Navy Marine Fuel Bunkering Proposal Compliance Review and Gaps

PWS-1.2(a)

Necessary crew and equipment to accomplish bunkering/de-bunkering

Discusses crew readiness, watchstanding, equipment status, readiness reviews

Partially Covered

Add minimum manning levels/roles (PIC, deck crew, hose team), certifications, and language capabilities as applicable.

PWS-1.2(b)

Licensed for F76 and F44(JP5); comply with Japanese safety/environment laws

Commits compliance; licensing; docs to be furnished

Covered

Add explicit list of applicable Japanese regulatory regimes/certificates held to reduce evaluator uncertainty.

PWS-1.2(c)

Appropriately coated tanks; comply with Appendix A; acceptable tank materials/coatings; prohibit copper/copper alloys

Affirms coatings; Appendix A; copper prohibition; configuration control; palm oil restriction screen

Covered

Add explicit statement tanks meet MIL-STD-3004-1C / Appendix A compatibility and cleanliness standards and how verified (inspection records).

PWS-1.2(d)

Capacity: 3x500kl + 3x300kl per task order; 2,400kl/day

Affirms and explains surge scheduling

Covered

Provide availability statement (e.g., dedicated vs. shared fleet) and contingency if a barge is down for maintenance.

PWS-1.2(e)

Suitable hoses; total hose length per operation ≤54m; extra hoses via CLIN

Affirms 54m limit; extra hoses rental when ordered; testing/inspection

Covered

Add metric/imperial conversion consistency and confirm hoses meet applicable pressure ratings/standards.

PWS-1.2(f)

Inspection and acceptance by Customer and CFAY Hakozaki fuel terminal prior to load/discharge

Commits to facilitate inspections and provide representative

Covered

Consider stating how access/entry safety will be managed for inspectors (permits, PPE, confined space protocols).

PWS-1.3(a)

Oral orders; performance commences when dispatched from ordinary mooring; provide vessel name and loading schedule prior to pre-loading; min 1000 bbl; pay min rules for <1000 bbl and <1500 bbl debunkering

Accurately restates dispatch definition; provides vessel ID/capacity/schedule; acknowledges min payment rules for 1000 and 1500

Covered

Add explicit linkage to delivery ticket time stamps to support disputes/detention/cancellation determinations.

PWS-1.3(b)

Detention: payable if >120 min; special rules for multi-day, multi-barge; no detention for certain times; no charge for severe weather

Explains timekeeping; acknowledges >120 min; multi-barge exclusions; severe weather no-charge

Partially Covered

Does not address ‘sunrise to sunset as per CFAYINST’ detention limitation explicitly; add explicit compliance statement.

PWS-1.3(c)

Cancellation rules and charge triggers by stage (before departure / after departure before loading / after pre-loading or after loading complete)

Explains cancellation distinctions and return charge interplay

Covered

Good; ensure pricing CLINs reflect per-job cancellation structure.

PWS-1.3(d)

Return charge: flat 1 job per CLIN; no return charge if continuous utilization for next evolution

Acknowledges and describes continuous utilization exception

Covered

Good.

PWS-1.3(e)

Oil boom service: install around entire vessel; keep absorbent/dispersant and spill-fighting resources on manned boat; remain in vicinity; remove upon completion; cancellation rules; donut fenders moving ops per (ii)

Describes oil boom install, manning, resources; fender moving and return

Covered

Add capability details: boom length/type, boat specs, typical install time, and inventory list.

PWS-1.3(f)

Extra hoses rental; still ≤54m per operation (base)

Addresses extra hoses CLIN and inspection/testing

Covered

OK.

PWS-1.3(g)

Oil/oily removal: commence immediately within boom; oil-retrieving boat; min 3 laborers; absorbents package spec; terminate immediately when directed; disposal per local law when ordered

Commits to immediate action; 3 laborers; absorbents; terminate on direction; disposal per law

Covered

Add explicit acknowledgement of absorbent package specification (100 sheets 65x65cm ~17kg) to mirror solicitation.

PWS-1.3(h)

Tank cleaning/gas freeing normally responsibility of Tank Cleaning Contractor; Govt may require contractor to clean tank if unclean/incorrect cargo provided per Appendix A

Mentions tank cleaning charges and gas-free condition; does not address responsibility split and Govt-directed cleaning trigger

Partially Covered

Add explicit statement acknowledging Govt right to direct tank cleaning if contractor provided unclean/incorrect cargo and contractor will comply per CLIN 0015/1015.

