# Class Deviation 2018-O0019
# Class Deviation 2018-O0019 - Contractor Personnel Performing in Japan

Status: Active
Date Issued: August 2018
Scope: All DoD contracting officers issuing solicitations and contracts, including those using FAR part 12 procedures for the acquisition of commercial items, that will require contractor personnel to perform in Japan

## Summary

This class deviation establishes a new DFARS clause, 252.225-7976, governing contractor personnel performing in Japan under the U.S.-Japan Status of Forces Agreement. The clause sets requirements for SOFA status designations, personnel accountability through the SPOT system, compliance with Japanese and U.S. laws and regulations and logistical support entitlements. It applies to both solicitations and contracts, including commercial item acquisitions under FAR part 12.

## Required Contracting Officer Actions

1. Include clause 252.225-7976 (Deviation 2018-O0019) in all solicitations and contracts, including FAR part 12 commercial item acquisitions, that will require contractor personnel to perform in Japan.
2. Consult with legal counsel and the USFJ/J06 office to determine SOFA Article I(b) status for contractor personnel, and approve SPOT-generated Letters of Authorization only after verifying eligibility criteria in USFJ Instruction 64-100.
3. If requesting SOFA Article XIV status, coordinate with HQ USFJ for final determination in consultation with the Government of Japan.
4. Annotate SPOT-generated LOAs with 'None' for Government-furnished routine medical services when such services are neither available nor authorized in the contract.
5. Authorize logistical support only when determined necessary and appropriate, and obtain specific authorization from the installation commander after coordination with USFJ/J06 for any support beyond the listed items.
6. Direct the contractor, at its own expense, to remove and replace any contractor personnel who fail to comply with applicable contract requirements, including those in this clause.

## Affected Provisions and Clauses

### 252.225-7976,  (Clause)
- Change type: MODIFIED
- Action: Modify clause 252.225-7976

## Notes

SPOT Compliance and Past Performance: Contractor non-compliance with SPOT requirements will be considered in past performance evaluations for future contract opportunities, per FAR subpart 42.15.

Short-Term Personnel: The full range of logistical support is generally not necessary for contractor personnel performing in Japan on a short-term basis of less than 91 days.

Weapons Restrictions: The importation and personal possession of firearms, swords and other weapons is highly restricted in Japan. Contractor personnel must comply with USFJ Instruction 31-207 before bringing any such items into Japan.

Subcontracts: Contractors must incorporate the substance of this clause, including the subcontracts paragraph, in all subcontracts requiring subcontractor personnel to perform in Japan.

## Suggested Questions

You can ask your AI assistant:
- What actions do I need to take for this deviation?
- Does this deviation affect commercial acquisitions under Part 12?
- Which clauses need to be removed from my existing contracts?
- How does this deviation change 252.225-7976 specifically?
- Are there any SAM registration implications?

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Source: https://part52.dev
Generated: 2026-03-20
Memorandum: https://www.acq.osd.mil/dpap/policy/policyvault/USA002186-18-DPC.pdf