QA VERSES QC

8/7/2019 QA VERSES QC

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As envisioned by the government-wide performance-based contracting(PBC) movement of the 1990s, quali-ty assurance (QA) and quality control(QC) work hand-in-hand to ensurethe contractual delivery of an excel-lent product to the government. Yet,the two terms compose two differententities and signify different contrac-tual responsibilities.

Generally speaking, the contractoris responsible for QC, while the gov-ernment is responsible for QA. Thatsounds clear enough, yet in practiceand historically speaking, the distinc-

tion between the two has sometimesbeen blurred—to the point wherethey have come to be used inter-changeably.

It is important to understand thedifference between quality controland quality assurance, and to ensurethat the two terms are not used syn-onymously. Why is it important? Thegovernment performs QA. Typicalgovernment contract clauses placeQC responsibility upon contrac-tors, requiring them to do certainthings to comply with the require-ments. Thus, it is important to have

a clear understanding as to whatthose requirements are. Blurringthe definition between the two con-cepts allows contractors unnecessarywiggle room in complying with theirresponsibilities, and complicates thegovernment’s evaluation and enforce-ment of these contractual duties.

This article has the modest goal of providing a clear understanding of quality control and quality assuranceterms, the difference between the

two, and a brief discussion of how theterms have sometimes been and con-tinue to be used interchangeably.

What Is Quality Control?The U.S. Air Force Instruction (AFI)63-501 defines quality control as

[T]hose actions that control theproduction of output to fulfillrequirements for quality in raw orproduced material and services.Quality control includes a feed-back process that measures actualperformance, compares it to qual-

ity requirements, and acts on thedifference to minimize variation.Quality control is the measure-ment of a process or product byan automated process, operator, orother person, with comparison torequirements and action to resolvevariation from a standard.1

A recent industry paper written by Alison Kaelin, a corporate quality assur-ance manager, defines quality control as

The “QT” on Quality Assurance versusQuality ControlBlurring the definition between quality assurance and quality control allows contractors

unnecessary wiggle room for compliance and thus complicates the government’s

evaluation and enforcement of these contractual duties.

BY JEFFREY A. RENSHAW

MAJOR JEFFREY A. RENSHAW is

an active duty judge advocate in the

U.S. Air Force Judge Advocate’s Corps.

He is a trial attorney assigned to the Air

Force Directorate of Contract Dispute

Resolution at Wright-Patterson Air Force

Base, Ohio, and is a member of the

Louisiana State Bar. Send comments

on this article to [email protected].

A b o u t t h e A u t h o r

22 ■ Contract Management / September 2005


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[P]erforming the necessary observa-tions, testing, and documentationthat verify the work performedmeets or exceeds the minimumstandards established by the projectspecifications or contract. Qualitycontrol involves the routine andsystematic inspections and tests thatare conducted to verify that eachphase of the work is in compliancewith the specification. Quality con-trol is the contractor’s responsibility.2

What Is Quality Assurance?The same U.S. Air Force Instruction

defines quality assurance as

A planned and systematic patternof actions necessary to provideconfidence that adequate techni-cal requirements are established;products conform to establishedtechnical requirements; and satis-factory performance is achieved.3

The industry paper cited earlierdefines quality assurance as

[T]he process to verify that thequality of work performed is actu-ally what was reported by qualitycontrol. Quality assurance is anaudit function, used to verify thatquality control is being performedand performed properly. It mayinclude review of QC documenta-tion or conducting actual testingon a spot or periodic basis. Qualityassurance is typically performed bythe owner or a third-party inspectoron the owner’s behalf.4

Practical Differences

Although the paper cited earlier dealsspecifically with the painting industry,it does an excellent job of laying outthe operative differences between QCand QA.

In simple terms, the contractor isfully responsible for every aspectof the project from the equipmentand materials, and experience andtraining of personnel, to the qualityof the final product. Quality con-

trol by the contractor is meant toprovide in-process verification thatthe cleaning and painting is beingperformed as designed to providea quality final product. Qualityassurance by the owner is meantto verify that the quality controlimplemented by the contractormeets the requirements of thespecification, to further assure thata quality final product will result.5

Kaelin’s paper also explains thatwhile QC is a full-time require-ment, QA can be full or part-time,

or performed at specific stages of thepainting process. Her paper empha-sizes that the presence of the owneror a third-party QA evaluator/inspec-tor does not relieve the contractor of its QC responsibilities. Indeed, thisprinciple is embodied in the Federal

