DEFENSE LOGISTICS AGENCY 
                                                   DEFENSE INDUSTRIAL SUPPLY CENTER
                                                                 700 ROBBINS AVENUE
                                                         PHILADELPHIA, PA 19111-5098

DISC-AE                                                                                                                               June 22, 1998

Subhas G. Malghan
National Institute of Standards and Technology
Building 820, Room 308
Gaithersburg, MD 20899

Dear Subhas G. Malghan:

It is truly unfortunate that we cannot meet with you on the 23rd of June 1998, as we planned.  I understand 
that an emergency has arisen that has caused the postponement of our meeting, but on behalf of the 
Government Industry Fastener Working Group (GIFWG), I would like to emphasize that it is absolutely 
essential that we do meet with you to discuss the issues we identified in previous communications.  In this 
regard, it was our intention to recommend that implementation of the Fastener Quality Act be delayed until 
certain, very important studies are completed.  I cannot emphasize it enough, that implementation on the 
26th of July 1998, as currently planned, will have a devastating impact on the entire fastener industry.  It is 
absolutely essential that someone recognize the very serious consequences that will result if there are not 
a sufficient number of accredited labs available to handle the volume fastener production (both in this 
country and abroad).  Of equal importance is a more precise definition of which fasteners are covered by 
he law.  These 2 issues are interrelated in that the types of fasteners impacted by the law will dictate the 
fields of testing that will need laboratory accreditation.

An important aspect of the GIFWG concerns that you need to understand is that it is not our intention to 
argue the merits of the FQA but rather to identify what we consider to be a most serious oversight in its 
implementation.  For example, in the years that you have pursued the extremely difficult task of FQA 
implementation, there has been much debate regarding the number of accredited labs needed to support 
the intentions of the law.  There have been all kinds of numbers put forth in this regard.  The truth of the 
matter, however, is that it isn't the number of accredited labs that's important but rather the number of labs 
accredited in all of the fields of fastener testing.  Just as important as the number of labs accredited in the 
fields of testing is the types of labs and where they are located.  For example, in the current cadre of 
accredited fastener testing labs, there are many labs located outside the United States; there are labs 
owned by fastener manufacturers; there are labs owned by the raw materials companies and there are 
independent labs.

The lab issue gets even more crucial when we start looking at the fields of testing.  Enclosure 2 is a 
tabulation of the U.S. based FQA accredited labs and the various fields of testing where accreditation 
has been obtained.  On page 6 of this tabulation, there is a summation for each field of testing.  I call 
your attention to the mechanical testing portion where for vibration testing, there are only 11 labs of the 
137 labs hat have accreditation status.  For fatigue testing there are only 19, for prevailing torque 18, for 
impact testing 23, etc., etc.  The bottom line from all this is that for one to say that 500 accredited labs 
are sufficient, or 600 or 1000, is foolhardy.  What if we had 1000 labs accredited and they were all foreign, 
or they were all owned by manufacturers, or none of them were accredited for one of the fields of fastener 
testing called out in the standards?

It is the position of the GIFWG that there needs to be a more precise way of ascertaining how much 
laboratory support will be needed to accommodate the volume of fastener business impacted by the 
FQA. To this end, I suggest that NIST immediately charter a group of experts to analyze both the 
laboratory and FQA fastener applicability issues that we have surfaced. Department of Commerce 
statistics project that over the next 8 years, the annual sale of industrial fasteners manufactured in the 
United States will exceed $8 billion. It is imperative that implementation of the FQA meet its stated 
objectives without jeopardizing this multi-billion dollar industry.

Respectfully yours,

James D. Nicolo
Director, Engineering and Technical
Services Office