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The “QT” on Quality

Assurance versus
Quality Control
Blurring 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 JE F F R E Y A . R E NS H AW

As envisioned by the government- tion between the two has sometimes two, and a brief discussion of how the
wide performance-based contracting been blurred—to the point where terms have sometimes been and con-
(PBC) movement of the 1990s, quali- they have come to be used inter- tinue to be used interchangeably.
ty assurance (QA) and quality control changeably.
(QC) work hand-in-hand to ensure It is important to understand the What Is Quality Control?
the contractual delivery of an excel- difference between quality control The U.S. Air Force Instruction (AFI)
lent product to the government. Yet, and quality assurance, and to ensure 63-501 defines quality control as
the two terms compose two different that the two terms are not used syn-
entities and signify different contrac- onymously. Why is it important? The [T]hose actions that control the
tual responsibilities. government performs QA. Typical production of output to fulfill
Generally speaking, the contractor government contract clauses place requirements for quality in raw or
is responsible for QC, while the gov- QC responsibility upon contrac- produced material and services.
ernment is responsible for QA. That tors, requiring them to do certain Quality control includes a feed-
sounds clear enough, yet in practice things to comply with the require- back process that measures actual
and historically speaking, the distinc- ments. Thus, it is important to have performance, compares it to qual-
a clear understanding as to what ity requirements, and acts on the
About the Author those requirements are. Blurring difference to minimize variation.
MAJOR JEFFREY A. RENSHAW is the definition between the two con- Quality control is the measure-
an active duty judge advocate in the cepts allows contractors unnecessary ment of a process or product by
U.S. Air Force Judge Advocate’s Corps. wiggle room in complying with their an automated process, operator, or
He is a trial attorney assigned to the Air responsibilities, and complicates the other person, with comparison to
Force Directorate of Contract Dispute government’s evaluation and enforce- requirements and action to resolve
Resolution at Wright-Patterson Air Force ment of these contractual duties. variation from a standard.1
Base, Ohio, and is a member of the This article has the modest goal of
Louisiana State Bar. Send comments providing a clear understanding of A recent industry paper written by
on this article to cm@ncmahq.org. quality control and quality assurance Alison Kaelin, a corporate quality assur-
terms, the difference between the ance manager, defines quality control as

22 ■ Contract Management / September 2005


[P]erforming the necessary observa- [T]he process to verify that the trol by the contractor is meant to
tions, testing, and documentation quality of work performed is actu- provide in-process verification that
that verify the work performed ally what was reported by quality the cleaning and painting is being
meets or exceeds the minimum control. Quality assurance is an performed as designed to provide
standards established by the project audit function, used to verify that a quality final product. Quality
specifications or contract. Quality quality control is being performed assurance by the owner is meant
control involves the routine and and performed properly. It may to verify that the quality control
systematic inspections and tests that include review of QC documenta- implemented by the contractor
are conducted to verify that each tion or conducting actual testing meets the requirements of the
phase of the work is in compliance on a spot or periodic basis. Quality specification, to further assure that
with the specification. Quality con- assurance is typically performed by a quality final product will result.5
trol is the contractor’s responsibility.2 the owner or a third-party inspector
on the owner’s behalf.4 Kaelin’s paper also explains that
What Is Quality Assurance? while QC is a full-time require-
The same U.S. Air Force Instruction Practical Differences ment, QA can be full or part-time,
defines quality assurance as Although the paper cited earlier deals or performed at specific stages of the
specifically with the painting industry, painting process. Her paper empha-
A planned and systematic pattern it does an excellent job of laying out sizes that the presence of the owner
of actions necessary to provide the operative differences between QC or a third-party QA evaluator/inspec-
confidence that adequate techni- and QA. tor does not relieve the contractor of
cal requirements are established; its QC responsibilities. Indeed, this
products conform to established In simple terms, the contractor is principle is embodied in the Federal
technical requirements; and satis- fully responsible for every aspect Acquisition Regulation and in Armed
factory performance is achieved.3 of the project from the equipment Services Board of Contract Appeals
and materials, and experience and decisions.6
The industry paper cited earlier training of personnel, to the quality
defines quality assurance as of the final product. Quality con-