PWS-1.3(i)

Multiple bunkering: oral order; dispatched definition; load multiple ships/barges regardless of quantity with one order; return and cancellation apply; provide vessel name/capacity/schedule

Addresses multiple bunkering and dispatch definition; return/cancellation applicability

Covered

OK.

PWS-1.4(a)(i)

Comply with all Japanese laws/regulations including environmental for handling/storage/transport by water of petroleum products

Commits compliance; references Japanese laws and JEGS

Covered

Strong.

PWS-1.4(a)(ii)

Attend each fuel operation at place of delivery; coordinate; forward notices to FLC fuel terminal (commence/terminate/duration)

Commits to on-scene representative and forwarding notices

Covered

OK.

PWS-1.4(a)(iii)

Arrive clean, gas-free, ready for internal inspection at terminal or customer ship

Commits clean and gas-free condition; inspection readiness

Covered

OK.

PWS-1.4(a)(iv)

Provide effective connections: attachments, couplings, extra hoses, reducers with manifold pipes

States connection kits include couplings/reducers; manifold compatibility planning

Covered

OK.

PWS-1.4(a)(v)

Invoices issued to FLC fuel terminal by task order; include info per FAR 52.232-25 Prompt Payment

Mentions invoices/task order level and prompt payment; does not explicitly say ‘issue to FLC fuel terminal’ nor list required invoice data elements

Partially Covered

Add explicit ‘invoices will be issued to FLC fuel terminal per task order’ and include an invoice data checklist aligned to 5 CFR 1315.9(b)/FAR 52.212-4(g).

PWS-1.4(b)(i)-(iii)

Government responsibilities: issue orders; provide cargo; handle ship’s lines at dock

Not directly addressed

Not Required/Informational

No action needed unless proposal inadvertently contradicts.

PWS-1.6

Oil spills: commence removal/cleanup immediately; contractor liable if at fault; reimburse spilled fuel/property damage; comply with JEGS Ch 18 and Japanese Marine Pollution law

Commits to immediate cleanup; accepts liability; references JEGS Ch 18 and the law

Covered

Good.

PWS-1.5 berth/manifold variability

Berth constraints and manifold types vary; connection type varies by vessel class

Acknowledges manifold variability and berth constraints; planning for hose/manifold compatibility

Covered

OK.

0001/1001 Bunkering service

Transport and deliver fuel per PWS

Operational concept provided; min order acknowledged

Covered

No pricing shown in narrative; ensure schedule aligns with max quantities.

0002/1002 De-bunkering service

De-fuel transport/handling per PWS

Explains de-bunkering and 1,500 bbl min payable

Covered

Also note PWS 1.3(a)(v) says fuel offloads are customer responsibility; proposal doesn’t contradict.

0003/1003 Detention charge

Fixed detention charge rules

Timekeeping and rule awareness described

Partially Covered

Add ‘sunrise-to-sunset per CFAYINST’ limitation acknowledgment.

0004/1004 Cancellation (bunkering/de-bunkering)

Cancellation charges per PWS 1.3(c)

Rules described

Covered

OK.

0005/1005 Cancellation of oil boom service

Cancellation charges per PWS 1.3(e)

Mentions cancellation concepts; not explicit on this CLIN

Partially Covered

Add explicit statement that oil boom cancellation charges will be applied per PWS 1.3(e) and CLIN 0005/1005.

0006/1006 Return charge

Return freight flat fee rules

Rules described

Covered

OK.

0007/1007 Oil boom service

Install/remove boom; manned boat; resources

Described

Covered

OK.

0008/1008 Oil boom + donut fenders moving

Move two donut fenders and return

Described

Covered

OK.

0009/1009 Rental of extra hoses

Provide extra hoses when ordered

Described

Covered

OK.

0010-0012 / 1010-1012 Oil/oily removal by time band

Provide response actions per time-of-day rates

Describes service but not time bands

Partially Covered

Add acknowledgement that pricing varies by time band and contractor will track start/stop times to bill correct CLIN.

0013/1013 Disposal and absorbents

Dispose retrieved absorbents when ordered

Described

Covered

OK.

