## Facts

- The United States Marine Corps issued a Request for Quotations (RFQ) to Federal Supply Schedule (FSS) contractors for the design, manufacture, and supply of approximately 120,000 flame-resistant shirts.
- The RFQ requested shirts in standard size categories: small, medium, large, extra-large, and XX-large.
- The RFQ required responsive contractors to submit two large-size sample shirts for flame-resistance testing.
- The RFQ did not include dimensional specifications (e.g., chest, sleeve, or length measurements) defining each size category.
- Before the due date for quotations, Quantico Arms and Tactical Supply, Inc., an FSS contractor, filed a pre-award protest at the Government Accountability Office (GAO).
- Quantico argued that without dimensional size specifications, it could not prepare a responsive quotation and vendors could not compete on a common basis because “large” (and other sizes) may vary by manufacturer.
- The Marine Corps responded that its primary concern was the flame-resistant performance of the shirts rather than strict uniformity in garment dimensions, that the size description was sufficient for a commercial-item FSS purchase, and that the Marine Corps had previously bought similar shirts from commercial vendors using similar size descriptions without problems.

## Issues

1. Whether an FSS RFQ for commercial apparel is improper or ambiguous for specifying standard size categories (S–XXL) without stating dimensional measurements for each size.
2. Whether the lack of dimensional size specifications prevented vendors from competing on a common basis and preparing responsive quotations.

## Decision

- GAO denied the protest.
- GAO found the Marine Corps reasonably described its needs for this commercial-item FSS procurement by using standard commercial size categories and requiring large-size samples for flame-resistance testing.
- GAO concluded the RFQ was sufficiently clear to permit vendors to compete and submit quotations on a common basis, even without a measurement chart.
- GAO determined Quantico did not show that the challenged sizing description created a material ambiguity or otherwise caused competitive harm warranting sustaining the protest.

## Legal Principles

- Agencies have discretion to determine and describe their minimum needs, and GAO will not object where the agency’s approach is reasonable and consistent with the procurement.
- In commercial-item acquisitions, including those conducted through the FSS, agencies may rely on common commercial descriptions and standards where they reasonably convey what is required.
- A solicitation must provide enough detail for offerors to prepare quotations and compete on a reasonably equal basis, but it need not eliminate every possible variation associated with commercial products.
- A protester challenging a solicitation term must show that the term is unreasonable, materially ambiguous, or otherwise improper, and must demonstrate competitive prejudice.

## Conclusion

In *Quantico Arms and Tactical Supply, Inc.*, GAO rejected a pre-award challenge to a Marine Corps FSS RFQ for flame-resistant shirts, holding that the use of standard commercial size categories without dimensional specifications—paired with a sample submission requirement for flame-resistance testing—reasonably described the agency’s needs and did not prevent common-basis competition.


Quantico Arms and Tactical Supply, Inc., 2008 WL 4394896 (2008)