Public Comments 2008-D003-C. Accetta

Technically, based on reading of the rule interpretations, DoD can expect to be supplied with anywhere from 100 per cent to zero per cent of fasteners manufactured from those defined specialty metals where the origin of melt is the USA or a qualifying country. The “50% Rule” does not guarantee anything in terms of how the DoD contracts will be provided. Manufacturers can certify that they will purchase 50% or more of certified origin specialty metals; most may choose to conform to that requirement. But, some of them won’t and the record- keeping required to assuage suspicion will be incredibly daunting for all participants. And while we’re picking at details, how about the defining unit of measure for this material? Is it weight or volume or dollars? What if a customer supplies the material? Does that count in either direction for the manufacturer’s annual totals? In spite of the details provided, this appears to have been poorly thought through from an execution standpoint. The “Buy America” sentiment has always appeared to be a well-intentioned attempt to protect the structure of our national industrial base and those supporting technologies from intrusion and disruption by outside market forces. However, it has never translated well to the component level of major defense projects and has often been a primary obstacle to the completion of such projects. The simplest solution seems to have eluded everyone involved in this process: The component in question needs to be above a certain dollar value for the clause to kick in. It certainly doesn’t benefit Carpenter Steel if the half-dozen MS51957-14s fastening the plastic lid to a junction box are or aren’t manufactured from DFARS-compliant 303 S/S. And it certainly doesn’t benefit any of us that this convoluted crazy-straw regulation is being taken in yet another direction. Please bring this mess back to the committee and try to remove the flaws, rather than just temporarily sweeping them out of sight. Charlie Accetta - General Manager Richard Manno & Co. 42 Lamar St. West Babylon, NY 11704 CAccetta@richardmanno.com 631-643-2200 ext 3023 631-643-2215 fax