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Class Deviation 2018-O0019

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Class Deviation 2018-O0019 - Contractor Personnel Performing in Japan

Status: Active

Date Issued: 2018-08-01

Scope: All DoD contracting officers

Applies to DAF/Air Force: Yes

Summary

This deviation creates a new Defense Federal Acquisition Regulation Supplement (DFARS) clause, 252.225-7976, for contracts requiring contractor personnel to perform in Japan. Contracting Officers must include the clause in all solicitations and contracts, including commercial (Part 12) acquisitions. The clause governs SOFA status, personnel accountability, compliance with Japanese law and USFJ instructions.

Required Contracting Officer Actions

  1. Include DFARS 252.225-7976 (Deviation 2018-O0019) in all solicitations and contracts requiring contractor personnel to perform in Japan, including commercial (Part 12) acquisitions.
  2. Consult with legal counsel and the USFJ/J06 office before making SOFA Article I(b) status determinations for contractor personnel.
  3. Approve SPOT-generated Letters of Authorization only after verifying eligibility criteria in USFJ Instruction 64-100 are met.
  4. Obtain specific authorization from the installation commander, after coordination with USFJ/J06, before approving logistical support beyond the listed categories.
  5. Direct contractors to register in SPOT and maintain accurate, up-to-date records for all SOFA-covered contractor personnel throughout performance.

Affected Provisions and Clauses

252.225-7976, (Clause)

  • Change type: MODIFIED
  • Action: Modify clause 252.225-7976

Notes

SOFA Article XIV Status: Article XIV status is reserved for extremely limited circumstances. HQ USFJ makes the final determination after consultation with the Government of Japan.

SPOT Compliance and Past Performance: SPOT non-compliance is relevant to past performance evaluations under FAR subpart 42.15. COs should document deficiencies.

Weapons Restrictions: Importation of firearms, swords and other weapons is highly restricted in Japan. COs should address weapons needed for contract performance separately in the contract.

Medical Services: USFJ has limited capability to provide Government-furnished routine medical services. Where unavailable or unauthorized, the SPOT-generated LOA must show 'None' for that field.

Subcontracts: Contractors must flow down the substance of clause 252.225-7976 to all subcontracts requiring performance 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?

Source: https://part52.dev

Generated: 2026-04-21 17:40 UTC

Memorandum: https://www.acq.osd.mil/dpap/policy/policyvault/USA002186-18-DPC.pdf