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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 usage of the two terms. One board been incurred in implementing a
As noted by the Office of the decision involved the U.S. Army’s quality assurance program during
Secretary of Defense’s “Share A-76” Missile Command and described the performance of a contract for
Web site, “QA and QC are frequently its “project assurance directorate,” the repair and overhaul of aerospace
confused and mistakenly used inter- which was responsible for quality con- ground equipment assigned to Tinker
changeably. On one hand, they refer trol.11 Another one, The Wayne Kerr Air Force Base, Oklahoma.” It then
to distinctly different actions per- Corporation case, involved a contract explains that the contract included
formed by different organizations.”7 that called for the contractor to design a number of provisions pertaining
The site explains that QA involves and develop a capacity measuring to inspection of the work and “qual-
actions taken by government quality system. The contractor claimed that ity assurance” and then includes the
assurance evaluators (QAEs) to deter- the QC contract specifications were contract language which is a clause
mine if goods or services meet the ambiguous, and that the government titled “Quality Control and Inspection
contract requirements. was requiring additional work. and Acceptance.” Any meaningful
On the other hand, QC refers to a “Quality control” and “quality distinction between the two terms
contractor’s actions taken to control assurance” appear to be used inter- was blurred in the following opinion
production of goods or services to changeably throughout the opinion: language:
ensure compliance with the contract
requirements. Other organizations It is apparent that appellant was An initial recommendation was
have also noted this confusion. For unfamiliar with the details and made to disapprove the award
example, the Husky Injection Molding procedures required by NASA con- based on appellant’s lack of
Systems, Ltd., Web site states tracts, particularly the requirement inspection and quality assurance
of NPC 200-4, a NASA quality con- personnel and procedures. However,
We often hear the terms quality trol procedure, compliance with after appellant had agreed to pro-
assurance and quality control used which was required by contract vide an acceptable quality control
interchangeably. However, I like to terms. The appeal file indicates and inspection manual and to
think of quality control as a reactive that respondent delegated certain provide acceptable inspection and
approach to quality: Doing inspec- contract administration author- quality control services as required
tions or taking part measurements, ity and quality control inspection by MIL-2-45208A, the appellant was
finding an out of spec part and fix- responsibility to the Defense awarded the contract.14
ing the process. Whereas quality Contract Administration Service.
assurance is proactive: Using the Several of the technical difficulties However, later in the opinion the
information we gather in quality appellant and its subcontractors board lists quality control and quality
control with tools such as pare to experienced in performing the assurance as separate components.
and control charts to monitor pro- contract work centered in compli- The board explained, “The U.S. Air
cesses and defect changes before ance with the quality assurance Force repeatedly indicated its inten-
the parts are out of spec.8 procedures required by the con- tion to implement fully a quality
tract…respondent wrote appellant a control, inspection, and quality assur-
The American Society for Quality letter…commenting on appellant’s ance procedure that would comply
(ASQ) has noted the sometimes-inter- December monthly progress report with the contract….”15
changeable use of quality control and and stated in part: “You are advised Yet, the board reverts back to
quality assurance as well, opining that your inspection plan was not characterizing the concepts as inter-
that both terms “have many inter- approved as written, however, we changeable, in its language, “At
pretations because of the multiple are informed that DCAS Quality various times during performance of
definitions for the words ‘assurance’ Assurance Representatives have the contract, government representa-
and ‘control.’”9 The Tennessee Center contacted your subcontractor for tives had requested that appellant
for Performance Excellence (TNCPE) necessary corrections and guide- furnish listings of its quality control
likewise notes the multiple definitions lines.”12 (Emphasis added) and/or quality assurance personnel.”
for “assurance” and “control,” stating, To further illustrate, although the
“Often, however, ‘quality assurance’ The case of Big 4 Mechanical employees on an August 24, 1972, list
and ‘quality control’ are used inter- Contractors, Inc.,13 adds to the blur- given by the contractor to the U.S. Air
changeably, referring to the actions ring of the QC/QA terms—it treats Force (USAF) were all QC personnel,
performed to ensure the quality of a the distinct concepts as synonymous. the board interchangeably uses the
product, service, or process.”10 The Armed Services Board of terms as follows:
A review of several Boards of Contract Appeals decision describes
Contract Appeals decisions also sheds the contractor’s claim as one for On 22 January 1973, Mr. Charles E.
some insight as to the “loosey-goosey” “additional costs alleged to have Towe furnished a list of appellant’s

