Comment on FR Doc # 2010-30072

Thank you for allowing me to comment on DRARS Case 2009-D038. I am specifically commenting on the changes to DFAR 252.242.7XXX. 1. I am concerned that proposed changes refer only DCMA and DCAA and exclude the other services. 2. FAR 45.105(b) outlines the duties and responsibilities of a property administrator in dealing with deficiencies in a contractor’s property management system. This same section outlines the responsibilities of the contracting officer if deficiencies are not corrected in a timely manner. Financial remedies are in place if a contractor fails to maintain an acceptable property management system. 3. For decades, dating back to Armed Forces Procurement System (ASPR) till the last significant FAR property change it was the responsibility of the property administrator to approve the contractor’s property management system. The last major FAR property change, presumed contractor’s to have an acceptable system and approval was not required. I think that the property administrator should be the individual to approve a contractor’s property system since they have the in-depth knowledge and day-to-day hands-on experience or working with the property management system. Contracting officers have the responsibility to disapprove a systems since this would have a financial impact on the contract. If Department of Defense feels so strongly on DFAR clause 252.242.7XXX I suggest that it should be incorporated as a FAR clause.