Updates Clarify Quality Assurance Requirements for NASA Contracts
Updates to NASA Procedural Requirements (NPR) 8735.2B,
Management of Government Quality Assurance Functions for NASA Contracts went into effect on Aug. 12, 2013. The
changes include new allowances and requirements that reflect NASA’s current strategic vision, priorities and
resources.
NPR 8735.2B ensures that supplies and services acquired under government contract conform to the contract's quality
requirements.
Policy News Quick Facts
WHAT'S NEW
The following changes were made to the NPR:
1. The definition of “critical
acquisition item” was clarified with the inclusion of detailed qualifiers and
references to mission and payload classifications contained in other NASA documents. (See Section 2.1.1.)
WHY IT MATTERS
The categorization of critical acquisition items drives the level of government quality assurance to be performed.
While items that posed a credible risk of loss of human life or serious injury were always considered critical
acquisitions, the revised standard is more closely aligned with other NASA classifications of criticality.
RATIONALE
The revision makes the identification of critical acquisition items easier. Under the previous NPR, critical
acquisitions were defined qualitatively and it was not always clear what qualified as a critical item.
2. A note was added clarifying how Federal Acquisition
Regulation (FAR) Part 12 and Space Act Agreements constrain government quality assurance. (See Section 2.1.2 d.)
WHY IT MATTERS
Space Act Agreements and commercial acquisitions are not desirable ways of acquiring highly critical or complex items
because they generally do not allow for the necessary quality assurance functions outlined in Section 2.6 of this
NPR including product examinations, process witnessing and auditing functions.
RATIONALE
The previous NPR did not reflect these new, common ways of acquiring items. Language was needed to ensure
practitioners are aware of the limitations attached to these types of acquisitions.
3. New language explains NASA’s
options for assuring the quality of commercial items acquired under FAR Part 12.
(See Section 2.3.)
WHY IT MATTERS
The addition outlines what the government can do in commercial acquisitions despite the limitations set forth by FAR
Part 12, including third party certification, document reviews, record reviews, quality data analyses and final
acceptance inspections.
RATIONALE
Although FAR Part 12 prevents typical government quality assurance functions, some verification and review of
critical and complex items are permissible and should be completed.
4. A new section addresses Commercially Available
Off-the-Shelf (COTS) items. (See Section 2.4.)
WHY IT MATTERS
COTS items pose heightened quality risks and should generally be excluded from use in critical applications when
non-COTS supply sources are available, unless they meet high quality and reliability standards or are otherwise best
suited to meet NASA’s interests.
RATIONALE
Due to heightened risk, COTS purchases of critical items should be performed only as needed and carefully controlled.
5. A section on research and development
acquisitions was added, including specific quality system evaluations that must occur
at contractor facilities. (See Section 2.5.)
WHY IT MATTERS
When critical or complex research and development is occurring, the government must go to the contractor facility and
conduct quality reviews to ensure conformance to contract requirements.
RATIONALE
The previous version of the NPR did not outline these types of acquisitions or the necessary evaluations; such
clarifications were necessary for proper quality assurance.
6. The revised NPR provides exemptions to the
requirement to review a contractor’s quality system processes every three
years, at a minimum. (See Section 2.6.3.2.)
WHY IT MATTERS
Under the updated NPR, quality system evaluations may be postponed, exempted or limited in scope if certain risk
criteria are met.
RATIONALE
The exemptions provide cost savings in circumstances where there is high confidence that the contractor will supply
conforming products and such quality reviews are unnecessary.
7. The updated NPR requires the program, project, center
Safety and Mission Assurance (SMA) office, or delegated representatives of those offices to forward quality
system audit results involving findings against agency-wide standards to Supplier Assessment System
(SAS) administrators for posting to the SAS website. (See Section 2.6.3.5.)
WHY IT MATTERS
The new requirement will give centers agency-wide access to quality audits performed by other centers.
RATIONALE
The new requirement can potentially result in substantial cost savings by eliminating unnecessary and duplicate
audits.
8. Exceptions were added to the requirement
to perform Government Mandatory Inspection Points (GMIPs) for all safety-critical attributes. (See
Section 8.2.1.)
WHY IT MATTERS
In the past, the government had to verify every safety-critical attribute, no exceptions. The revision outlines
conditions that if met, allow GMIP exemptions.
RATIONALE
Verifying every safety-critical attribute is costly; the exemptions can save money without compromising technical
rigor or undertaking undue risk if conducted under carefully evaluated and controlled conditions.
TAKE ACTION
These changes affect all NASA programs and projects. Program and project managers should review the revised standard
and share it with their teams. Center SMA and Quality organizations involved with acquisitions also need to review
this document and work with program and project offices to effectively implement the changes.
Have questions on the updated NPR? Contact Brian Hughitt, NASA
technical fellow for Quality Engineering.