0014/1014 Cancellation of oil/oily removal

Cancellation charge

Mentions termination upon direction but not cancellation CLIN

Partially Covered

Add explicit alignment to cancellation CLIN 0014/1014 triggers.

0015/1015 Tank cleaning charge

Govt-directed cleaning if contractor provided unclean/incorrect cargo

Mentions tank cleaning charges generally

Partially Covered

Add explicit acceptance of Govt-directed tank cleaning scenarios per PWS 1.3(h)/Appendix A.

0016/1016 Multiple bunkering service

One order, multiple ships/barges

Described

Covered

OK.

0017 Minimum guarantee

Billable only if < $1,000 orders in first year

Acknowledges minimum guarantee concept

Partially Covered

Add explicit compliance statement on invoicing condition and timing.

ADM-01

Submit signed SF1449 cover page; complete blocks 17a and 30a–30c

States intention to submit signed SF1449 with blocks completed

Partially Covered

Add explicit confirmation ‘SF1449 attached and executed’ once final; ensure signer name/title/date included.

ADM-02

Acknowledge all amendments (SF30) if applicable

States acknowledgement of all amendments if issued

Partially Covered

Add a compliance matrix listing amendment numbers/dates (or ‘none issued as of submission date’).

ADM-03

Submission language: English or English translation

States quote submitted in English

Covered

Meets requirement.

ADM-04

Electronic submission via email to listed addresses; confirm receipt; 10MB email limitation

Not mentioned

Gap

Add a submission plan statement: file sizes, split emails, naming convention, and explicit ‘we will confirm receipt’.

ADM-05

Provide proposed unit price and maximum amount for all CLINs; totals for 0001-0017 and 1001-1016; grand total

States will provide unit prices and maximum amounts for all CLINs and totals

Partially Covered

Ensure pricing schedule is actually attached and matches CLIN max quantities/units (barrel/job/hour/meter/package/lot).

ADM-06

Provide three PPIs using Attachment II; one copy each; recency within 3 years

States will provide three PPIs within 3 years and similar scope

Partially Covered

Add a brief table summarizing the three references (customer, period, scope, magnitude, contact).

ADM-07

Provide financial data: latest balance sheet, P&L; completed Financial Information Data Sheet (Attachment III)

States will provide balance sheet, P&L, and Attachment III

Partially Covered

If possible, add a one-paragraph financial narrative (liquidity, ability to surge) tied to statements in attachments.

ADM-08

Technical quote must include formal vessel/barge spec sheet, Senpaku Meisai, and other official docs proving PWS 1.2(b)-(d) for all barges

States these documents will be included

Partially Covered

Add an index of included technical docs per barge (Doc name, issuing authority/date, what requirement it supports).

ADM-09

Clarification requests must be written (no verbal) and submitted by specified deadline

Not addressed

Gap

Add acknowledgment: ‘We will submit any questions in writing per RFQ instructions’ (optional but low effort).

ADM-10

Special note: sources must be duly authorized to operate and do business in Japan; may need immigration clearance evidence

States WOSB prime authorized in Japan and prepared to provide immigration/clearance documentation

Covered

Good; consider naming the Japanese registrations/licenses held (company registration, maritime operator registrations).

Oral order maximum value

No oral order > $350,000 (or lower if specified)

Not mentioned

Gap

Add explicit compliance statement and an internal control (e.g., ‘verify oral order value prior to acceptance’).

Delivery ticket with each shipment/performance

Provide delivery ticket in triplicate showing contract #, order #, date order placed, name/title of person placing order, itemized listing, unit price/extension, delivery/performance date

Mentions documentation/timekeeping but not delivery tickets or required data elements

Gap

High operational risk: add delivery ticket template/fields and commitment to triplicate ticket process.

Invoices accompanied by received copy of each delivery ticket

Invoice for oral orders must include received copy of delivery ticket

Not mentioned

Gap

Add procedure tying invoice package to signed/received delivery ticket copies.

Ordering activity will designate authorized oral order personnel in writing

Government will furnish list of authorized individuals

Proposal acknowledges ordering officer roles but not this control

Partially Covered

Add statement: ‘We will accept oral orders only from individuals designated in writing’.

Written confirmation timeline

Written confirmation within 10 working days or twice monthly consolidated

Proposal mentions later written task order confirmation but not timeline options

Partially Covered

Add explicit acknowledgement of 10-working-day/twice-monthly confirmation terms and how contractor will reconcile confirmations.

