need to add-in extra time for mailing an SDR. The time standard for the initial response 

to the SDR by the action activity was reduced from 55 days to 50 days (with separate time 

standards delineated for depot shipments). The Air Force had asserted that a reduced time limit 

for exhibit items was necessary because exhibit items usually involve a limited contractor 

warranty. The goal was to insure that the materiel would be returned to the contractor within the 

shortest amount of time possible so as not to jeopardize the warranty coverage. The revised time 

standards are governed by DoD 4000.25-M (see reference 3.b). Subsequent to the publication of 

the ADC, Defense Security Cooperation Agency (DSCA) formally distributed the revised time 

standard guidance (see reference c). 

 b. Intent of the transaction: To allow the FMS customer sufficient time to submit an 

SDR for reconsideration after in-country receipt of returned SDR exhibit item. 

c. Scenario for which the transaction is used: The FMS customer returns an SDR 

exhibit item to an action activity for evaluation/repair/replace. The action activity determines 
Page 3 Attachment, ADC 430 

either that no discrepancy exists or repairs the item, at no cost, and returns it to the FMS 

customer. The FMS customer again tests the item and finds it is still discrepant. 

 d. Procedures, transactions, data elements, processing details in use today: The 

customer is submitting a request for reconsiderations at 45 days indicating exhibit materiel has 

not been received in country yet in order to meet the current time standard. Upon receipt and 

inspection of the item, a correction or cancellation is submitted.. 

5. REQUESTED CHANGE(S): 

 a. Requested change in detail: Establish an exception to the 45 day reconsideration 

timeframe for FMS customers who are receiving a returned exhibit item as a result of their 

previous SDR submission. This change will re-instate the 90 day reconsideration timeframe 

where materiel/exhibits must be returned to the customer, thereby allowing additional time for 

the return-to-customer transportation and the customer’s re-evaluation of their returned property. 

Revisions subsequent to staffing are highlighted in green. 

 b. Proposed procedures: Update the DLMS manual procedures for FMS Requests For 

Reconsideration as shown below. 

 (1) Current DoD 4000.25-M reads: “C17.5.7.1. Requests for Reconsideration. The 

SA purchaser may ask the U.S. Government to reconsider the disposition for a reported supply 

discrepancy. Purchasers must send a written request to the ILCO within 45 calendar days 

from the date of the ILCO reply to the customer concerning disposition, as provided by the 

responsible action activity.” 

 (2) Proposed change would read: “C17.5.7.1. Requests for Reconsideration. The SA 

purchaser may ask the U.S. Government to reconsider the disposition for a reported supply 

discrepancy. Purchasers must send a Request for Reconsideration to the ILCO within 45 

calendar days from the date of the ILCO final reply to the customer concerning disposition, 

except when materiel/exhibit return to the customer is required subsequent to US 

Government-directed evaluation/testing/repair. This exception is applicable only when the 

materiel/exhibit must be re-inspected by the customer to confirm that the reported 

discrepancy/deficiency has been resolved and, therefore, additional transportation time is 

necessary for the return shipment. Under this scenario only, the SA purchaser is authorized 

up to 90 days from the date of the final ILCO reply to submit the Request for Reconsideration 

to the ILCO. The ILCO shall be responsible for monitoring that requests for reconsideration 

are submitted within the allowable time standards. 

 c. Alternatives: Not applicable. 

6. REASON FOR CHANGE: While the SDR reply is transmitted electronically to the 

customer, 45 days is not sufficient time for an action activity to physically return exhibit materiel 

to the FMS customer country and allow the FMS customer to re-inspect and submit the SDR for 

reconsideration if they disagree with the action activity determination of denial/repair. It is 

recommended the FMS customer still be allowed a 90 day reconsideration timeframe when 

materiel return is involved. This will prevent the customer from submitting a request for 

reconsiderations at 45 days indicating exhibit materiel has not been received in country yet, and 

that a correction or cancellation will follow upon receipt and inspection of the item. With the 

reduced 45 day timeline, this precautionary, and often unnecessary paperwork, is the country’s 
Page 4 Attachment, ADC 430 

only option to ensure their reconsideration claim can be processed within the regulatory 

guidelines, if needed, upon receipt of the materiel. 

 a. Advantages (tangible/intangible): Reduce the number of subsequent contested SDR 

submissions that may result when the FMS customer is unable to meet the 45 day resubmission 

timeframe and the resubmission request is denied. Prevent extra workload to process 

resubmission claims followed by cancellations or corrections because the 45 days is insufficient 

time to receive and re-inspect materiel. 

