INTRODUCTION This article discusses a complex, yet controversial group of process controls required for the accountability of tools as prescribed by the Naval Aviation Maintenance Tool Control Program. The article will provide a brief description of some of the required functional controls and the presentation of conditions where (a) accountability requires greater emphasis and (b) commercial practices are a more efficient way of doing business. BACKGROUND The Naval Aviation Maintenance Program (NAMP) is a five-volume directive mandated for use by all Naval Avia- tion Activities, including Commercial Contractors.
Vol- ume V Chapter 13 contains the details for ensuring con- trol of tools and loose consumable materials which if unac- counted for may contribute to or cause a flight safety con- sideration. All of our contracts utilize the NAMP as the baseline for Contractor Aviation Maintenance and allow for flexibility to adjust the process when cost and other fac- tors dictate. DEFINITIONS Tool: A generalized term referring to loose and hand tools, portable power tools and special purpose tools.
INFORMATION This contract has incorporated the FAR 45.5 Low Dollar Deviation. The ctools d provided by contract indi- vidually fit multiple classifications (Facilities and Materi- als) and because of pilferage considerations are often desig- ... more. less.
nated sensitive property prior to issue. REQUIREMENTS Under the NAMP Tool Control Program, there are numerous property management life-cycle functional con- trols.<br><br> The following reflects a brief description of just some of the NAMP tool control requirements: Management Develop written procedures following Chapter 13 Tool Control requirements Loss Damage or Destruction Perform thorough investigations to ensure missing or unac- counted for items are not in the aircraft or piece of support equipment.QC provides recommendations based upon results of investigations. Physical Inventories Quarterly tool container inventories conducted by work cen- ter tool representatives with tool control coordinator and results provided to work center supervisor. Work center supervisor performs physical inventory of all tool containers at the beginning and end of each shift and prior to operational checks and documents results.<br><br> By contract, there are approximately 52,000 tools and 322 tool containers provided as government furnished property. The Navy determined that furnishing these tools would help standardize the quality of maintenance. I don 9t quite understand the rationale that the government fur- nishing all property including common hand tools would standardize the quality of maintenance.<br><br> In any event, the government must ensure the contractor 9s tool control effort is maintained at an acceptable level of risk. A review of the NAMP requirements reflects similari- ties to those controls specified by FAR 45.5. There are requirements for management approved written proce- dures, loss, damage, destruction investigations, physical inventories and final dispositions.<br><br> In the next few para- graphs, I will discuss three of those areas where actual experience has found weaknesses in the process. If we review a provision from FAR 45.504(b) for example, the functional control requirements for lost or missing tools specified by the NAMP are clarified by FAR 45.5 as follows: Loss Damage or Destruction 45.504(b) The contractor shall investigate and report to the property administrator all cases of loss,damage or destruction of govern- ment property in its possession or control as soon as the facts are known or when requested by the property administrator. The NAMP emphasis of reporting and investigation of lost or missing tools or pieces thereof is solely for ensur- ing the item is not in the aircraft or piece of support NPMA 9 Volume 13, Issue 1 3 2001 © 2001 National Property Management Association Tool Control In Naval Aviation Maintenance A Discussion of Property Issues Affecting Flight Safety FREDERIC C.THOMPSON JR.CPPA,AUSTIN CHAPTER equipment.<br><br> The emphasis for the contractor is on preven- tion of Foreign Object Damage (FOD) and Flight Safety considerations. However, the process is incomplete in that conclusiveness of the lost or missing item investigation is questionable. An example of an investigation surrounding a missing droplight was that it was not in the aircraft or the in the area of use and the contractor 9s investigation was subsequently closed.<br><br> The emphasis of ensuring FOD free conditions and Flight Safety considerations completely bypassed the level of accountability required by FAR 45.5. By combining the FAR and the NAMP requirements, the contractor is then required to establish and maintain a Loss, Damage or Destruction Reporting system, not only to investigate but report and establish protective measures for related property until corrective action has been proven effective. Then the contractor would be in line with meet- ing all contractual accountability requirements.<br><br> Granted, the contractor investigation techniques should provide a standard where dollar value and/or type of item would require greater focus rather than spending excessive labor hours on investigation of low dollar and high consumption items. In order to perform efficiently and maintain effec- tiveness, the contractor should consider statistical sampling techniques to focus investigation attention except where Flight Safety and FOD are high risk. Loss, Damage or Destruction 45.504(a) The contractor may also be liable when the use or consump- tion of Government Property unreasonably exceeds the allowances provided for by the contract,the bill of material or other appropriate criteria.<br><br> From the consumption standpoint, the NAMP does not directly emphasize the use of minimum standards for determining a reasonable level of tool consumption. There are directions and emphasis for use of specific tools for spe- cific jobs as specified by maintenance manuals and other guiding directives. These directions, in most cases, essen- tially provide guidance as to utilization of the items.