Public Comments 2007-D007-M. Paulini

I am submitting these comments as a member of the general public, not as a representative of the Agency for which I work - The Defense Contract Management Agency. However, my comments are based on my experience dealing with contractors and IUID over the past couple of years. I recommend you include more clarification for some of the IUID data elements. For the most part, the clarification is needed for vendors which use the Wide Area Workflow (WAWF) to create a Material Inspection and Receiving Report and enter IUID data on the WAWF UID data entry forms. Original Part Number: The proposed change reads ?Original part number (if there is serialization within the original part number)?. Vendors are confused as to whether they can enter the delivered item?s part number when UID Type 1 is the construct used (UID Type 1 is concatenated Issuing Agency Code + Enterprise Identifier + Serial Number). Your changes should address the following: 1. Is the Original Part Number only provided when there is serialization within the Original Part Number (i.e., UID Type 2)? 2. Can the vendor enter the Original Part Number in the WAWF form (or direct entry to the Registry) when it does not use UID Type 2 (e.g., using UID Type 1, ESN, VIN, etc)? WAWF will allow data entry of Original Part Number when any UID type used, including ESN, VIN, GRAI, GIAI, etc). 3. Vendors are also confused with the word ?Original?. For example, a vendor will be delivering a Widget and the company's current part number is 123ABC-005. The Widget has evolved over the years. The true original part number in the company?s configuration management system was 123ABC-001. I interpret the data element to mean that at the time the UII is assigned to the asset, the UID Original Part Number is the company?s current part number as recorded in its configuration management system. That is, for an item delivered today, the UID Original Part Number would be 123ABC-005, not 123ABC-001. If I am correct, I recommend you clarify the meaning of Original Part Number. Lot or Batch Number: Similar to Original Part Number: 1. Can a Lot or Batch Number be entered if UID Type 2 is not used? 2. WAWF allows entry of both the Original Part Number and Lot/Batch Number when UID Type 2 is chosen. Should this be allowed? If not, then the clause should state that only Original Part Number or Lot/Batch Number should be used. Current Part Number: The proposed definition for Current Part Number is ?Current part number (optional and only if not the same as the original part number).? 1. There is no clear guidance on the DoD IUID web site that defines Current Part Number. And, the clause does not tell the vendor it must use the UID web site to obtain the definitions. There are too many documents pertaining to UID and the community must read all of them to try to understand the entire program. Thus, the clause must provide a clear definition. 2. Your use of ?optional? means the vendor never has to report the Current Part Number ? even if the asset has been modified. If an asset is modified to a newer part configuration, must the Current Part Number be reported and submitted? If so, then ?optional? can not be used. 3. My understanding is a Current Part Number must be reported when the asset has been modified to a different configuration from that used at the time the UID was assigned to it. For example, a contractor has a contract which requires it to perform overhaul and maintenance on units it receives. The contract also states that the vendor will also upgrade the item to the latest configuration. This normally means the item will be modified to a match a newer part number. When the vendor delivers the modified asset, it must report and submit the Current Part Number for the modified part. If that is correct, then your definition should be further clarified to explain when Current Part Number must be reported and submitted. 4. The IUID Software User?s Manual Version 3.4 (June 29, 2007) states the Current Part Number is ?Used only if the item's current part number is different from the Original Part Number. It must be provided if the Current Part Number Effective Date is provided. ? Current Part Number Effective Date: The proposed change reads, ?Current part number effective date [(optional and only if current part number is used)].? 1. The use of ?optional? means the contractor never has to report the effective date. 2. Within WAWF, if a Current Part Number is entered, the vendor must enter an Effective Date. It should be changed to state the effective date must be reported and submitted when a Current Part Number is reported and submitted. 3. The IUID Software User?s Manual Version 3.4 (June 29, 2007) states the Current Part Number Effective Date is ?The date the item was modified or changed to the current part number from a previous part number. Must be provided if Current Part Number is provided.? 4. The clause should be changed to be consistent with all other guidance and should specifically state when the Effective Date is required. Acquisition Value: 1. The proposed change does not mention anything about the increase in value to an asset because of a change in the Current Part Number. In WAWF, this value is called the ?Current Part Cost?. In the IUID Software User?s Manual Version 3.4, it is called ?Acquisition Value? (not to be confused with Acquisition Cost. The Manual states the Acquisition Value is ?The cost incurred by the DoD when a part number changes, the value added to an item when it is updated. Acquisition Cost must be provided if Current Part Number is provided. Provide only when Current Part Number is provided.? 2. The IUID Flat File Specification, Version 2 (June 19, 2007) defines Acquisition Value as ?The cost incurred by the DoD when the part number changed.? 3. The IUID XML Data Submission guide calls this value ?Current Acquisition Value?. It defines the data item as ?The cost incurred by the DoD when a part number changes. Must be provided if Current Part Number is provided. Provide only when Current Part Number is provided.? 4. Shouldn?t the clause, the IUID Software Manual and WAWF be consistent? Shouldn?t the proposed DFARS change include the value added because of the Part Number change?