Paul Krumhaus AMIS Support Contractor - PowerPoint Presentation

Slide1

Paul KrumhausAMIS Support Contractor6 June 2019

Item Unique Identification (IUID) Implementation PlansEssential Informationfor Planners

Includes change to the $5000 IUID mandate!

(Slide 19)

Note: This briefing and subsequent revisions are down-loadable from http

://www.usarmyamis.army.mil/AIT.html

Slide2

The Value Proposition

A GOOD IUID IMPLEMENTATION PLAN, WELL-EXECUTED, LEADS TO A COMPLIANT DATA MATRIX MARK, A SIM ENABLER!

Serialization

IUID

SIM

SIM – Serialized Item Management

Slide3

Contents

What is Item Unique Identification (IUID) and how does it relate to serialization?

Why is IUID important to the Army and DOD?

What are the stages of IUID Implementation?

Which Items require IUID?

What is the difference between items requiring SIM and items requiring IUID?

What are the responsibilities of the lifecycle manager of “Tangible Personal Property”?

What are the major topics that need to be addressed in an IUID Implementation Plan?

How can the use of Systems Planning and Requirement Software (SYSPARS) help produce a good implementation plan?

The importance of the quality assurance of marks.

What, historically, have been high risk areas in IUID planning and implementation?

What future changes in IUID policy and implementation are expected?

Where can a planner find information/get help?

Backup

Alternatives to specifying Construct #2

Examples of IUID plan execution failures

Slide4

IUID / UII Definitions

Item Unique Identification (IUID) means a system of marking items delivered to the DOD with unique item identifiers that have machine-readable data elements to distinguish an item from all other like and unlike items. “IUID” generally refers to the program, rather than the data.Unique Item Identifier (UII) means a set of data marked on items that is globally-unique, unambiguous, and robust enough to ensure data information quality throughout life and to support multi-faceted business applications and users. The UII is the data.

The UII

is Like a Social Security Number - for

Things

Slide5

Assign an item a globally-unique identification number1Register that number and supporting pedigree information in a central databaseApply a permanent machine-readable mark, containing that Unique Item Identifier (UII), to the item2Use that globally-unique identification number for life cycle management of the itemDOD and Army transition to use of IUID involves:The marking of millions of items meeting IUID criteria that are already in the inventory and of others that are being acquiredAutomated systems enabled to use the UII data element

IUID Simplified

DETAILS

1 Will

functionally

replace the

SN (SN will remain)

2 Enables error-free data

transfer

Slide6

UII Is Globally Unique

SN 00002345

SN is

Not

Globally Unique

Serial Number (SN) vs. UII

UII:

Unique Item Identifier

Slide7

UII Is Globally Unique

UII=D12374HW76-2100002345

UII=D44L2300002345

UII=D7932800002345

UII=D9VW0100002345

UII=D881024432700002345

UII=D68D2200002345

Serial Number (SN) vs. UII (Cont’d)

SN 00002345

SN is

Not

Globally Unique

UII:

Unique Item Identifier

Slide8

SERIALLY

MANAGEDBECOMES IN EFFECTUNIQUELY MANAGED

MANUAL DATA ENTRYBECOMESAUTOMATED DATA ENTRY

1005678

D192071005678

Transitioning to IUID - a Simple Concept

IUID: Item Unique Identification

Slide9

Importance of IUID

Why is IUID Important to the Army and DOD?

Enables reliable unique item level traceability across all DOD business systems.UII is a single data element that uniquely identifies a tangible item.

DATA

UII =

Common

Key

Slide10

BUSINESS RULE #1 “The UII shall be derived from its discrete component data elements or UII data set encoded as a single element. The UII is not required to be marked on the item as a separate data element.”

1 This example uses Text Element Identifiers2 This example uses MH10.8.2 Data Identifiers* Or Lot Number, or Batch Number

EID: Electrically Initiated DevicesIAC: Issuing Agent CodeIUID: Item Unique IdentificationUII : Unique Item Identifier

Encoding the UII

Concatenated

UII

UII

Construct #1

1

EID

MFR

0CVA5

Serial No

. SER 786950

UII Construct #

1

D0CVA5786950

IAC

*

CAGE

Serial No.

UII

Construct

#2

2

EID (

12V)194532636

Orig. Part No.*

(1P)1234

Serial

No

. (S)786950

UII Construct

#2

UN1945326361234786950

IAC

DUNS

Orig.

Part No.

Serial No.