<br><br> How- ever, because of the common nature of the tools (i.e.; easily convertible to personal use), it is essential that the contrac- tor establish minimum acceptable standards for consump- tion and the methods for review and evaluation within the tool control procedures.. If we again review a provision from FAR 45.508 for example, the functional control requirements for physical inventories specified by the NAMP are clarified by FAR 45.5 as follows: Physical Inventories 45.508 The contractor shall periodically physically inventory all Gov- ernment property (except materials issued from stock for man- ufacturing, research, design, or other services required by the contract) in its possession or control and shall cause subcon- tractors to do likewise.The contractor,with the approval of the property administrator, shall establish the type, frequency, and procedures.These may include electronic reading,recording and reporting or other means of reporting the existence and loca- tion of the property and reconciling the records.Type and fre- quency of inventory should be based on the contractor 9s estab- lished practices,the type and use of the Government property involved,or the amount of Government property involved and its monetary value,and the reliability of the contractor 9s prop- erty control system.Type and frequency of physical inventories normally will not vary between contracts being performed by the contractor, but may vary with the types of property being controlled.Personnel who perform the physical inventory shall not be the same individuals who maintain the property records or have custody of the property unless the contractor 9s opera- tion is too small to do otherwise. Under the NAMP tool control program, physical inventories are performed for every item considered a tool, regardless of size, configuration or individual classification.<br><br> Keep in mind these tools are classified as sensitive prior to issue for use. Once the tools are issued to the tool contain- er or toolbox, primary visibility is reestablished by intense physical inventory performance and other controls defined by the NAMP. One of the primary requirements is for the work center supervisor to perform a physical inventory of every container in his custody at the beginning and end of each work shift and prior to operational checks.<br><br> There is also the requirement for physical inventory performance by the work center custodian 9s representative AND the tool control coordinator who maintains the master records every quarter. For example, the actual number of physical inventories required in twelve months for 322 toolboxes and containers for a single eight hour shift operation would be (322x2)*350+(322x4)=226,688 physical inven- tories. This of course would not include pre-operational check inventories.<br><br> If a toolbox contained 76 tools and 50 percent of the box population was small, consumable tools like screwdrivers and wrenches, inventory performance would appear to have heavier focus on materials issued from stock than more important emphasis. If there is con- siderable evidence of good inventory performance, the fre- quency cannot be reduced as provided by FAR 45.508 because of the mandated flight safety considerations. That is a tremendous amount of workload just in tool invento- ries!<br><br> It would seem more important and provide signifi- cantly more efficiency and value to stratify inventory per- formance for tools and containers where Flight Safety risk is lower based upon historical inventory performance. This of course would entail considerable training of personnel involved in the evaluation of tool consumption, the critical or non-critical nature of each loss, damage or destruction situation and resulting corrective action process and a complete revamping of physical inventory protocols focus- ing on reasonableness by evidence. The final details and action would then be to ensure there is sufficient and sub- stantial evidence to educate the Flight Customer to ensure they would be satisfied with this change prior to imple- mentation.<br><br> 10 NPMA © 2001 National Property Management Association Volume 13, Issue 1 3 2001 CONCLUSION The NAMP requirements for control of tools and loose consumable materials are well defined and sometimes too specific for contractor applications.. The Flight Cus- tomer relies heavily upon the use and compliance to NAMP requirements for their ultimate safety in the air. However, in these days of shrinking budgets and emphasis on business reengineering, there are control requirements for tools in the NAMP presently applicable to contractor aviation maintenance that are neither practical nor cost effective.<br><br> Control provisions such as those defined for Loss, Damage or Destruction, Consumption and Physical Inventories require more detailed examination to empha- size implementation of more cost effective and risk-based commercial practices. The dictation of a common sense, risk-based approach to common tool accountability in Avi- ation Maintenance must be attainable somehow. x (Views expressed are those of the author and do not necessarily reflect those of the Chief of Naval Air Training or the Department of the Navy) REFERENCES: Department of the Navy, Chief of Naval Operations (1998), OPNAVINST 4790.2G,Naval Aviation Maintenance Program Department of the Navy, Chief of Naval Operations (1989) OPNAVINST 10200.1,Policy Governing Tool Control Procedures General Services Administration, Department of Defense and the National Aeronautics and Space Administration (1999 Edition), Federal Acquisition Regulations,Washington D.C.- US Government Printing Office Joint Aeronautical Commanders Group - Commercial Support Subgroup (1999),Commercial Support of Defense Systems Section II Item IA7(c) Office of the Undersecretary of Defense Memorandum DP (DAR) 99-00008 13 Jul 99,Class Deviation from FAR 45 Frederic C.Thompson, Jr., CPPA, is the Property Administrator and Plant Clearance Officer for the Naval Air Training Command under the cog- nizance of the Chief of Naval Air Training in Corpus Christi,Texas.He has 23 years federal service, with 16 in Contract Property Management, primarily with Aviation Maintenance and Communication Support Service contracts.<br><br> He is a member of the Austin Chapter,South Texas Division,NPMA. NPMA 11 Volume 13, Issue 1 3 2001 © 2001 National Property Management Associatio n