Tool Control In
Naval Aviation Maintenance
A Discussion of Property Issues Affecting Flight Safety
FREDERIC C. THOMPSON JR. CPPA, AUSTIN CHAPTER
INTRODUCTION
Loss Damage or Destruction
This article discusses a complex, yet controversial
group of process controls required for the accountability of
tools as prescribed by the Naval Aviation Maintenance
Tool Control Program. The article will provide a brief
description of some of the required functional controls and
the presentation of conditions where (a) accountability
requires greater emphasis and (b) commercial practices are
a more efficient way of doing business.
Physical Inventories
BACKGROUND
The Naval Aviation Maintenance Program (NAMP) is
a five-volume directive mandated for use by all Naval Aviation Activities, including Commercial Contractors. Volume V Chapter 13 contains the details for ensuring control of tools and loose consumable materials which if unaccounted for may contribute to or cause a flight safety consideration. All of our contracts utilize the NAMP as the
baseline for Contractor Aviation Maintenance and allow
for flexibility to adjust the process when cost and other factors dictate.
DEFINITIONS
Tool: A generalized term referring to loose and hand
tools, portable power tools and special purpose tools.
INFORMATION
This contract has incorporated the FAR 45.5 Low
Dollar Deviation. The “tools” provided by contract individually fit multiple classifications (Facilities and Materials) and because of pilferage considerations are often designated sensitive property prior to issue.
Quarterly tool container inventories conducted by work center tool representatives with tool control coordinator and
results provided to work center supervisor.
Work center supervisor performs physical inventory of all tool
containers at the beginning and end of each shift and prior to
operational checks and documents results.
By contract, there are approximately 52,000 tools and
322 tool containers provided as government furnished
property. The Navy determined that furnishing these tools
would help standardize the quality of maintenance. I don’t
quite understand the rationale that the government furnishing all property including common hand tools would
standardize the quality of maintenance. In any event, the
government must ensure the contractor’s tool control
effort is maintained at an acceptable level of risk.
A review of the NAMP requirements reflects similarities to those controls specified by FAR 45.5. There are
requirements for management approved written procedures, loss, damage, destruction investigations, physical
inventories and final dispositions. In the next few paragraphs, I will discuss three of those areas where actual
experience has found weaknesses in the process.
If we review a provision from FAR 45.504(b) for
example, the functional control requirements for lost or
missing tools specified by the NAMP are clarified by FAR
45.5 as follows:
Loss Damage or Destruction 45.504(b)
REQUIREMENTS
Under the NAMP Tool Control Program, there are
numerous property management life-cycle functional controls. The following reflects a brief description of just some
of the NAMP tool control requirements:
Management
Develop written procedures following Chapter 13 Tool Control
requirements
Volume 13, Issue 1 – 2001
Perform thorough investigations to ensure missing or unaccounted for items are not in the aircraft or piece of support
equipment. QC provides recommendations based upon results
of investigations.
The contractor shall investigate and report to the property
administrator all cases of loss, damage or destruction of government property in its possession or control as soon as the facts
are known or when requested by the property administrator.
The NAMP emphasis of reporting and investigation
of lost or missing tools or pieces thereof is solely for ensuring the item is not in the aircraft or piece of support
© 2001 National Property Management Association
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equipment. The emphasis for the contractor is on prevention of Foreign Object Damage (FOD) and Flight Safety
considerations. However, the process is incomplete in that
conclusiveness of the lost or missing item investigation is
questionable. An example of an investigation surrounding
a missing droplight was that it was not in the aircraft or
the in the area of use and the contractor’s investigation was
subsequently closed. The emphasis of ensuring FOD free
conditions and Flight Safety considerations completely
bypassed the level of accountability required by FAR 45.5.
By combining the FAR and the NAMP requirements, the
contractor is then required to establish and maintain a
Loss, Damage or Destruction Reporting system, not only
to investigate but report and establish protective measures
for related property until corrective action has been proven
effective. Then the contractor would be in line with meeting all contractual accountability requirements. Granted,
the contractor investigation techniques should provide a
standard where dollar value and/or type of item would
require greater focus rather than spending excessive labor
hours on investigation of low dollar and high consumption
items. In order to perform efficiently and maintain effectiveness, the contractor should consider statistical sampling
techniques to focus investigation attention except where
Flight Safety and FOD are high risk.
Loss, Damage or Destruction 45.504(a)
The contractor may also be liable when the use or consumption of Government Property unreasonably exceeds the
allowances provided for by the contract, the bill of material or
other appropriate criteria.
From the consumption standpoint, the NAMP does
not directly emphasize the use of minimum standards for
determining a reasonable level of tool consumption. There
are directions and emphasis for use of specific tools for specific jobs as specified by maintenance manuals and other
guiding directives. These directions, in most cases, essentially provide guidance as to utilization of the items. However, because of the common nature of the tools (i.e.; easily
convertible to personal use), it is essential that the contractor establish minimum acceptable standards for consumption and the methods for review and evaluation within the
tool control procedures..
