Global Fastener News

GAO Seeks Comment on Small Lot Exemption

John Wolz

The General Accounting Office is seeking public comment on the small lot exemption to the U.S. Fastener Quality Act to determine if the industry would use it as a loophole to circumvent the law�s requirements.
The 1999 amendments to Public Law 101-592 require the GAO to conduct a study of the exemption of fasteners ordered for use as spare, substitute, service or replacement parts in packages containing 75 or fewer pieces and parts contained in assemblies. \
The GAO must submit a report to Congress by June 2001 �describing any changes in industry practice� resulting from the enactment of the small lot exemption. The deadline for public comments is November 30, 2000.
Al Stapleton, GAO assistant director, said comments should be limited to the exemption and not to the law as a whole.
�In response to reports of deaths, accidents and equipment damage caused by poor quality or mislabeled fasteners, the Congress enacted the FQA, which required that fastener quality be assured through laboratory testing. However, concerns over the high cost of testing for small lots led the Congress to amend the law in 1999 to exempt from testing� small lots of fasteners, according to a GAO statement.
GAO cited a possible example as �increased marketing, distribution and sale of safe, properly labeled fasteners manufactured after December 6, 1999, in packages of 75 or fewer or in an assembly kit to avoid the costs of complying with FQA requirements.�
�The small lot exemption was included in the 1999 amendments to the FQA in response to concerns from industries that use fasteners, particularly foreign automobile manufacturers,� according to the GAO. The testing requirements could make small lots �prohibitively expensive� or lead fastener manufacturers �either to stop selling fasteners in small lots� or to raise prices so high �that users might stop buying them and instead substitute lower-quality, lower-cost, �hardware store� fasteners.�
The GAO Federal Register announcement of the public comment period cites an example of a farm equipment company which usually bought fasteners in packages of 500, but after the FQA implementation on December 6, 1999, began buying in packages of 75 or fewer.
Comments should include a description of the practice before implementation, why there is a change, information on how widespread changes are and contact information for additional information or clarification.
GAO is seeking broad input from any interested party, including those in government procurement, the fastener industry, and large and small buyers of fasteners.
Comments may be sent via e-mail to: fasteners@gao.gov or by mail to Theresa Roberson, General Accounting Office, General Government Division, Room 2908, 441 G St. NW, Washington, DC 20548.
For additional information contact Al Stapleton at 202 512-3418 or e-mail: stapletona.ggd@gao.gov or Theresa Roberson at 202 512-3431. E-mail: robersont.ggd@gao.gov Web: www.gao.gov
In addition to reviewing public comments, the GAO is tracking calls to the Bureau of Export Enforcement FQA hotline and checking the federal agencies that buy fasteners.