BNUMBER:  B-265934; B-265934.2
DATE:  January 19, 1996
TITLE:  Metfab Engineering, Inc.; Mart Corporation

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Matter of:Metfab Engineering, Inc.; Mart Corporation

File:     B-265934; B-265934.2

Date:     January 19, 1996

John T. Rego, for Metfab Engineering Inc.; and Michael Curth, and Gary 
Minkin, for The Mart Corporation, the protesters.
Lee Curtis, Esq., and Jerone C. Cecelic, Esq., Howrey & Simon, for 
Better Engineering Manufacturing, Inc., an interested party.
Timothy Lasko, Esq., Department of the Navy, for the agency.
Marie Penny Ahearn, Esq., David A. Ashen, Esq., and John M. Melody, 
Esq., Office of the General Counsel, GAO, participated in the 
preparation of the decision.

DIGEST

1.  Protest that request for proposals (RFP) for brand name or equal 
commercial aircraft parts washers contains insufficient detail on 
required preproduction testing examinations to enable the protester to 
compete intelligently is denied where the examinations either are 
based on the salient characteristics set forth in the RFP or concern 
areas, such as accessibility, about which a commercial vendor should 
understand what would be required.

2.  Protest alleging noncompliance of the awardee's brand name product 
with stated salient characteristics, which required modification of 
brand name product for compliance, is denied where record demonstrates 
that agency reasonably determined compliance based on the 
representation in the awardee's proposal.

DECISION

Metfab Engineering, Inc. protests certain specifications and Mart 
Corporation protests the award of a contract to Better Engineering 
Manufacturing, Inc., under request for proposals (RFP) No. 
N68335-95-R-0185, issued by the Department of the Navy for commercial, 
off-the-shelf, brand name or equal, large aqueous parts washers, used 
in the degreasing of aircraft parts.  Metfab argues that the 
specification provisions with respect to the required post-award, 
preproduction testing are vague so as to preclude competition on a 
common basis.  Mart asserts that Better Engineering's proposed parts 
washer did not meet the stated salient characteristics.  

We deny the protests.

BACKGROUND

The RFP, specifying Better Engineering model F-4000-P or equal, 
required offerors to propose "commercial items," that is, "items 
regularly used in the course of normal business operations."  See 
Defense Federal Acquisition Regulation Supplement (DFARS)  sec.  
252.211-7012(b)(1).  Offerors were required to describe in their 
proposals compliance with the listed salient characteristics and to 
include descriptive literature establishing details of the products 
offered which were pertinent to significant elements such as design, 
performance characteristics, and operation.  Proposals were to be 
evaluated on a pass/fail basis for compliance with the "performance 
specification." 

The Navy received six offers.  Award was made to Better Engineering as 
the lowest-priced technically acceptable offeror.  

METFAB'S PROTEST

Metfab argues that the solicitation provisions for contractor 
preproduction (post-award) testing provided insufficient detail for 
intelligent competition on an equal basis.

Generally, the RFP provided that the contractor is to submit a 
preproduction test plan after award, for review and approval by the 
government.  Once the plan is approved, preproduction testing is to be 
conducted by the contractor on two units at its own expense; test 
results are to be submitted to the government for approval.  The 
required preproduction testing includes operational tests "to evaluate 
safe operation of all controls, components, and safety devices" and 
"[f]it and placement of components, and equipment weight and 
dimensions"; "[s]pecial concern [is to be given to] any unforeseen 
operational anomalies affecting safe performance."   The preproduction 
test required the following examinations:  (1) completeness; (2) 
nameplates and identification; (3) alignment and tightness; (4) 
finish; (5) fit and placement of components; (6) ease of operations, 
switches, and controls; (7) equipment weight and dimensions; (8) 
accessibility of components and parts; (9) power cord; and (10) safety 
examinations/instructions.  

Metfab complains that the solicitation did not include "specific and 
complete requirements and test parameters" for the preproduction test 
examinations, and that such detail was required to assure fair and 
equal competition.  

Where a DOD agency intends to acquire a commercial item, it is 
obligated to describe the item in a way that identifies the agency's 
needs with sufficient detail and clarity so that all offerors have a 
common understanding of what is required under the contract in order 
that they can compete intelligently on a relatively equal basis.  
Adventure Tech, Inc., B-253520, Sept. 29, 1993, 93-2 CPD  para.  202, aff'd, 
Adventure Tech, Inc.--Recon. and Entitlement to Costs, B-253520.2; 
B-253520.3, Feb. 9, 1994, 94-1 CPD  para.  105; see Automated Power Sys., 
Inc., B-256242, May 31, 1994, 94-1 CPD  para.  329.

