Q: I just looked up DODI 5000.64 and am more confused than before. I could not figure out what “property is subject to the DODI” . We sell to the Government daily and have for over 35 years…. For example, the Government purchases valves from us where unit value is $6,000. Nothing in our contract states MIL-STD-130 or DFARS 252.211-7003. Are we required to put UID tags on the items? Thanks! – Denise K.
A: The new DoDI specifically removes the dollar amount from the consideration nor is it likely these valves have a DoDI 5000.64 requirement, so I think we can lay aside the $6,000 cost as a consideration.
So what else could trigger an item level traceability requirement in this case?
- Is the valve a repairable item that would be returned for repair or modification? If so it could be considered Government Furnished Property at that time and IUID would apply.
- Is the valve tracked as an individual asset because of its criticality to system performance or because of maintenance or safety requirements?
- Is the valve a cost driver for the system and the PM has determined it should be tracked to measure performance?
The fact that nothing in the contract states MIL-STD-130 or DFARS 252.211-7003 is a little concerning from the Government’s perspective. Is this an inherently governmental part or dual use? If it is a commercial use item, then perhaps the PM Office has determined commercial marking is sufficient. Mil-STD-130 (i.e. item marking) and MIL-STD-129 (i.e., packaging) are common in most government acquisitions regardless of whether IUID is specifically called out with the DFARS clause. They have marking requirements either way, which typically include permanent marking using Human Readable Information and preferences for Machine Readable Information (i.e., barcodes).