Order issuance methods (FAR 52.216-18)

Orders considered issued via mail/fax/electronic; other methods only if authorized

Not addressed

Gap

Optional but recommended: acknowledge acceptance of email/fax issuance per clause; specify contractor points of contact for receipt.

Minimum order limitation (FAR 52.216-19)

Gov not obligated <1,000 barrels; contractor not obligated to furnish under contract

Proposal states min barrels per order and compensation rules if below minimum

Partially Covered

Potential ambiguity: solicitation says Gov not obligated to buy <1,000; PWS says if ordered below, pay minimum. Add statement clarifying contractor will follow contract order limitation clause and coordinate if <1,000 is requested.

PAY-01

Payment by EFT (FAR 52.232-33); transaction fee deducted (JPY 735) and possible additional bank fees

Acknowledges EFT and transaction fee deduction

Covered

Good.

PAY-02

Invoice instructions provided at task order level

Acknowledges invoices/payment instructions at task order level

Covered

OK.

PAY-03

WAWF required for electronic submission of payment requests/receiving reports (DFARS 252.232-7003/7006), unless alternate method approved

Not mentioned

Gap

Add explicit WAWF readiness: SAM eBiz POC, WAWF registration status, and ability to submit Invoice 2-in-1 (for services) as directed per task order.

PAY-04

Prompt Payment invoice content requirements (52.212-4(g); 5 CFR 1315.9(b))

Mentions prompt payment generally; no explicit invoice element list

Partially Covered

Add invoice checklist: contract/order/CLIN, description, qty/unit, dates, acceptance, remittance, EFT info, etc.

PAY-05

Assignment of Claims (Overseas) potential (DFARS 252.232-7008 / FAR 52.212-4(c))

Not addressed

Gap (low)

If intending to assign payments, state approach; otherwise optional acknowledgement not required.

PAY-06

Economic Price Adjustment clause present (FAR 52.216-4)

Not addressed

Gap (low)

Optional: acknowledge understanding and process for notices/supporting data if seeking adjustment.

PAY-07

Tax relief / taxes on foreign procurements (DFARS 252.229-7001; FAR 52.229-11/12) and W-14 if foreign person

Not addressed

Gap

Add representation: whether company is a ‘foreign person’ for 26 USC 5000C; and if applicable, provide W-14 / tax handling statement.

PAY-08

Minimum guarantee CLIN 0017 conditions (invoice only if orders < $1,000 first year)

Acknowledges minimum guarantee CLIN structure generally

Partially Covered

Add explicit compliance: will invoice CLIN 0017 only under stated condition and only within first year.

Cybersecurity – Basic Safeguarding of Covered Contractor Information Systems (FAR 52.240-93)

Implement minimum controls for Federal Contract Information; flow down to subs

Not addressed

Gap

Add a cybersecurity compliance statement and high-level control summary; include subcontractor flowdown assurance.

CUI / OPSEC / Security access local text (SUPTXT204-9400)

CAC requirements, AT Level I training, OPSEC & CUI training, security representative designation within 3 work days, onboarding docs, interim access impacts

Not addressed

Gap (conditional)

Even if work is largely marine ops, personnel may access bases/terminals. Add a section stating applicability assumptions and readiness to comply (CAC processing, training certificates, security rep contact).

Antiterrorism/Force Protection outside US (DFARS 252.225-7043)

OSAC affiliation (if US entity), embassy registration, AT/FP guidance

Not addressed

Gap

Add compliance statement and how briefings/registration will be handled for deployed personnel.

Covered telecom prohibitions (FAR 52.204-26; DFARS 252.204-7018) and ByteDance app prohibition (FAR 52.204-27)

Must not use/provide prohibited telecom/video surveillance; ByteDance covered apps prohibition

Not addressed

Gap

Add representations consistent with SAM reps and internal policy (especially if using comms equipment onboard).

NIST SP 800-171 DoD Assessment (DFARS 252.204-7020) & Safeguarding CDI (252.204-7012)

Assessment requirements and incident reporting if handling CDI/CUI

Not addressed

Gap (conditional)

State whether CDI/CUI is expected; if yes, provide compliance posture (SPRS score/assessment, incident reporting plan).