 b. Disadvantages: None known 

7. NOTE ANY REGULATIONS OR GUIDANCE: (IF APPLICABLE): 

8. ESTIMATED TIME LINE/IMPLEMENTATION TARGET: As soon as possible. 

9. ESTIMATED SAVINGS/COST AVOIDANCE ASSOCIATED WITH 

IMPLEMENTATION OF THIS CHANGE: This will prevent redundant and unnecessary 

paperwork by the customers and the ILCOs as the customers will have sufficient time to receive 

and inspect their materiel, then submit an SDR request for reconsideration if needed. Otherwise, 

the customers submit the request for reconsideration to beat the clock prior to knowing if the 

claim is justified or not. 

10. IMPACT: 

 a. New DLMS Data Elements: N/A 

 b. Changes to DLMS Data Elements: N/A 

c. Publications: DLMS and Security Assistance Management Manuals 

d. AIS Impact: May impact SDR processing applications with automated time standard 

edits. 
ADC 430 Enclosure 

Enclosure, Concurrence and Comment Resolution 

 Organization Concurrence/Comment Response 

1. DLA Concur 

As previously stated, there is no way to systemically 

identify these items in EBS, so the burden will be on 

the ILCO to monitor. 

Initial comments: 

I have some substantive comments from a SPO for 

SDRs and what they feel is needed before he can 

concur (below). Also, there will be system impact on 

EBS and an SCR will be required. 

1. System edits would need to be developed to 

determine if the activity that is requesting 

reconsideration is actually FMS. Also, edits would 

need to be developed that would look at the original 

disposition code and check that against the time the 

original closure or disposition was provided and then 

check that against the incoming reconsideration 

request and determine if it falls within the timeframe 

allowed. These system edits would need to be 

developed so that the ILCO office can ensure that the 

system is not being abused. 

2. DLA Land and Maritime T/Q SPO sees no system 

edits in place to monitor the implementation of this 

process. Furthermore, there is no guidance/policy 

outlined in this process that describes the 

responsibility of the ILCO Office to ensure that the 

customer is receiving exhibits from a previously 

submitted SDR, thus allowing them to exceed the 45 

day limit for reconsideration. This would effectively 

allow all customers to exceed the 45 day time limit. 

 In conclusion, since there are no system edits in place 

and no policy offered in this PDC for the ILCO office 

to ensure criteria is met that allows the customer to 

exceed the 45 day limit for reconsideration, DLA 

Land and Maritime T/Q SDR SPO non-concurs to the 

cited changes outlined in PDC 458. 

Noted. 

Response to initial comments: 

1. DLA does not need additional 

edits to support this change. The 

ILCO will be responsible for 

confirming that the 

reconsideration request has been 

submitted within the allowable 

time standard (for both standard 

and exception criteria). All FMS 

requests for reconsideration 

forwarded by the ILCO to the 

DoD action activity may be 

processed as within the 

allowable time standard. 

2. Clarification has been added 

to the DLMS manual procedures 

stating that it is ILCO 

responsibility to monitor for 

compliance with the new time 

standard. 

3. The examples provided 

would not qualify for the 

exception time standard. Only 

specific scenarios would be 

authorized the additional time 

for submission of the request for 

reconsideration: (1) item(s) 

which have been returned by the 

FMS customer to the U.S. 

custody by the direction of the 

DoD action activity and (2) these 

item(s) require repair or 

analysis/inspection/corrective 

action and subsequent return to 

the FMS customer (vice credit 

for the item), and (3) the FMS 

customer must have the returned 
Page 2 Attachment, ADC 430 

3. DLA SPO non-concurs to the PDC as written. The 

number of reconsiderations associated to material 

returned from exhibit should be minimal. The PDC 

does not outline a traceable and reliable process to 

identify these. How would the ILCO identify the 

material as being returned from an exhibit? I think it 

would leave all reconsiderations open for the 

increased timeframe. 

I have two examples that support the decision to nonconcur. One is where the customer has basically 

stated they will return tires in their time. The second 

is where only one customer is complaining about the 

material and is not responsive in returning material. I 

have attached emails as support. 

item(s) in custody in order to 

verify that that the 

discrepancy/deficiency has been 

resolved. 

(4) Additional clarification has 

been incorporated in the DLMS 

manual procedures. 

2. Air Force Concurs Noted 

3. Army Concurs Noted 

4. USTRANSCOM Abstains Noted 

5. USMC Concurs Noted 

6. DSCA Concurs Noted