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quality assurance personnel which The PBC team is interested in uti- meeting the government’s performance
showed changes from the 24 August lizing systematic quality assurance standards. The government’s quality
1972 listing as follows: Robert Van surveillance methods in monitor- assurance surveillance plan is the inter-
Atta was substituted as quality control ing contractor performance. The mittent check on its effectiveness.23
manager, Ken Reeves was listed under contractor is responsible for man-
Category A Shop, and Robert Billins aging and controlling the output QA/QC Confusion
and Delain Baxter had been added to of its service through its quality As discussed earlier, while the trans-
quality control for the service line.16 control plan…. Effective utiliza- formation in government contracting
tion of these two components, the to performance-based contracting has
Conflicting usage of the two terms contractor’s quality control plan and definitely aided in marking the delin-
is peppered throughout the decision. the government’s quality assurance eation between QC and QA, there
In sum, it appears that in the 1970s plan (QASP) is a key reason why lingers some residual confusion and
when the decision was rendered, quality performance-based contracting is a overlapping between the two.
control was considered to be a subset superior contracting methodology.”21 Confusion between the two
of quality assurance, whereas in pres- terms—what is meant by quality
ent day, both are separate entities. The QASP details how and when assurance and quality control—should
Another case arising from Tinker the government will survey, observe, be avoided. How can this be done?
Air Force Base, Bailey et al v. United test, sample, evaluate, and document Government contract attorneys should
States, involved an action by 30 fed- contractor performance according to review contract clauses carefully to
eral employees, who were employed the performance work statement. The ensure that the two terms are defined
as “quality control inspectors” by the QASP explains, “The government’s and differentiated, with a clear con-
U.S. Air Force in the mid 1970s.17 QASP and the contractor’s quality tractual spelling-out of the two items.
At that time, the air force was still control plan (QCP) work together to As an example, the National
responsible for contractual QC, or ensure project performance standards Institutes of Health (NIH), a federal
was characterizing quality control as are met.”22 agency, adopted use of the American
quality assurance. In either event, the This interaction between the con- Institute of Architects MASTERSPEC©
point is that the two terms were being tractor’s QCP and the government’s specification system for its construc-
used virtually synonymously. QASP is now recognized in FAR tion contract specifications. Portions
37.602-2: of the MASTERSPECS had to be
Emergence of 1990s altered, however, to reflect the proper
Performance-Based Contracting Agencies shall develop quality usage of QA and QC terms, as follows:
The Office of Federal Procurement assurance surveillance plans when
Policy’s letter of April 9, 1991, acquiring services….These plans Quality Control Versus Quality
established a federal policy that all shall recognize the responsibility Assurance: Quality control is the
government agencies would use per- of the contractor…to carry out its responsibility of the construc-
formance-based contracting (PBC) quality control obligations and shall tion contractor. Quality assurance
methods to “the maximum extent contain measurable inspection and is the responsibility of the NIH.
practicable henceforth.”18 As part of acceptance criteria correspond- Terminology: The A/E must change
that policy, agencies were directed to ing to the performance standards the terminology used through-
assign contractors full responsibility contained in the statement of work. out Divisions 2 through 16 of the
for quality performance, whereas the The quality assurance surveillance MASTERSPEC documents. Most
government would develop “perfor- plans shall focus on the level of per- technical sections in MASTERSPEC
mance standards and surveillance formance required by the statement Divisions 2 thorough 16 include
plans to facilitate the assessment of of work, rather than the method- a paragraph titled “Quality
contractor performance.”19 Further, ology used by the contractor to Assurance.” “Quality assurance”
the policy letter encouraged agencies achieve that level of performance. is also used in verbiage throughout
to avoid “cumbersome and intrusive these technical sections. For all NIH
process-oriented inspection and over- FAR Subpart 46.3 requires that projects, all references to “qual-
sight programs to assess contractor in service contracts, all contractors ity assurance” must be changed
performance.”20 must have a QCP; it is a mandatory to “quality control” to assign
The interaction between contractor- element of the performance work responsibility to the construction
provided QC and government-pro- statement. The interaction between contractor.24
vided QA is critical to ensure that the two is described as follows:
a quality product is delivered to the Previously, we looked at some
government. As explained on the The contractor’s quality control plan is examples of confusion between these
government’s Know Net Web site: the contractor’s everyday tool to insure terms in several industries. This still