*Commercial

and

Government

Entity

Slide11

IUID- Essential to Materiel Readiness

Value

Processes

Analysis

Information Systems

Supply Chain Events

Uniquely Identified Items

Unique Item

Identifier (UII)

Machine Readable Marking

Automated

Data

Collection

Item Unique Identification (IUID)

Financial Management

Warranty Management

Tracking Item Performance & Age

Failure Analysis

Reliability Improvement

Engineering Design Analysis

Maintenance Productivity

Supply Productivity

Safety

Accountability

READINESS!

Strategic Serialized Asset Management

Capabilities

Requirements

Objectives

Resources

Payback

Speed and Precision in Data Capture

Functions supported by IUID

Slide12

IUID Success

IUID Success May be Described as:Integration of item data across Federal and industry asset management systems, as envisioned by the DoD Business Enterprise Architecture (BEA), to include improved data quality and global interoperability and rationalization of systems and infrastructure.Improved item management and accountability.Improved asset visibility and life cycle management.Clean audit opinions on item portions of DoD financial statements.

Slide13

Automatic Identification Technology (AIT) is a Key to Data Integrity

D123455513HGR13136574867635009

UII can contain up to

50

characters

Each uniquely identified item must bear a data matrix symbol encoding

the data from which its Unique

Item Identifier (UII)

is derived

Goal:Eliminate key entry of data!

Tomorrow ?

Today

Imager Enables Error-Free Data Transfer

Slide14

I

Focus of: MATDEVS ILSCs

DFARS 211.274-2 & 252.211-7003

Army Directive 2016-21

AR 700-145

Write IUID Plan Determine items to be marked

II

Determine and document how and where to mark

Focus of:

MATDEVS Suppliers Depots

III

Mark items and register pedigree information

Focus of:

Suppliers

DepotsService Bureaus

IV

Focus of:

Functional proponents Automated Information System (AIS) PMs

Stages of IUID Implementation

Involves integration of AIT in AIS

Use the Unique Item Identifier (UII) in Business Processes – Create Value!

ILSC: Integrated Logistics Support Center

MATDEVS: Materiel Developers

MIL-STD-130 (latest)

DoD Guide to Uniquely Identifying Items

MIL-STD-130 (latest)

DoD Guide to Uniquely Identifying Items

Slide15

UII -

Marked

Property

Maintenance

Management

AIS

Accommodating

UII and AIT

Automatic Identification Technology

(Readers)

IUID-Enabled Maintenance Management

GCSS-A

GCSS-A

CL

II\, V and IX*

CL

VII

UII: Unique

Item

Identifier

CL: Supply Class

GCSS-A: Global

Combat Support System - Army

MATDEV Focus

Elements of an IUID-enabled Solution

* Marked at maintenance trigger events

AIT: Automatic

Identification

Technology

AIS: Automated

Information

System

IUID: Item

Unique

Identification

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A Successful IUID Implementation Plan

Describes:The systemHow to determine which systems and components require IUIDThe roles of each stakeholder in IUID implementationContractual requirements relating to IUID.A reliable quality assurance processFunding requirements and sources

Slide17

Items that require SIM must be serialized and uniquely identified (IUID)Items that do not qualify for SIM but for which the initial Materiel Developer (MATDEV) desires IUID are serialized and uniquely identified (IUID) but are not serially tracked in GCSS-A and LMP.

=

IUID

SIM+

SIM – Serialized Item Management

What Gets IUID?

Slide18

Items Requiring IUID

OSD: Office of the Secretary of DefenseNSN: National Stock NumberUII: Unique Item Identifier

Which Items require IUID?

DODI

8320.04 was revised in Sep

15 and assigns the Military Services the task of writing their IUID policies, including their IUID criteria.

AR

700-145

is one of the two primary Army IUID policy documents and was

revised in Feb

2016

.

The second primary Army IUID policy document, the interim

Army Serialized Item Management (SIM) Policy was published as

Army

Directive (AD) 2016-21

in May 2016.

Do NOT attempt to use DODI 8320.04 to determine IUID criteria

.

Any item that is required to be serially managed in the Army will require IUID

. The UII will eventually

functionally

replace the serial number (items will continue to have serial numbers

). AR 700-145 authorizes MATDEVs to require IUID for additional items.

IUID and SIM criteria apply to all tangible personal

property,

regardless of whether it has an NSN (standard and non-standard

).

DFARS 211.274-2 lists additional IUID criteria mandatory for acquisitions

across the DoD.

(NOTE; IMPORTANT CHANGE to that! See next page.)