Acquisition Regulation and in ArmedServices Board of Contract Appealsdecisions.6

September 2005 / Contract Management ■ 23


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Q U A L I T Y A S S U R A N C E V S . Q U A L I T Y C O N T R O L

Term Interchange and Confusion As noted by the Office of theSecretary of Defense’s “Share A-76” Web site, “QA and QC are frequentlyconfused and mistakenly used inter-changeably. On one hand, they referto distinctly different actions per-formed by different organizations.”7 The site explains that QA involvesactions taken by government qualityassurance evaluators (QAEs) to deter-mine if goods or services meet thecontract requirements.

On the other hand, QC refers to acontractor’s actions taken to controlproduction of goods or services toensure compliance with the contractrequirements. Other organizationshave also noted this confusion. For

example, the Husky Injection MoldingSystems, Ltd., Web site states

We often hear the terms qualityassurance and quality control usedinterchangeably. However, I like tothink of quality control as a reactiveapproach to quality: Doing inspec-tions or taking part measurements,finding an out of spec part and fix-ing the process. Whereas qualityassurance is proactive: Using theinformation we gather in qualitycontrol with tools such as pare toand control charts to monitor pro-cesses and defect changes beforethe parts are out of spec.8

The American Society for Quality(ASQ) has noted the sometimes-inter-changeable use of quality control andquality assurance as well, opiningthat both terms “have many inter-pretations because of the multipledefinitions for the words ‘assurance’

and ‘control.’”9

The Tennessee Centerfor Performance Excellence (TNCPE)likewise notes the multiple definitionsfor “assurance” and “control,” stating,“Often, however, ‘quality assurance’and ‘quality control’ are used inter-changeably, referring to the actionsperformed to ensure the quality of aproduct, service, or process.”10

A review of several Boards of Contract Appeals decisions also shedssome insight as to the “loosey-goosey”

usage of the two terms. One boarddecision involved the U.S. Army’s Missile Command and describedits “project assurance directorate,”which was responsible for quality con-trol.11 Another one, The Wayne Kerr

Corporation case, involved a contractthat called for the contractor to designand develop a capacity measuringsystem. The contractor claimed thatthe QC contract specifications wereambiguous, and that the governmentwas requiring additional work.

“Quality control” and “qualityassurance” appear to be used inter-changeably throughout the opinion:

It is apparent that appellant wasunfamiliar with the details and

procedures required by NASA con-tracts, particularly the requirementof NPC 200-4, a NASA quality con-trol procedure, compliance withwhich was required by contractterms. The appeal file indicatesthat respondent delegated certaincontract administration author-ity and quality control inspectionresponsibility to the DefenseContract Administration Service.Several of the technical difficultiesappellant and its subcontractorsexperienced in performing thecontract work centered in compli-ance with the quality assuranceprocedures required by the con-tract…respondent wrote appellant aletter…commenting on appellant’sDecember monthly progress reportand stated in part: “You are advisedthat your inspection plan was notapproved as written, however, weare informed that DCAS Quality

Assurance Representatives have

contacted your subcontractor fornecessary corrections and guide-lines.”12 (Emphasis added)

The case of Big 4 Mechanical

Contractors, Inc.,13 adds to the blur-ring of the QC/QA terms—it treatsthe distinct concepts as synonymous.The Armed Services Board of Contract Appeals decision describesthe contractor’s claim as one for“additional costs alleged to have

been incurred in implementing aquality assurance program duringthe performance of a contract forthe repair and overhaul of aerospaceground equipment assigned to Tinker Air Force Base, Oklahoma.” It thenexplains that the contract includeda number of provisions pertainingto inspection of the work and “qual-ity assurance” and then includes thecontract language which is a clausetitled “Quality Control and Inspectionand Acceptance.” Any meaningfuldistinction between the two termswas blurred in the following opinionlanguage:

An initial recommendation wasmade to disapprove the award

based on appellant’s lack of inspection and quality assurancepersonnel and procedures. However,after appellant had agreed to pro-vide an acceptable quality controland inspection manual and toprovide acceptable inspection andquality control services as requiredby MIL-2-45208A, the appellant wasawarded the contract.14

However, later in the opinion theboard lists quality control and qualityassurance as separate components.The board explained, “The U.S. AirForce repeatedly indicated its inten-tion to implement fully a qualitycontrol, inspection, and quality assur-ance procedure that would complywith the contract….”15

