Public Comments 2007-D013-M. Schnorenberg

We appreciate the opportunity to comment on the above noted DFARs Case: Reading the (A) Background section of the proposed legislation, paragraph [C] in particular. The legislation allows for "Offered to the Government, without modification, in the same form in which it is sold in the commercial marketplace; ........". My comment on this directly relates to commercially available distributed hardware items. Woodward is a manufacturer of aerospace fuel systems. We procure 2000+ items through distribution with most falling into the "defined" commercially available parts, but we do often require "some" modification. * If we are to mill a slot into a commercially available screw and insert a locking device or drill an additional hole for an anti-tampering device-these would certainly be considered modifications. However, we are buying a commercially available fastener and even with the modification, the base item is still commercially available and the final function of the part has not been altered. If Woodward is to take this out of distribution and contract with a source to procure compliant raw material and then form the part as a make-to-print item, we will still be effected by the same condition that is driving this proposed legislation; availability of the raw material. Lead-times would move out dramatically and our cost would be driven up. * Staying with distributed hardware, does the addition of passivation or fluorescent penetrant inspection to a standard part be considered a modification. Our interpretation is no, because we are cleaning and validating, not really changing the part in any way. We would like clarification on my second point, but also feel as though placing all commercially available items into the same "bucket" and then stating no modification may be over simplifying the intent. Modifying a computer or GPS is different that the modification of a fastener. Consideration to allowing some flexibility within the legislation should be given. Again, thank you for the opportunity to comment. Mark J Schnorenberg Supplier Manager/ Small Business Liaison Officer Woodward-Rockford 815.639.6500 mschno@woodward.com "There ain't but one time to go fishin' and that's whenever you can." -Diron Talbert