Unit

level personnel are not authorized to IUID-mark items without authorization and direction from higher HQ.

Slide19

CAC – Common Access CardDFARS – Defense Federal Acquisition Regulation SupplementSIM – Serialized Item Management

Items Requiring IUID (Cont)

The mandate to apply IUID to all delivered items with a unit price of $5000 or greater has been changed

On 9 Feb 18, the Office of Deputy Assistant Secretary of the Army (Procurement) (DASA-P) provided new direction.(PARC Policy Alert #18-39) to Army Contracting Command.

The direction is outlined below:

To determine the items that require IUID, requiring activities apply the criteria outlined in

DoDI

8320.04, AR 700-145 and Army Directive 2016-21 (Interim SIM Policy).

Contracting officers shall include the clause at DFARS 252.211-7003, Item Unique Identification (IUID) and Valuation, in solicitations and contracts as prescribed at DFARS 211.274-6(a)(1).

If informed by the requiring activity that a delivered item with a unit acquisition cost of $5,000 or more does not require unique item level traceability, contracting officers may include that item in paragraph (c)(1)(

i

) of the DFARS 252.211-7003 clause.

BL:

If a delivered item with a unit price of $5000 or greater does not require unique item level traceability

at any point in its life cycle, the requiring activity may request that it be listed in (or insert it into) paragraph (c)(1)(

i

) of the DFARS 252.211-7003 clause, which

exempts it from IUID marking and registration

.

PARC Document

(

CAC required).

Slide20

DFARS – Defense Federal Acquisition Regulation SupplementSIM – Serialized Item Management

Items Requiring IUID - Problems

DISCLAIMER: The opinions expressed on this slide are those of the author and do not necessarily represent the official views of any Army organization.

FACT: IUID criteria applicable to the Army is largely contained in three documents: DFARS 211.274-2, AR 700-145 and Army Directive 2016-21.

OPINION:

Army Directive 2016-21 provides solid rationale for SIM. Items meeting the criteria require both serialization and IUID.

Disconnects:

Paragraph 2-2b of AR 700-145 contains IUID requirements that are broader than those in Army Directive 2016-21. It mandates IUID for some items that will derive little or no benefit from unique identification.

Paragraph (a)(3)(iii) of DFARS 211.274-2 requires IUID of all “warranted serialized items”. If the item has a serial number and a warranty, IUID is required. Rationale: IUID was expected to be used in DoD systems to manage warranties. To the best of our knowledge neither GCSS-A nor LMP are structured to do that. The author’s perception is that most organizations ignore this DFARS requirement and KOs do not police it.

Expectation: The disconnects will be fixed in policy but those fixes will move glacially to fruition.

Slide21

Using DFARS 252.211-7003 to specify items to receive IUID (c)(1) The Contractor shall provide a unique item identifier for the following:  (i) Delivered items for which the Government’s unit acquisition cost is $5,000 or more, except for the following line items:  Contract Line, Subline, or Exhibit Line Item Number Item Description ___________________________________________________________________  (ii) Items for which the Government’s unit acquisition cost is less than $5,000 that are identified in the Schedule or the following table: Contract Line, Subline, or Exhibit Line Item Number Item Description ___________________________________________________________________(If items are identified in the Schedule, insert “See Schedule in this table.)  (iii) Subassemblies, components, and parts embedded within delivered items, items with warranty requirements, DoD serially managed reparables and DoD serially managed nonreparables as specified in Attachment Number ____.  (iv) Any item of special tooling or special test equipment as defined in FAR 2.101 that have been designated for preservation and storage for a Major Defense Acquisition Program as specified in Attachment Number ____.

DFARS – Defense Federal Acquisition Regulation Supplement

Contractually Requiring IUID

Slide22

IUID Candidate ProcessPMs may contractually task the contractor to analyze systems to identify those components that require unique item level traceability, and to provide IUID recommendations for review and approval by the PMO.If an IUID candidate process is used, the IUID Implementation Plan:Should describe the candidate process.Should discuss when a contract modification will be processed to document in the DFARS 252.211-7003 contract clause those items that require IUID but were not included in that clause or an attachment at the time of contract award.When SYSPARS is used to produce an IUID implementation plan, insert discussion of the candidate process into paragraph 4.1.1.