Yet, the board reverts back tocharacterizing the concepts as inter-changeable, in its language, “Atvarious times during performance of the contract, government representa-

tives had requested that appellantfurnish listings of its quality controland/or quality assurance personnel.”To further illustrate, although theemployees on an August 24, 1972, listgiven by the contractor to the U.S. AirForce (USAF) were all QC personnel,the board interchangeably uses theterms as follows:

On 22 January 1973, Mr. Charles E.Towe furnished a list of appellant’s



quality assurance personnel whichshowed changes from the 24 August1972 listing as follows: Robert Van Atta was substituted as quality controlmanager, Ken Reeves was listed underCategory A Shop, and Robert Billinsand Delain Baxter had been added toquality control for the service line.16

Conflicting usage of the two termsis peppered throughout the decision.In sum, it appears that in the 1970swhen the decision was rendered, qualitycontrol was considered to be a subsetof quality assurance, whereas in pres-ent day, both are separate entities.

Another case arising from Tinker Air Force Base, Bailey et al v. United

States, involved an action by 30 fed-

eral employees, who were employedas “quality control inspectors” by theU.S. Air Force in the mid 1970s.17

At that time, the air force was stillresponsible for contractual QC, orwas characterizing quality control asquality assurance. In either event, thepoint is that the two terms were beingused virtually synonymously.

Emergence of 1990sPerformance-Based ContractingThe Office of Federal ProcurementPolicy’s letter of April 9, 1991,established a federal policy that allgovernment agencies would use per-formance-based contracting (PBC)methods to “the maximum extentpracticable henceforth.”18 As part of that policy, agencies were directed toassign contractors full responsibilityfor quality performance, whereas thegovernment would develop “perfor-mance standards and surveillanceplans to facilitate the assessment of

contractor performance.”19

Further,the policy letter encouraged agenciesto avoid “cumbersome and intrusiveprocess-oriented inspection and over-sight programs to assess contractorperformance.”20

The interaction between contractor-provided QC and government-pro-vided QA is critical to ensure thata quality product is delivered to thegovernment. As explained on thegovernment’s Know Net Web site:

The PBC team is interested in uti-lizing systematic quality assurancesurveillance methods in monitor-ing contractor performance. Thecontractor is responsible for man-aging and controlling the outputof its service through its qualitycontrol plan…. Effective utiliza-tion of these two components, thecontractor’s quality control plan andthe government’s quality assuranceplan (QASP) is a key reason whyperformance-based contracting is asuperior contracting methodology.”21

The QASP details how and whenthe government will survey, observe,test, sample, evaluate, and documentcontractor performance according to

the performance work statement. TheQASP explains, “The government’sQASP and the contractor’s qualitycontrol plan (QCP) work together toensure project performance standardsare met.”22

This interaction between the con-tractor’s QCP and the government’sQASP is now recognized in FAR 37.602-2:

Agencies shall develop qualityassurance surveillance plans whenacquiring services….These plansshall recognize the responsibilityof the contractor…to carry out itsquality control obligations and shallcontain measurable inspection andacceptance criteria correspond-ing to the performance standardscontained in the statement of work.The quality assurance surveillanceplans shall focus on the level of per-formance required by the statementof work, rather than the method-

ology used by the contractor toachieve that level of performance.

FAR Subpart 46.3 requires thatin service contracts, all contractorsmust have a QCP; it is a mandatoryelement of the performance work statement. The interaction betweenthe two is described as follows:

The contractor’s quality control plan is

the contractor’s everyday tool to insure

meeting the government’s performance

standards. The government’s quality

assurance surveillance plan is the inter-

mittent check on its effectiveness.23

QA/QC Confusion As discussed earlier, while the trans-formation in government contractingto performance-based contracting hasdefinitely aided in marking the delin-eation between QC and QA, therelingers some residual confusion andoverlapping between the two.

Confusion between the twoterms—what is meant by qualityassurance and quality control—shouldbe avoided. How can this be done?Government contract attorneys shouldreview contract clauses carefully to

ensure that the two terms are definedand differentiated, with a clear con-tractual spelling-out of the two items.

