Critical Safety Item (CSI)

Overview

A Critical Safety Item (CSI) is a part, assembly or support equipment whose failure could cause loss of life, permanent disability or major injury, loss of a system or significant equipment damage. Special attention should be placed on CSIs to prevent the potential catastrophic or critical consequences of failure. Significant problems occurred when DoD purchased CSIs from suppliers with limited knowledge of the item’s design intent, application, failure modes, failure effects or failure implications.

CSI Analysis

The purpose of CSI analysis is to ensure that Program Managers (PMs) for DoD acquisition programs who enter into contracts involving CSIs do so only with resources approved by the Design Control Activity (DCA). The DCA is defined by law as the systems command of a military department. The DCA is responsible for the airworthiness or seaworthiness certification of the system in which a CSI is used.

The intent of CSI laws, policies, regulations and guidance is to reduce the likelihood and consequence of failure by mitigating receipt of defective, suspect, improperly documented, unapproved and fraudulent parts having catastrophic potential. These statutory requirements are contained in P.L. 108-136 (SEC 802), enacted to address aviation CSIs, and P.L. 109-364 (SEC 130), enacted to address ship CSIs, embedded in 10 USC 2319. The statute addresses three specific areas:

CSI policies and guidance ensure that items of supply that are most critical to operational safety are rigorously managed and controlled in terms of:

DoDM 4140.01, Volume 11 establishes top-level procedures for the management of aviation CSIs. The Joint Aeronautical Commanders Group issued the Aviation Critical Safety Items (CSIs) Management Handbook. This guidance establishes standard user-level operating practices for aviation CSIs across the Services, the Defense Logistics Agency (DLA), the Defense Contract Management Agency (DCMA), and other Federal agencies. Appendix I of the Aviation CSI Management Handbook is a joint Military Service/Defense Agency instruction on "Management of Aviation Critical Safety Items" issued on January 25, 2006. This instruction (SECNAVINST 4140.2, AFI 20-106, DA Pam 95-9, DLAI 3200.4, and DCMA INST CSI (AV)) addresses requirements for identifying, acquiring, ensuring quality of, managing and disposing of aviation CSIs. Similar policies and guidance are being developed and/or revised to address ship CSIs as defined by public law.

The Defense Federal Acquisition Regulation Supplement (DFARS) was amended to implement the contractual aspects regarding aviation CSIs. Comparable DFARS amendments are being developed to address ship CSIs. DFARS (Subpart 209.270) states that the DCA is responsible for:

This supplement states that the contracting activity contracts for aviation CSIs only with suppliers approved by the DCA. PMs should coordinate with the contracting activity to ensure that they contract for aviation CSIs only with suppliers approved by the DCA and that nonconforming aviation CSIs are to be accepted only with the DCA’s approval, as required by DFARS (Subpart 246.407). DFARS (Subpart 246.407) was amended to state that DCA authority can be delegated for minor nonconformance. DFARS (Subpart 246.504) requires DCA concurrence before certificates of conformance are issued to accept aviation CSIs.

Because the developer may uncover problems with products after items are delivered, DFARS (Subpart 246.371) and DFARS (Subpart 252.246-7003) require the developer to notify the procuring and contracting officers within 72 hours after discovering or obtaining credible information that a delivered CSI may have discrepancies that affect safety. PMs should coordinate with the contracting authority to be kept aware of materiel recalls and shortfalls that may impact production rates and sustainment.

The CSI list evolves as the design, production processes and supportability analyses mature. PMs identify and document CSIs during design and development to influence critical downstream processes, such as initial provisioning, supply support and manufacturing planning to ensure adequate management of CSIs throughout a system’s Operations and Support (O&S) phase. The PM should ensure that the allocated baseline established at the Preliminary Design Review (PDR) includes an initial list of proposed CSIs and a proposed process for selecting and approving CSIs, and that it addresses the critical characteristics of those items.

Prior to the Critical Design Review (CDR), the program office, with support from the DCA and developer/OEM contractors, should ensure there is a clear understanding of CSI processes, terms and criteria. The initial product baseline, established at CDR, should have 100% of drawings completed for the CSIs. Throughout Low-Rate Initial Production (LRIP) (if applicable), conduct of the Physical Configuration Audit (PCA) and establishment of the product baseline, the program should update the CSI list and review it to ensure the list reflects the delivered system. Before the Full-Rate Production/Full Deployment Decision Review (FRP/FD DR), a final CSI list should be documented and approved by the DCA.

Products and Tasks

Product Tasks
10-6-1: Verification of critical safety item (CSI) program
  1. Identify critical safety items (CSI) for systems / subsystems / components to be developed, modified, or procured.
  2. Document CSI items in accordance with current guidance, and submit to cognizant military service engineering support activity (ESA) / design control activity (DCA) responsible for official CSI determination.
  3. Obtain list of prescribed appropriate CSI artifacts from the cognizant ESA/DCA.
  4. For approved and prescribed CSI artifacts, document CSI technical risks, measures, metrics and reviews in the program’s systems engineering plan (SEP).
  5. Verify appropriate CSI clauses are in the request for proposal (RFP) / contract in accordance with defense federal acquisition regulation supplement (DFARS).
  6. Examine each CSI and document CSI level of criticality determination, identification, and critical characteristics / processes/inspections in the technical data package (TDP).
  7. Verify CSI surveillance is performed by defense contract management agency (DCMA).
  8. Verify CSI serial number management and tracking process is in place and properly applied.
  9. Verify CSI configuration management process is in place for ESA / DCA approval of any proposed change of CSI acquisition.
  10. Verify disposal process is in place to dispose of CSIs in accordance with criticality code and current guidance.

Source: AWQI eWorkbook

Resources

Key Terms

Source:
DAU ACQuipedia
DAU Glossary

Policy and Guidance

DAU Training Courses

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  1. Overview
  2. CSI Analysis
  3. Resources
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