DFARS – Defense Federal Acquisition Regulation SupplementSYSPARS: Systems Planning and Requirements Software

Contractually Requiring IUID (

Cont

)

Slide23

WebFLIS and FLIS IUID IndicatorsHQDA has done an initial scrub of items for which the Army is the Primary Inventory Control Activity (PICA) to determine IUID relevance for each NSN. (USAF and USMC have done similar scrubs.) Preliminary results of those scrubs were documented in WebFLIS* in a new field “IUID Indicator”.Today, pending application of changed IUID and SIM criteria and subsequent re-scrubbing, the WebFLIS IUID Indicator is unreliable.The remainder of WebFLIS-listed items have an IUID Indicator of “N”, meaning “not "Y“”. They might have been evaluated as "NO", or not evaluated, or evaluated as "Not Mandatory for all Services, but not prohibited for any Service.”A mechanism for Army item managers to challenge a WebFLIS IUID Indicator decision has not yet been announced.

* The IUID Indicator is not yet a field in FLIS

SIM – Serialized Item ManagementWebFLIS: Web Federal Logistics Information System

Items Requiring IUID (

Cont

)

Slide24

Updating WebFLIS and FLIS IUID IndicatorsArmy Directive 2016-21 states business rules for Serialized Item Management (SIM). Items designated for SIM require serialization and IUID. The Army Enterprise Material Master (AEMM) will be the authoritative source of SIM Yes/No data.Now that the SIM criteria is finalized, there is a need to relook previous IUID Yes/No decisions, make new decisions and adjust WebFLIS/FLIS “IUID Indicators” to document the new decisions. ASA(ALT) and/or Army G4 is expected to disseminate guidance on this subject.Going forward, the FLIS IUID Indicator and AESIP serialization code will be determined and set during the provisioning process for items that are provisioned

Items Requiring

IUID (

Cont

)

Slide25

Today, which Items require IUID?If an item is tangible personal property owned by DOD and meets one or more of the business rules in Army Directive (AD) 2016-21, it is presumed to require SIM and IUID, subject to review using a Human in the Logic (HITL) process.If an item is tangible personal property owned by DOD and does not meet AD 2016-21 business rules but is mandated for IUID by paragraph 2-2 of AR 700-145, it goes through the HITL process to determine SIM applicability but, regardless of the results of that process, requires IUID.Additionally, per AR 700-145, if the initial MATDEV decides that an item requires unique item level traceability, it requires IUID.The following are examples of items sometimes thought to be exempt from IUID and/or SIM that are NOT EXEMPT if they meet one or more of the army directive’s business rules or AR 700-145’s IUID criteria:Commercial-off-the-shelf (COTS) itemsForeign military sales items meeting IUID criteria (See paragraph 3-10, AR 700-145)Non-standard items

DFARS: Defense Federal Acquisition Regulation Supplement MATDEV: Materiel DeveloperNSN: National Stock Number

Items Requiring IUID - Summary

Slide26

They require cataloging in the Army Enterprise Material Master (AEMM).Cataloging in the AEMM is followed by a SIM decision made by a Human in the Logic Serialization Adjudication Group (HITL-SAG).The AEMM then documents whether the item requires Serialized Item Management (SIM)If they require SIM, they require IUID - 100% of the time – It is not optional. However, in some cases determining how to mark an item may be a very difficult problem (i.e. a radio set consisting of multiple receivers and transmitters – which item is marked with the UII for the set?)

More on COTS &

Non-standard

Items

Slide27

Answer the following questions for each item:Does the item require Serialized Item Management (SIM)?Does the item meet one of the mandatory IUID criteria in DFARS 211.274-2(a)? *Does the item meet a criterion in paragraph 2-2b of AR 700-145 that mandates IUID?Does the item require unique item level traceability for anther reason?If the answer to one or more of those questions is “Yes”, the item requires IUID and an acquisition contract for the item must contain the clause at DFARS 252.211-7003 specifying that the item requires IUID (unless the item qualifies for IUID marking after government acceptance, as provided in DFARS 211.274-2(b)).

DFARS: Defense Federal Acquisition Regulation Supplement MATDEV: Materiel DeveloperSIM: Serialized Item Management

MATDEV IUID Decision Process

*

Note new exception to $5000 mandate

Slide28

Army Directive 2016-21

FEDLOG: Federal Logistics Data

Promulgates Army Interim Serialized Item Management (SIM) Policy

Will be incorporated into AR 710-3

If items require SIM, they require IUID.

It states

the criteria for identifying items requiring SIM; it relies heavily on the use of FEDLOG catalog codes.

If the item qualifies based on one or more of the catalog codes listed, the assumption is that it should receive SIM and IUID

.*

If the item is not catalogued but a similar item that is cataloged qualifies based on one or more of the catalog codes listed, the assumption is that it should receive SIM and IUID. *

If

neither the item nor a similar item qualifies based on a catalog code, the assumption is that it should not receive

SIM.

