Pholcids do indeed have short fangs, which in arachnological terms is called uncate because they have a secondary tooth which meets the fang like the way the two grabbing parts of a pair of tongs come together. Brown recluse spiders similarly have uncate fang structure and they obviously are able to bite humans.
The DCMA is responsible for ensuring the integrity and application effectiveness of contractor EVMS. To this point, the DCMA works with various Government and Industry teams to develop practical EVMS guidance to ensure initial and ongoing compliance with EVMS guidelines in ANSI/EIA-748.
OSP has overall responsibility for coordinating and approving any update to IRM 20.1, Penalty Handbook. OSP's role is to ensure fairness and consistency in penalty administration. This IRM contains exhibits to assist the user in researching penalty issues: Exhibit 20.1.1-1, Penalty Relief Application Chart.