POGO recently obtained reports by the Defense Contract Management Agency (DCMA) asking contractors to fix serious "contractual nonconformities." The reports, which were obtained through the Freedom of Information Act (FOIA), are Level III Corrective Action Requests (CAR), given for "a serious nonconformity" or "repeat nonconformities found within one year."
There are four levels of CARS: Level I, the least serious, is "issued for a nonconformity that can be corrected on the spot." The most serious, Level IV, can result in "contractual remedies such as suspension of progress payments."
These kinds of issues are serious enough to warrant payment reductions by the government (a Level IV CAR can essentially shut down a project.) But according to experts, CARs aren't always taken as seriously as they should be.
POGO’s Winslow Wheeler said, “typically in the past [CARs] have been a slap on the wrist. Many months ago, DCMA warned Lockheed it was not up to snuff on its business management systems. The press covered it, but I don’t know how hard Lockheed actually tried to fix the issues.”
POGO contacted Lockheed Martin about the specific CAR reports we obtained, asking what action had been taken. Spokesman Jennifer Allen gave the following statement:
Lockheed Martin is committed to delivering high quality products and services to help our customers achieve their missions. We take responsibility for our performance in all of our decisions and actions and work closely with the DCMA to address any performance concerns in a timely manner.”
Want to check out all the CAR III reports for yourself? See below (parentheses show DCMA report date):
Excerpt: “On 03/21/2011, during the Preflight brief with the Navy Aircrew of aircraft 162314, it was discovered by records personnel that the main aircraft battery was installed in the aircraft was high time. The battery was due to be replaced on 12/06/2010. The release of the aircraft was delayed to install a serviceable battery.”
Excerpt: “Boeing failed to meet customer service expectations by failing to take timely action and implement effective containment in response to a Leve l III CAR. DCMA has repeatedly communicated concerns regarding Boeing’s inability to conduct containment and provide requested information. DCMA concerns were elevated to Boeing’s senior leadership resulting in minimal action or improvement.”
Excerpt: “Government Quality Assurance personnel discovered non conformances...conflicting quality control procedures and obsolete procedures.”
Excerpt: “Inadequate planning and/or non-conformances to BAE processes/procedures were identified during DCMA’s audit of BAE’s Quality Management System.”
Excerpt: “Contractor employees not following document procedures to include instructions and technical data.”
Excerpt: “This [CAR] results from BAE Systems’ failure to identify and control non-conforming material in a timely manner.”
Excerpt: “Boeing [failed] to control subcontractors in the procurement of titanium and [failed] to verify titanium supplier material certifications to specification requirements.”
Excerpt: “Over the past four months, several instances were discovered where Boeing failed to acquire controls and tools at suppliers resulting in numerous non compliances.”
Excerpt: “A CSC employee removed a Digital Electronic Control from an unserviceable [engine] and installed it on an [engine] belonging to a UH-60M aircraft without following the established control procedure…the aircraft was subsequently flown [without incident.]”
Excerpt: “The purpose of this request is to inform Ceradyne Inc. of serious conditions or actions that may affect material subject to Government Source Inspection.”
Excerpt: “Personnel assigned to this program have observed significant non-conformances, to include Safety of Flight deficiencies primarily involving [work] on CH-47 aircraft, which ultimately have been attributed to contractor employees improperly performing tasks.”
Excerpt: “Facility has incurred eight Level III CARs over the past seven years indicating a systematic failure to follow procedures.”
Excerpt: “This CAR and previous CARs that have been issued indicate a systematic problem in regard to 'Safe for Flight' that requires AECOM’s immediate attention.”
Excerpt: “BAE Systems failed to take timely action to identify and control nonconforming material. As a result, product was delivered with nonconforming parts…this part is used in both the Common Missile Warning System, Electronic Control Unit and the Advanced Threat Infrared Countermeasure.”
Excerpt: “Gages were found on the assembly floor…with a calibration sticker applied indicating calibration was due on 2/5/2010.”
Excerpt: “Four serviceable nacelles removed from [an aircraft] that should have been retained for future use were destroyed.”
Excerpt: “The quality assurance personnel assigned to this program have observed significant nonconformities during routine audits."
Excerpt: “This Level III CAR is the result of Lockheed Martin’s continuing failure to control documents related to the P-3 work effort…due to the critical nature of Safety of Flight items involved in these instances, we request you take aggressive and comprehensive actions to prevent recurrence.”
Dana Liebelson is POGO’s Beth Daley Impact Fellow.