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is of some concern in the USAF, as tor is required to furnish.…The provides the measures needed to
AFI 63-124 states, “An inspection of contractor, and not the government, lead the contractor to success.
services clause is required for every is responsible for management and Once the quality control program is
service contract. You should adopt the quality control actions to meet the approved, careful application of the
quality control and quality assurance terms of the contract. The role of process and standards presented in
practices used in the commercial the government is quality assurance the remainder of this document will
marketplace to the maximum extent to ensure contract standards are ensure a robust quality assurance
practicable.”25 If there is confusion achieved. In this contract the qual- program.29
in the commercial marketplace as to ity control program is the driver for
usage of the two terms, and the USAF product quality.…The first major Another example of a template
is to rely upon that marketplace for step to ensuring a “self-correct- developed for mass use that well-
its own contractual QA and QC prac- ing” contract is to ensure that the defines QC are specifications
tices, might there not be a danger of quality control program approved drafted by the USAF Center for
confusion between the two terms in at the beginning of the contract Environmental Excellence (AFCEE)
its contracts?
It is impossible to survey the uni-
verse of federal government agency
solicitations to see if QC and QA are
adequately defined and administered.
It is my belief that in general, federal
agency solicitations do a good job
with definitions and the respective
roles and duties each has for the gov-
ernment and the contractor.
For example, the Office of Federal
Procurement Policy issued a template
for a statement of work (SOW) to be
used in elevator maintenance and
repair contracts. An initial caveat
to the SOW template stated that it
was based upon “commercial mar-
ket practices as determined by the
market research conducted on this
requirement.”26 The template con-
tains a separate paragraph discussing
QC, which reads in part, “Contractor
shall develop and maintain a qual-
ity program to ensure maintenance
and repair services are performed in
accordance with ANSI/ASMW A17
and other applicable standards and
codes.”27
The separate QA paragraph simply
reads, “The government will peri-
odically evaluate the contractor’s
performance in accordance with the
quality assurance surveillance plan
(QASP).”28 The template for the QASP
language states in part:

This quality assurance surveillance


plan (QASP) has been developed to
evaluate contractor actions while
implementing this SOW.…The
QASP provides a systematic method
to evaluate the services the contrac-

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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