If we again review a provision from FAR 45.508 for
example, the functional control requirements for physical
inventories specified by the NAMP are clarified by FAR
45.5 as follows:
Physical Inventories 45.508
The contractor shall periodically physically inventory all Government property (except materials issued from stock for manufacturing, research, design, or other services required by the
contract) in its possession or control and shall cause subcontractors to do likewise.The contractor, with the approval of the
property administrator, shall establish the type, frequency, and
procedures.These may include electronic reading, recording and
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reporting or other means of reporting the existence and location of the property and reconciling the records. Type and frequency of inventory should be based on the contractor’s established practices, the type and use of the Government property
involved, or the amount of Government property involved and
its monetary value, and the reliability of the contractor’s property control system. Type and frequency of physical inventories
normally will not vary between contracts being performed by
the contractor, but may vary with the types of property being
controlled. Personnel who perform the physical inventory shall
not be the same individuals who maintain the property records
or have custody of the property unless the contractor’s operation is too small to do otherwise.
Under the NAMP tool control program, physical
inventories are performed for every item considered a tool,
regardless of size, configuration or individual classification.
Keep in mind these tools are classified as sensitive prior to
issue for use. Once the tools are issued to the tool container or toolbox, primary visibility is reestablished by intense
physical inventory performance and other controls defined
by the NAMP. One of the primary requirements is for the
work center supervisor to perform a physical inventory of
every container in his custody at the beginning and end of
each work shift and prior to operational checks. There is
also the requirement for physical inventory performance
by the work center custodian’s representative AND the tool
control coordinator who maintains the master records
every quarter. For example, the actual number of physical
inventories required in twelve months for 322 toolboxes
and containers for a single eight hour shift operation
would be (322x2)*350+(322x4)=226,688 physical inventories. This of course would not include pre-operational
check inventories. If a toolbox contained 76 tools and 50
percent of the box population was small, consumable tools
like screwdrivers and wrenches, inventory performance
would appear to have heavier focus on materials issued
from stock than more important emphasis. If there is considerable evidence of good inventory performance, the frequency cannot be reduced as provided by FAR 45.508
because of the mandated flight safety considerations. That
is a tremendous amount of workload just in tool inventories! It would seem more important and provide significantly more efficiency and value to stratify inventory performance for tools and containers where Flight Safety risk
is lower based upon historical inventory performance. This
of course would entail considerable training of personnel
involved in the evaluation of tool consumption, the critical
or non-critical nature of each loss, damage or destruction
situation and resulting corrective action process and a
complete revamping of physical inventory protocols focusing on reasonableness by evidence. The final details and
action would then be to ensure there is sufficient and substantial evidence to educate the Flight Customer to ensure
they would be satisfied with this change prior to implementation.
© 2001 National Property Management Association
Volume 13, Issue 1 – 2001
CONCLUSION
The NAMP requirements for control of tools and
loose consumable materials are well defined and sometimes
too specific for contractor applications.. The Flight Customer relies heavily upon the use and compliance to
NAMP requirements for their ultimate safety in the air.
However, in these days of shrinking budgets and emphasis
on business reengineering, there are control requirements
for tools in the NAMP presently applicable to contractor
aviation maintenance that are neither practical nor cost
effective. Control provisions such as those defined for Loss,
Damage or Destruction, Consumption and Physical
Inventories require more detailed examination to emphasize implementation of more cost effective and risk-based
commercial practices. The dictation of a common sense,
risk-based approach to common tool accountability in Aviation Maintenance must be attainable somehow. ◆
(Views expressed are those of the author and do not necessarily
reflect those of the Chief of Naval Air Training or the Department of
the Navy)
Volume 13, Issue 1 – 2001
REFERENCES:
Department of the Navy, Chief of Naval Operations (1998), OPNAVINST
4790.2G, Naval Aviation Maintenance Program
Department of the Navy, Chief of Naval Operations (1989) OPNAVINST
10200.1, Policy Governing Tool Control Procedures
General Services Administration, Department of Defense and the National
Aeronautics and Space Administration (1999 Edition), Federal Acquisition
Regulations,Washington D.C. - US Government Printing Office
Joint Aeronautical Commanders Group - Commercial Support Subgroup
(1999), Commercial Support of Defense Systems Section II Item IA7(c)
Office of the Undersecretary of Defense Memorandum DP (DAR) 99-00008
13 Jul 99, Class Deviation from FAR 45
Frederic C. Thompson, Jr., CPPA, is the Property Administrator and
Plant Clearance Officer for the Naval Air Training Command under the cognizance of the Chief of Naval Air Training in Corpus Christi,Texas. He has 23
years federal service, with 16 in Contract Property Management, primarily
with Aviation Maintenance and Communication Support Service contracts.
He is a member of the Austin Chapter, South Texas Division, NPMA.
© 2001 National Property Management Association
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