You get a job to quote and one of the requirements stated is for all material to be DFARS compliant. You ask yourself; what is DFARS? Piping Supplies Inc has been machining parts for the US Navy for over 50 years. Here is what we know.
FARS is one of the millions of US government anacronyms which stands for Federal Acquisition Regulation. DFARS is the Defense Federal Acquisition Regulation Supplement. The defense supplement was added to meet the higher-level guidelines needed for our national defense. DFARS is a document with broad scope. It addresses everything from the source of materials you can use to the ways you can communicate data, like prints, for a contract.
The purpose of DFARS is to protect the US supply chain from relying on critical foreign sourced materials. There are two main points to remember when DFARS compliance is required: where does the material come from and what type of material is it. Specialty metals are restricted but not all metals are considered specialty metals. DFARS defines specialty metals as:
- Steel with certain maximum alloy content
- Metal containing more than 0.25 percent of any of the following elements: aluminum, chromium, cobalt, columbium, molybdenum, nickel, titanium, tungsten, or vanadium
- Metal alloys consisting of nickel, iron-nickel
- Cobalt base alloys containing a total of other alloying metals (except iron) of more than 10 percent
- Titanium and titanium alloys.
- Zirconium and zirconium base alloys.
In addition, the Department of Defense prohibits the purchase of certain magnets and tungsten from North Korea, China, Russia, and Iran through an amendment to DFARS.
There are exceptions to the DFARS Specialty Metals rule, including:
- As required in the interest of national security.
- When specialty metals are not available in sufficient quantities, in the necessary form, or cannot be acquired when they are needed.
- When the acquisition supports U.S. combat or contingency operations.
- When necessary to complete an agreement with a foreign government.
- When used in small purchases.
- When used in off-the-shelf commercial items.
- When used in some electrical components.
Otherwise, non-compliant metal is permitted if it makes up no more than two percent of the final product.
DFAR material must be purchased from a “Qualifying country”. This means a country with a reciprocal defense procurement memorandum of understanding or international agreement with the United States in which both countries agree to remove barriers to purchases of supplies produced in the other country or services performed by sources of the other country, and the memorandum or agreement complies, where applicable, with the requirements of section 36 of the Arms Export Control Act (22 U.S.C. 2776) and with 10 U.S.C. 2457. Whew! The following are qualifying countries: Australia, Austria, Belgium, Canada, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Germany, Greece, Israel, Italy, Japan, Latvia, Luxembourg, Netherlands, Norway, Poland, Portugal, Slovenia, Spain, Sweden, Switzerland, Turkey, United Kingdom of Great Britain and Northern Ireland.
Now this is a lot to take in and we have not gotten into the restrictions on how you can exchange information about a DFAR compliant contract. That is the topic for another day.