Q: If a contract from the DLA includes this language: “MARK IAW MIL-STD-130N(1), DATED 16 NOV 2012. CONFIGURATION CONTROL APPLIES” without any further details, are we to assume that we must mark our parts (even small dollar items) with UID labels? – Janet K.
A: The short answer is that just that statement by itself would not require you to comply with Item Unique Identification (IUID) requirements. Mil-Std 130 covers all forms of item marking. For IUID to be required, it should state MIL-STD 130 in accordance with IUID requirements at a minimum. You should also have one or both of the following two clauses in the contact to trigger IUID compliance:
- DFARS 252.211-7003, Item Unique Identification and Valuation
- DFARS 52.211-7007, Reporting of Government-Furnished Property
There is also a DLA clause variant of the above which specifically calls out IUID so you should confirm that clause is not in your contract.
It is from: DEFENSE LOGISTICS AGENCY (DLA) MASTER SOLICITATION FOR EPROCUREMENT AUTOMATED SIMPLIFIED ACQUISITIONS (PART 13), REVISION 3 (MARCH 2012)
This reference consolidates many of the FARS, DFARS contract clauses, including the IUID one listed below, into a single document and includes them in total as requirements by its reference. The DLA acquisition bible is the DEFENSE LOGISTICS ACQUISITION DIRECTIVE (DLAD) as you probably already know.
The phrase “Configuration Control Applies” is not necessarily an indication that IUID is required. The National Consensus Standard for Configuration Management is EIA-649-A which does not directly speak to IUID requirements. Had it said something like “DoD serially managed” or “Complying with Serialized Item Management”, then I’d say it could be presumed.
This is not to say you shouldn’t apply IUID to the items that meet the IUID requirements, because you should for consistency since they are likely IUID required by other customers and other suppliers where applicable. But by no means does what you’ve quoted imply IUID would apply to all items provided.
I hope this helps and if you need any help interpreting which items would be required to comply with IUID by the policy or any other policy interpretation, please feel free to reach out to me directly.