Metfab has not established that the solicitation failed to include 
adequate information for the preproduction examinations listed in the 
solicitation.  While the actual testing approach was not specified, 
but instead was to be provided by the contractor in its test plan and 
approved by the government, the examinations clearly are to be based 
in the first instance on the salient characteristics set forth in the 
RFP.  In general, these salient characteristics, which the protester 
has not challenged, were reasonably specific in nature.  For example, 
with respect to equipment weight and dimensions, an area cited by the 
protester, the salient characteristics required a turntable of "1,500 
pounds weight capacity" and overall dimensions "not to exceed 63 
inches wide by 72 inches deep by 72 inches high."  While other areas 
to be evaluated in the preproduction examinations--e.g., accessibility 
of components and parts--were not expressly addressed in the salient 
characteristics, we see no reason why commercial vendors would not 
understand what would be sufficient to meet the agency's requirements 
in these areas in terms of performance required and form, fit and 
function (e.g., that there be reasonable accessibility).   See 
Adventure Tech, Inc., supra.  The fact that the Navy received five 
proposals other than Metfab's, all offering different model machines, 
with no indication that the other offerors viewed the specification as 
uncertain or risky, supports the conclusion that the RFP contained 
sufficient information for offerors to intelligently compete on a 
common basis.  See University Research Corp., B-228895, Dec. 29, 1987, 
87-2 CPD  para.  636.   

MART'S PROTEST 

Mart argues that Better Engineering's proposed modified brand name 
parts washer did not comply with the RFP's salient characteristics (1) 
requiring the capability to raise the water temperature to 200 degrees 
Fahrenheit (F) within 2 hours (the heat-up requirement) and (2) 
limiting the maximum amperage draw to 59 amperes (amps) with a 
220-volt, three phase power source.  Mart contends that Better 
Engineering's water heater will either fail to heat in the time 
required, or that if it heats as required, it will draw more than 59 
amps of power.  The protester asserts that the specifications were 
relaxed and that it could have reduced its price had it been afforded 
an opportunity to offer on the same relaxed specifications. 

Although the RFP did not expressly state that it included 
specifications which required modification of the brand name product 
for compliance, there is no disagreement among the parties that this 
was the case here; Mart and Better Engineering both recognized that 
the 18 kilowatt (KW) heater of the brand name product was inadequate 
to meet the solicitation's heat-up requirement, and both offered 
larger heaters.[1]  Better Engineering's proposal described its heater 
as follows: 

     "Units to be equipped with 24 KW of electric heat (33 percent 
     more than on a standard F-4000-P) to ensure temperature rise to 
     200 degrees F in two (2) hours.  Our experience and the laws of 
     physics have shown that less than 24 KW of heat in this tank size 
     will not provide required heat-up performance."  (Emphasis in 
     original.)

In addition, Better Engineering responded to the 59-amp limitation by 
describing its proposed parts washer as "220 volt, 3 phase, 60 HZ with 
59 amp draw at full load."  In contrast, Mart proposed a "primary" 
heater of "15 KW (operates as required)" and a "secondary" heater of 
"7.5 KW (de-energized when pump runs)," operating at 200 volts, but 
did not mention the 59-amp requirement.  

The Navy, which was familiar with Better Engineering's previous 
descriptive literature showing its parts washers operating at 240 
volts, interpreted Better Engineering's proposal as Better Engineering 
states it intended--a 24 KW heater operating at 240 volts derated to 
220 volts, which it determined will dissipate   20.17 KW of power, and 
which will therefore not draw more than 59 amps.  The agency engineer 
concluded that Better Engineering's statement in its proposal that the 
maximum amperage draw would not be exceeded was achievable based on 
the engineer's knowledge of amperage limitation devices, including 
load shedding devices, which could be utilized to avoid exceeding the 
maximum allowable amperage (59) draw, and which it assumed Better 
Engineering was offering.  