Subcontracting with debarred/suspended entities (FAR 52.209-6)

Do not subcontract over threshold with excluded parties; disclosure/CO notification

Not addressed (only mentions awareness)

Partially Covered

Add a subcontractor vetting process: SAM exclusion checks, written disclosures, CO notification procedure.

Contractor Code of Business Ethics and Conduct (FAR 52.203-13) & related whistleblower clauses

Ethics program, internal controls, disclosure

Not addressed

Gap

Add brief ethics/compliance program summary and reporting channels.

Texting while driving policy encouragement (FAR 52.226-8)

Encourage policies banning texting while driving

Not addressed

Gap (low)

Add a one-line policy statement covering vehicle/boat operations where applicable.

Trade Agreements / country of origin certificates (DFARS 252.225-7021 etc.)

Applies to end products where relevant

Not addressed

Gap (low/unclear)

Likely minimal for services; if providing materials/equipment, state sourcing compliance or that not applicable.

Reporting requirements for contracted services (DFARS 252.204-7023 Alt I)

Annual service contract reporting in SAM when thresholds met

Not addressed

Gap (conditional)

Add acknowledgement of service reporting obligations and responsible role in company.

AbilityOne release of offeror info (SUPTXT203.1106-1)

Consent to release proprietary info to AbilityOne support contractor

Not addressed

Gap

Add acknowledgement/consent statement (or note you will comply by submission; but explicit helps).

Japanese conciliation procedures (SUPTXT225-9401)

Dispute conciliation via US-Japan Joint Committee after CO decision

Not addressed

Gap (low)

Optional acknowledgement; usually not evaluated but can be included in contract compliance section.

Acquisition type & vehicle

Commercial services; Performance-based; IDIQ single-award; FFP CLINs; ordering per FAR 52.216-18/19/22

States IDIQ single-award; FFP line items; ordering by oral order with written task order confirmation; cites FAR 52.212-4, 52.216-18/19/22

Covered

Good framing; ensure no misstatements of ordering procedures (see oral order cap and delivery ticket requirements).

Period of performance

10 Apr 2026–09 Apr 2028; Base Year I/II

Matches dates and base year structure

Covered

Accurate.

Evaluation factors & weighting

Technical capabilities >> Price >> Past performance; technical gate: PWS 1.2(b)(c)(d)

Explicitly acknowledges technical gate and ineligibility risk; organizes narrative to show compliance

Covered

Strong evaluator-friendly statement.

Technical gate: PWS 1.2(b) licensing & compliance with Japanese laws

Must be licensed for NATO F76 and F44(JP5) and comply with Japanese safety/environment laws

Commits that barges are licensed for clean products incl. F76/JP5; will furnish Senpaku Meisai; commits compliance with Japanese laws

Covered

Add explicit statement that licensing specifically covers NATO F44 (JP5) (they say F44 (JP5) earlier, later ‘F44’ implied).

Technical gate: PWS 1.2(c) tank coating/Appendix A/copper prohibition

Appropriately coated; comply with Appendix A (MIL-STD-3004-1C); acceptable tank materials; no copper/copper alloys

States coated tanks prepared to comply with Appendix A; acknowledges and controls copper/copper alloys prohibition; mentions palm oil restriction

Covered

Would benefit from citing MIL-STD-3004-1C explicitly and providing objective tank material/coating descriptions per barge.

Technical gate: PWS 1.2(d) capacity to provide 3x500kl + 3x300kl per task order (2,400kl/day)

Must be capable of equivalent capacity per task order

States capability and scheduling concept; will substantiate via spec sheets

Covered

Add specific hull IDs/capacities and how many simultaneously available (not just ‘equivalent to’).

R-01

Quote deemed administratively incomplete

Missing explicit submission mechanics (email size limits, receipt confirmation) and missing explicit attachments/index

Medium

Medium

Add a compliance checklist and attachment index; include submission plan and confirmation process.

R-02

Oral order noncompliance leading to payment disputes

No delivery ticket triplicate process; no invoice-delivery ticket linkage; no oral order $350k control

High

High

Add SOP and templates for delivery tickets; internal verification of ordering authority and dollar cap; tie to invoicing package.

R-03

Cyber/security clause noncompliance discovered post-award

No statements on FAR 52.240-93, telecom prohibitions, local security/CAC/training, DFARS cyber clauses

Medium

High

Add clause compliance section; identify security representative; describe training/cyber controls and flowdowns.

