Policy Changes Affecting Safety and Health Plans to Result in Cost Savings
Changes to NASA Federal Acquisition Regulation Supplement (NFS) 1852.223-73 will make NASA’s proposal review process quicker and more efficient. The requirement changes permit companies competing for low-cost and administrative contracts with minimal hazards to submit Safety and Health Plans after the contract is awarded.
Safety and Health Plans provide NASA personnel who review contract negotiations with information on how contractors handle safety within their organization and how they would address safety in the context of the contracted work.
“We get a feel for how they view safety within their organization,” said Gerry Schumann, institutional safety program manager at NASA Headquarters’ Office of Safety and Mission Assurance. “Is it a number one priority? Is it inadequate or is it above and beyond?”
Prior to the change, all companies bidding on a contract were required to submit Safety and Health plans, which were expected to be site-specific and fairly elaborate whether the contract was for a simple, low-risk administrative task or for hazardous operations. Once the NFS changes are implemented, only the awarded company will submit a plan for contracts involving minor operations. However, the plan still must be submitted and approved by NASA reviewing officials before work begins.
Delaying the submission of these plans until the contract is awarded significantly reduces the paperwork necessary to bid on a contract, making NASA’s review process for proposals quicker and easier. This results in cost and time savings for both contractors and NASA. The change comes as a direct result of the Paperwork Reduction Act, which tasked NASA with reducing the amount of paper required for a contract to be levied.
“It will take less time to review all the paperwork and shorten the approval process for what is submitted,” explained Schumann. “It also will take fewer resources to approve a plan, because we’re no longer reviewing one for every bidding company.”
Contracts involving hazardous operations will continue to require Safety and Health Plans from all contractors during the bidding phase due to the potential for injury to personnel.
The updated supplement is still in the final stages of the review process, but in the meantime contractors competing for low-cost and administrative contracts with minimal hazards can submit waivers to postpone the submission of a Safety and Health Plan until the contract is awarded.