for use in landscaping contracts. The ment is able to afford itself of available 15. Ibid., at 8.
template states, “Quality control shall remedies to enforce clearly defining 16. Ibid., at 9.
be provided for the entire project…. contractual quality expectations. CM 17. Bailey et al v. United States, U.S. Claim
Responsibility for accomplishing qual- Ct, 3 Cl Ct. 619 (1983).
ity control is the contractor’s.” The Endnotes 18. April 9, 1991, Policy Letter 91-2, “To
template then contains five pages of the Heads of Executive Agencies, and
1. Air Force Instruction 63-501 May 31,
text that lists specific quality control Departments, OFPP,” Allan V. Burman,
1994, “Air Force Acquisition Quality
plan requirements for the contrac- Administrator. FAR Subpart 37.6 imple-
Program,” Attachment 1, “Glossary of
tor. This particular template actually References, Abbreviations, Acronyms, ments OFPP Policy Letter dated April
places some QA responsibilities upon and Terms Explained.” 9, 1991, which first established the
the contractor as well, and notes requirement that results not processes
2. Alison B. Kaelin, “Quality Control and be specified and that requirements be
specifically that the government is Quality Assurance: Defining the Roles stated in measurable terms. This OFPP
not required to inspect a contractor’s and Responsibilities of the Contractor’s Policy Letter was letter rescinded, when
work or to protect a contractor from QC and the Owner’s QA,” paper pre- FAR 37.6 was amended/updated to
the consequences of such work.30 sented at the Painting and Coatings reflect the modern PBC policy. See Know
Such templates evidence federal Expo (PACE 2005), sponsored by the Net, www.knownet.hhs.gov, Topic
agency actions to implement the per- Society for Protective Coatings (SSPC) 2.3, “Writing the Quality Assurance
formance-based contracting goals of and the Painting and Decorating Surveillance Plan.” Know Net is a knowl-
placing more quality requirements Contractors of America (PDCA), at edge management, e-learning, and
upon contractors while placing less www.kta.com/knowledge/PACE2005/ performance support system sponsored
QC&QA%20ABK.pdf. Kaelin is the cor-
responsibility upon the govern- by the U.S. government.
porate quality assurance manager for
ment. Assuming that most—if not 19. Ibid.
KTA-Tator, Inc., Pittsburgh, PA.
all—federal agencies try in good faith
3. AFI 63-501, supra. 20. See www.knownet.hhs.gov, accessed
to comply with this goal, and make on May 2, 2005.
efforts to contractually delineate the 4. Kaelin, at 2.
21. Ibid.
differences between QA and QC, then 5. Ibid.
what is the problem, if any? 22. Ibid.
6. See FAR 52.246-2(k); Rosendin Electric,
In my view, the problem is the fact 23. Ibid.
Inc., ASBCA No. 22996, 81-1 BCA
that some loose usage of the quality ¶14,827. 24. See http://orf.od.nih.gov/policy/vol-
control and quality assurance terms ume4-constructionspecs.htm, Office
7. Office of the Secretary of Defense,
exists in various industries today, of Research Facilities, Development
Undersecretary for Acquisition,
and to the extent that federal agency and Operations, National Institute of
Technology & Logistics, Share A-
contract specifications are supposed 76 Web page, http://emissary.acq. Health website, Section R. Construction
to mirror commercial practices, those mil/inst/share.nsf/CONTDEFLOOK/ Specifications, R.1, Specification Sections,
specifications may themselves mir- About+A-76-Process+Model-Previous+Ci R.1.1, “Quality Control Versus Quality
ror some of the residual confusion rcular+Appeal, accessed on May 2, 2005. Assurance” and R.1.1.1 “Terminology.”
between the two terms. 8. See www.husky.ca/products/quality. 25. AFI 63-124.
Additionally, and strictly on an html, accessed on May 10, 2005. 26. See www.acqnet.gov/Library/OFPP/
anecdotal basis, I have seen firsthand PolicyDocs/afelevator.doc. The Office of
9. See www.asq.org/topics/qa_qc.html,
in contract administration a confu- Federal Procurement Policy, or “OFPP,”
accessed on May 2, 2005. The American
sion in usage of the two terms, and Society for Quality (ASQ) is a 104,000- falls under the Office of Management
a subsequent issue created because member professional association that and Budget (OMB), and provides overall
government QA evaluators allegedly describes itself as “the world’s leading direction of government-wide procure-
performed QC functions and the con- authority on quality since 1946.” ment policies, regulations, procedures,
tractor attempted to use this to its and forms for executive agencies and to
10. See www.tncpe.org/resources/criteria/ promote economy, efficiency, and effec-
benefit in interpreting its quality obli- terminology.asp, accessed on May 10, tiveness in the procurement of property
gations under the contract. 2005. and services by the executive branch of
To fulfill the goals of performance- 11. Protest of Project Software and the federal government. 41 USC 404.
based contracting and ensure that Development, Inc., GSBCA No. 8471-P, 27. Ibid.
contractors know what is expected 86-3 BCA ¶19,082.
of them, precise usage of the QC and 28. Ibid.
12. Wayne Kerr Corporation, NASA BCA No.
QA terms—both in written (contract 29. Ibid.
670-10, 73-2 BCA ¶10,240.
clauses) and verbal form (in practice in 30. See www.afcee.brooks.af.mil/dc/dcd/
13. Big 4 Mechanical Contractors Inc.,
the administration of government con- land/mstrland/mlcs_8.asp.
ASBCA No. 20897, 77-2 BCA ¶12,716.
tracts)—is critical. And, if they do not
fulfill those expectations, the govern- 14. Ibid.,.at 6.

28 ■ Contract Management / September 2005

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