R-04

Detention billing disputes

Sunrise-to-sunset detention limitation not explicitly acknowledged; time-band CLINs not operationalized

Medium

Medium

Explicitly incorporate CFAYINST sunrise-to-sunset rule; implement time-band tracking and logs mapped to CLINs.

R-05

Tank cleaning responsibility misunderstanding

Does not clearly acknowledge Govt right to direct tank cleaning if contractor fault (unclean/incorrect cargo)

Medium

Medium

Add explicit acceptance of PWS 1.3(h) scenario and corrective action process.

R-06

Evaluation uncertainty on capacity proof

Narrative says ‘equivalent to’ but does not enumerate actual barges and availability

Medium

High

Provide a fleet table with barge IDs, tank capacities, certifications, and availability/backup plan; attach supporting official docs.

R-07

Subcontractor compliance risk

No subcontractor vetting/flowdown process described for exclusions and safeguarding

Low-Medium

Medium

Add subcontractor management plan: SAM checks, flowdowns, and documentation retention.

High

Add an ‘Oral Order Compliance’ appendix with (1) $350,000 oral order cap control, (2) acceptance only from authorized ordering officials list, (3) delivery ticket (triplicate) template containing all required fields, and (4) invoice package requirement to include received delivery ticket copy.

SUPTXT 216-9402 Oral Orders (a)-(e)

Reduces high-risk payment/admin disputes; demonstrates operational maturity and compliance.

High

Add a ‘WAWF & Invoicing’ section stating WAWF registration status, SAM eBiz POC, ability to submit Invoice 2-in-1 or other document type as directed, and include an invoice data-element checklist aligned to FAR 52.212-4(g)/5 CFR 1315.9(b).

DFARS 252.232-7003/7006; FAR 52.212-4(g)

Improves payment compliance and evaluator confidence.

High

Include a fleet compliance table for each proposed barge/vessel: name/ID, tank capacity (kl), product licensing (F76/F44 JP5), tank material/coating type, copper-alloy compliance statement, last cargo history (incl. palm oil screening), hose inventory/length, and attached document references (Senpaku Meisai, spec sheets).

PWS 1.2(b)-(d); Appendix A; palm oil note

Makes gate technical compliance quickly verifiable; lowers ‘uncertified’ risk.

High

Add a clause compliance matrix covering at minimum: FAR 52.240-93 (basic safeguarding), FAR 52.204-26/27 (telecom/ByteDance), DFARS 252.204-7012/7020 (if applicable), DFARS 252.225-7043 (AT/FP), and AbilityOne release text acknowledgement.

Multiple clauses/local texts

Prevents ‘silent noncompliance’ concerns and strengthens responsibility determination.

Medium

Explicitly acknowledge detention limitation ‘outside sunrise to sunset per CFAYINST no detention assessed’ and implement log fields to track detention start/stop consistent with multi-barge rules.

PWS 1.3(b)(iii)

Reduces billing ambiguity and disputes.

Medium

Address PWS 1.3(h) explicitly: normal tank cleaning responsibility, and acceptance of Government-directed tank cleaning when contractor provided unclean/incorrect cargo; describe corrective action and documentation for acceptance.

PWS 1.3(h); Appendix A

Clarifies liability and readiness to comply with corrective actions.

Medium

Add time-band operational procedures for oil/oily substance removal (0800-1700; 0600-0800/1700-2200; 2200-0600) to ensure correct CLIN billing and staffing availability.

CLINs 0010-0012 / 1010-1012

Improves pricing/operational alignment and reduces invoicing errors.

Medium

Expand crew readiness details: minimum manning for bunkering/boom/removal boat; training program; emergency roles; language/communications plan; fatigue management specifics.

PWS 1.2(a); 1.3(e); 1.6

Strengthens technical narrative beyond restating requirements.

Low

Add explicit compliance statement for minimum guarantee CLIN 0017 invoicing conditions (only if orders < USD 1,000 in first year; BER conversion).

CLIN 0017; BER note

Avoids misunderstanding on billing rights/limitations.

Low

Add subcontractor governance statement: SAM exclusion checks, flowdown of safeguarding clause, and notification to CO if any excluded subcontractor is contemplated.

FAR 52.209-6; FAR 52.240-93(c)

Improves responsibility posture and reduces compliance risk.