As an example, the NationalInstitutes of Health (NIH), a federalagency, adopted use of the AmericanInstitute of Architects MASTERSPEC© specification system for its construc-tion contract specifications. Portionsof the MASTERSPECS had to bealtered, however, to reflect the properusage of QA and QC terms, as follows:

Quality Control Versus Quality

Assurance: Quality control is theresponsibility of the construc-tion contractor. Quality assuranceis the responsibility of the NIH.Terminology: The A/E must changethe terminology used through-out Divisions 2 through 16 of the MASTERSPEC documents. Mosttechnical sections in MASTERSPECDivisions 2 thorough 16 includea paragraph titled “Quality

Assurance.” “Quality assurance”is also used in verbiage throughoutthese technical sections. For all NIHprojects, all references to “qual-ity assurance” must be changedto “quality control” to assignresponsibility to the constructioncontractor.24

Previously, we looked at someexamples of confusion between theseterms in several industries. This still



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is of some concern in the USAF, as AFI 63-124 states, “An inspection of services clause is required for everyservice contract. You should adopt thequality control and quality assurancepractices used in the commercialmarketplace to the maximum extentpracticable.”25 If there is confusionin the commercial marketplace as tousage of the two terms, and the USAFis to rely upon that marketplace forits own contractual QA and QC prac-tices, might there not be a danger of confusion between the two terms inits contracts?

It is impossible to survey the uni-verse of federal government agencysolicitations to see if QC and QA areadequately defined and administered.

It is my belief that in general, federalagency solicitations do a good jobwith definitions and the respectiveroles and duties each has for the gov-ernment and the contractor.

For example, the Office of FederalProcurement Policy issued a templatefor a statement of work (SOW) to beused in elevator maintenance andrepair contracts. An initial caveatto the SOW template stated that itwas based upon “commercial mar-ket practices as determined by themarket research conducted on thisrequirement.”26 The template con-tains a separate paragraph discussingQC, which reads in part, “Contractorshall develop and maintain a qual-ity program to ensure maintenanceand repair services are performed inaccordance with ANSI/ASMW A17and other applicable standards andcodes.”27

The separate QA paragraph simplyreads, “The government will peri-

odically evaluate the contractor’sperformance in accordance with thequality assurance surveillance plan(QASP).”28 The template for the QASPlanguage states in part:

This quality assurance surveillanceplan (QASP) has been developed toevaluate contractor actions whileimplementing this SOW.…TheQASP provides a systematic methodto evaluate the services the contrac-

tor is required to furnish.…Thecontractor, and not the government,is responsible for management andquality control actions to meet theterms of the contract. The role of the government is quality assuranceto ensure contract standards areachieved. In this contract the qual-ity control program is the driver forproduct quality.…The first majorstep to ensuring a “self-correct-ing” contract is to ensure that thequality control program approvedat the beginning of the contract

provides the measures needed tolead the contractor to success.Once the quality control program isapproved, careful application of theprocess and standards presented inthe remainder of this document willensure a robust quality assuranceprogram.29

Another example of a templatedeveloped for mass use that well-defines QC are specificationsdrafted by the USAF Center forEnvironmental Excellence (AFCEE)




for use in landscaping contracts. Thetemplate states, “Quality control shallbe provided for the entire project….Responsibility for accomplishing qual-ity control is the contractor’s.” Thetemplate then contains five pages of text that lists specific quality controlplan requirements for the contrac-tor. This particular template actuallyplaces some QA responsibilities uponthe contractor as well, and notesspecifically that the government isnot required to inspect a contractor’swork or to protect a contractor fromthe consequences of such work.30

Such templates evidence federalagency actions to implement the per-formance-based contracting goals of placing more quality requirements

upon contractors while placing lessresponsibility upon the govern-ment. Assuming that most—if notall—federal agencies try in good faithto comply with this goal, and makeefforts to contractually delineate thedifferences between QA and QC, thenwhat is the problem, if any?

In my view, the problem is the factthat some loose usage of the qualitycontrol and quality assurance termsexists in various industries today,and to the extent that federal agencycontract specifications are supposedto mirror commercial practices, thosespecifications may themselves mir-ror some of the residual confusionbetween the two terms.

Additionally, and strictly on ananecdotal basis, I have seen firsthandin contract administration a confu-sion in usage of the two terms, anda subsequent issue created becausegovernment QA evaluators allegedlyperformed QC functions and the con-

tractor attempted to use this to itsbenefit in interpreting its quality obli-gations under the contract.

