Corrective Action Requests (CARs)

CORRECTIVE ACTION REQUESTS (CARS)

DCMA NSEO has a policy that when nonconformities associated with a supplier's Quality Management System (QMS), processes or product characteristics are independently discovered by DCMA, the supplier shall be notified and requested to initiate corrective actions in accordance with the contract requirements. Product or process nonconformities may be evidence of a breakdown in the supplier's QMS or inspection systems.

FAR 46.105(a) states that the contractor is responsible for carrying out its obligations under the contract by (1) controlling the quality of supplies, and (2) tendering to the Government for acceptance only those supplies that conform to the contract requirements.

FAR 46.106 states that when a contract is assigned for administration to the contract administration office cognizant of the contractor's plant, that office, unless specified otherwise, shall perform all actions necessary to verify whether the supplies or services conform to the contract quality requirements.

There are four levels of Corrective Action Requests (CARs) that depend on the severity of the nonconformity, and the level of supplier management visibility required to adequately address corrective actions. CARs can be issued by any DCMA NSEO functional specialist to include the QAR, Industrial Specialist (IS), and the Administrative Contracting Officer (ACO).

• Level I CARs are issued to the supplier management level responsible for taking corrective actions for a nonconformity that can be corrected on the spot, and where no further corrective action response is necessary.
• Level II CARs are the minimum level for a nonconformity associated with critical characteristics. They are issued to the supplier management level responsible for initiating corrective actions when the contractual nonconformity cannot be corrected on the spot. Level II CARs may be issued to subcontractors, and may be coupled with contractual remedies such as charge for additional cost of inspection or test when prior rejection makes reinspection or retest necessary. The purpose of a Level II CAR is to help a supplier improve their QMS.
• Level III CARs are issued to the supplier's top management for serious contractual nonconformities, failure to respond to a Level II CAR that has been issued, and repeat Level II CARs which indicates inadequate root cause determinations. Level III CARs are issued by the DCMA NSEO ACO and may be coupled with contractual remedies to include reduction of progress payments, cost disallowances, business management systems disapprovals, and charge for additional cost of inspection or test when prior rejection makes reinspection or retest necessary. A Level III CAR is the DCMA NSEO Commander's management tool to correct issues that need to be addressed.
• Level IV CARs are issued to the supplier's top management when a Level III CAR has been ineffective and when the contractual nonconformity is of a serious nature. Level IV CARs are issued by the DCMA NSEO ACO and may be coupled with contractual remedies to include suspension of progress payments, suspension of product acceptance activities, removal of QAR from facility, and charge for additional cost of inspection or test when prior rejection makes reinspection or retest necessary.

The supplier's response to the CAR should (1) identify the causes of the nonconformity to include the root cause(s) and casual factors; (2) state the actions taken to correct the specific nonconformity; (3) state the actions taken or planned to eliminate the cause(s) and prevent recurrence of the nonconformity; (4) state whether other products are affected, including product already delivered to the customer; (5) state action taken to correct the weakness which allowed deficient product to be presented to the government for acceptance; and (6) state the target date(s) for implementation of planned actions.

DCMA NSEO will review the supplier's corrective action response; verify implementation of the corrective action, and follow-up to validate the effectiveness of the corrective action. If the supplier's corrective action is ineffective, then the corrective action request is resubmitted to the supplier. If the supplier's corrective action is effective then the CAR is closed. The overall objective of the CAR process is to reduce the number of PQDRs.