Mart argues that Better Engineering's proposal should have been 
determined noncompliant because (1) the proposal indicated that the 
offered parts washer would need to dissipate at least 24 KW of 
power--which would draw a higher amperage--to meet the heat-up 
requirement, and (2) "nowhere in Better Engineering's technical 
proposal . . . did they state that an 'amperage limiting device' was 
included" to derate the heater to 220 volts from 240 volts.[2]  
  
Generally, the contracting agency is responsible for evaluating the 
data submitted by an offeror under a brand name or equal procurement 
and ascertaining if it provides sufficient information to determine 
whether the offeror's product meets the salient characteristics.  
Andromeda Corp., B-245345, Nov. 20, 1991, 91-2 CPD     para.  485; VG 
Instruments, Inc., B-241484, Feb. 7, 1991, 91-1 CPD  para.  137.  We will 
not disturb an agency's determination absent a showing that it was 
unreasonable.  Id.    
The Navy reasonably determined that Better Engineering's proposal 
adequately showed compliance with the requirements in issue.  Better 
Engineering expressly stated in its proposal that the brand name 
heater would be modified to "ensure temperature rise to 200 degrees F 
in two (2) hours," that is, to meet the heat-up requirement, and that 
there would be a "59 amp draw at full load" with a 220-volt power 
source.  Mart has furnished no calculations establishing that the 
anticipated resulting 20.17 KW of power dissipation would not meet the 
heat-up requirement.  Rather, Mart bases its argument that 20.17 KW of 
power dissipation will not suffice on Better Engineering's statement 
in its proposal that "experience and the laws of physics have shown 
that less than 24 KW of heat in this tank size will not provide 
required heat-up performance."  (Emphasis in original.)  While the 
protester assumes that Better Engineering's reference to "24 KW of 
heat" was a reference to the required power dissipation, rather than 
to the size of the required heating element, there was nothing in 
Better Engineering's proposal indicating that this was Better 
Engineering's intent.  Moreover, Mart itself apparently intends to 
furnish a heater dissipating only 20.6 KW of power and did not explain 
in its proposal exactly why 20.6 KW would be sufficient for its washer 
to meet the heat-up requirement.  It thus appears that both proposals 
were evaluated on the basis of their statements of compliance with the 
heat-up requirement,[3] and there is no basis for questioning the 
agency's determination of Better Engineering's compliance with this 
requirement.  See Inframetrics, Inc., B-257400, Sept. 30, 1994, 94-2 
CPD  para.  138; Power Dynatec Corp., B-251501.3, Aug. 3, 1993, 93-2 CPD  para.  
73.   

The failure of Better Engineering's proposal to describe the use of an 
amperage limitation or load shedding device to be used to assure 
compliance with the        59 amp limitation, also does not furnish a 
basis for questioning the Navy's determination of compliance.  
Although the solicitation required offerors to describe in their 
proposals compliance with the salient features and to include 
descriptive literature establishing pertinent details of the products 
offered, the solicitation did not require offerors to detail exactly 
how their offered equipment would perform in a compliant manner.  
Since there was a feasible means of meeting the requirement, we think 
the agency could reasonably assume that this means would be employed 
by Better Engineering.  Moreover, as discussed above, since the agency 
accepted general statements of compliance with the salient 
characteristics from both offerors, Better Engineering's failure to 
provide more specifics with regard to its intent to use an amperage 
limiting or load shedding device was not a basis for rejecting its 
proposal.  See Inframetrics, Inc., supra; Power Dynatec Corp., supra.

The protests are denied.

Comptroller General
of the United States 

1. While the RFP did not specify the heating element size, and the 
agency did not perform actual calculations to determine the necessary 
heating element size, an agency engineer has explained that "[b]ased 
on previous experiences of other aqueous parts washers of similar 
size, the agency felt that the 18 KW heating element (standard on the 
basic Better Engineering F-4000 unit) would provide only marginal 
performance."

2. In comments to a supplemental agency report, Mart also contends 
that the total amperage draw of Better Engineering's parts washer will 
in fact exceed the 59 amp limitation based on additional amperage 
resulting from a transformer for the system controls.  This 
contention, raised more than 10 working days--in fact, approximately 2 
months--after the protester's receipt of a copy of the awardee's 
proposal, when the basis of protest should have been known, is 
untimely and will not be considered.  4 C.F.R.  sec.  21.2(a)(2) (1995).  

3. As another relevant example, although Mart states that "[its] 
proposal also includes electrical devices that keep the amperage draw 
. . . under the maximum  59 amps allowed," nowhere in its proposal did 
it specifically state that it was using an amperage limitation or load 
shedding device.  In fact, Mart's proposal did not even mention the 
59-amp limitation.