To fulfill the goals of performance-based contracting and ensure thatcontractors know what is expectedof them, precise usage of the QC andQA terms—both in written (contractclauses) and verbal form (in practice inthe administration of government con-tracts)—is critical. And, if they do notfulfill those expectations, the govern-

ment is able to afford itself of availableremedies to enforce clearly definingcontractual quality expectations. CM

Endnotes

1. Air Force Instruction 63-501 May 31,

1994, “Air Force Acquisition QualityProgram,” Attachment 1, “Glossary of

References, Abbreviations, Acronyms,

and Terms Explained.”

2. Alison B. Kaelin, “Quality Control and

Quality Assurance: Defining the Roles

and Responsibilities of the Contractor’s

QC and the Owner’s QA,” paper pre-

sented at the Painting and Coatings

Expo (PACE 2005), sponsored by the

Society for Protective Coatings (SSPC)

and the Painting and Decorating

Contractors of America (PDCA), at

www.kta.com/knowledge/PACE2005/QC&QA%20ABK.pdf. Kaelin is the cor-

porate quality assurance manager for

KTA-Tator, Inc., Pittsburgh, PA.

3. AFI 63-501, supra.

4. Kaelin, at 2.

5. Ibid.

6. See FAR 52.246-2(k); Rosendin Electric,

Inc., ASBCA No. 22996, 81-1 BCA

¶14,827.

7. Office of the Secretary of Defense,

Undersecretary for Acquisition,

Technology & Logistics, Share A-76 Web page, http://emissary.acq.

mil/inst/share.nsf/CONTDEFLOOK/

About+A-76-Process+Model-Previous+Ci

rcular+Appeal, accessed on May 2, 2005.

8. See www.husky.ca/products/quality.

html, accessed on May 10, 2005.

9. See www.asq.org/topics/qa_qc.html,

accessed on May 2, 2005. The American

Society for Quality (ASQ) is a 104,000-

member professional association that

describes itself as “the world’s leading

authority on quality since 1946.”

10. See www.tncpe.org/resources/criteria/

terminology.asp, accessed on May 10,

2005.

11. Protest of Project Software and

Development, Inc., GSBCA No. 8471-P,

86-3 BCA ¶19,082.

12. Wayne Kerr Corporation, NASA BCA No.

670-10, 73-2 BCA ¶10,240.

13. Big 4 Mechanical Contractors Inc.,

ASBCA No. 20897, 77-2 BCA ¶12,716.

14. Ibid.,.at 6.

15. Ibid., at 8.

16. Ibid., at 9.

17. Bailey et al v. United States, U.S. Claim

Ct, 3 Cl Ct. 619 (1983).

18. April 9, 1991, Policy Letter 91-2, “To

the Heads of Executive Agencies, and

Departments, OFPP,” Allan V. Burman,Administrator. FAR Subpart 37.6 imple-

ments OFPP Policy Letter dated April

9, 1991, which first established the

requirement that results not processes

be specified and that requirements be

stated in measurable terms. This OFPP

Policy Letter was letter rescinded, when

FAR 37.6 was amended/updated to

reflect the modern PBC policy. See Know

Net, www.knownet.hhs.gov, Topic

2.3, “Writing the Quality Assurance

Surveillance Plan.” Know Net is a knowl-

edge management, e-learning, and

performance support system sponsoredby the U.S. government.

19. Ibid.

20. See www.knownet.hhs.gov, accessed

on May 2, 2005.

21. Ibid.

22. Ibid.

23. Ibid.

24. See http://orf.od.nih.gov/policy/vol-

ume4-constructionspecs.htm, Office

of Research Facilities, Development

and Operations, National Institute ofHealth website, Section R. Construction

Specifications, R.1, Specification Sections,

R.1.1, “Quality Control Versus Quality

Assurance” and R.1.1.1 “Terminology.”

25. AFI 63-124.

26. See www.acqnet.gov/Library/OFPP/

PolicyDocs/afelevator.doc. The Office of

Federal Procurement Policy, or “OFPP,”

falls under the Office of Management

and Budget (OMB), and provides overall

direction of government-wide procure-

ment policies, regulations, procedures,

and forms for executive agencies and topromote economy, efficiency, and effec-

tiveness in the procurement of property

and services by the executive branch of

the federal government. 41 USC 404.

27. Ibid.

28. Ibid.

29. Ibid.

30. See www.afcee.brooks.af.mil/dc/dcd/

land/mstrland/mlcs_8.asp.


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QA VERSES QC