An item coded

pilferable

is not automatically assumed to require SIM and IUID. It requires

closer analysis

to decide whether there is a business case supporting SIM (unless the item also meets

an additional

business rule for SIM

).

Pilferability

is normally addressed with physical security.

Slide29

Army Directive 2016-21 (Cont)

The results of those assumptions are reviewed using a Human in the Logic (HITL) process. The Army G4 is the HITL proponent. The HITL makes the final decision (but subject to appeal by the MATDEV or item manager) on whether there is a regulatory or business case supporting a decision for SIM of the item.

Prior to being considered by the Human in the Logic Serialization Adjudication Group (HITL-SAG), the item must be cataloged in the Army Enterprise Materiel Master (AEMM).

The

authoritative source that documents SIM decisions is the

AEMM

Definitive published guidance on specifics of the HITL-SAG process are (as of March 2019) pending from the Army G4.

Slide30

Differences Between SIM and IUID

Q. What is the difference between deciding whether an item is to receive SIM and deciding whether an item is to receive IUID?

A.

A SIM decision

is based on

the criteria in Army Directive 2016 (which is being incorporated into AR 710-3)

Whether statute, regulation, policy or business value require unique item level traceability.

is reviewed using a Human in the Logic (HITL) process

has, as its ultimate decision-making authority, the HQDA Army G-4

Slide31

Differences Between SIM and IUID

Q. What is the difference between deciding whether an item is to receive SIM and deciding whether an item is to receive IUID?A. An IUID decisionis based onthe criteria in AR 700-145 and DFARS 211.274-2whether the item has been selected for SIM (all items designated for SIM also require IUID).is not subject to HITL reviewhas as its final decision-making authority the “initial MATDEV”However: Only items that are also selected for SIM with that SIM designation documented in the AEMM will be uniquely tracked in the Single Army Logistics Enterprise (SALE).

AEMM – Army Enterprise Material Master

MATDEV:- Materiel Developer

SIM – Serialized Item Management

Slide32

What are some responsibilities of a MATDEV who acquires “Tangible Personal Property”?Ensure all contracts for new equipment, major modifications and reprocurements of equipment and spares, to include Services contracts requiring the delivery of tangible personal, contain the DFARS 252.211-7003 clause requiring IUID for all items meeting SIM/IUID criteria and that the content and attachments required by that clause are completed, identifying each end and embedded item requiring IUID.Develop and execute an IUID implementation plan that:Lists the items requiring IUID and, as a minimum, contains all of the content required by paragraph 3-1 of AR 700-145.Monitor plan execution and update the plan annually, if appropriateEnsure that the requirement for IUID is annotated within the purchase request for items requiring IUIDBe aware that the easiest way to ensure a compliant plan is to use the latest version of the SYSPARS IUID Planning tool. * * NOTE: AMIS can assist PMs with this.

MATDEV – Materiel DeveloperSYSPARS: Systems Planning and Requirements Software

MATDEV IUID Responsibilities

DETAILS

Slide33

Milestone C IUID Implementation Plan ≠Milestone A IUID Implementation Plan

IUID Implementation Plan Required

IUID Implementation Plan Update Likely Required

YEARS?

YEARS?

Fact: IUID Policy, Procedures and Criteria change over time.

BL: IUID Plans Must Normally Change Over Time.

Slide34

Writing IUID Implementation Plans

What are

some

of the major topics that need to be addressed in an IUID Implementation Plan?

IUID marking and registration of new acquisitions

IUID marking and registration of items already in Army ownership but as yet not marked or not registered (AMC has responsibility for getting the marking done).

Specifically who will do what relative to engineering of the mark, physically marking the items and registering the items

How quality assurance will be addressed to ensure:

Correct data correctly encoded in the item mark and the packaging mark

A mark that will last the life cycle of the item

Item and supporting pedigree data is correctly registered in the DOD Registry

The plan for funding the effort

Slide35

MATDEV: Materiel Developer

AR 700-145 requires Item Managers and MATDEVs to submit, annually review, and (if appropriate) update IUID Implementation Plans Over time, mandated policy and procedures change and plans need to evolve. As an example, 2016 was a year of major policy changes that plans need to reflect.Paragraph 3-1 of AR 700-145 lists minimum plan content requirementsThe US Army Logistics Data Analysis Center (LDAC) has automated IUID Plan creation in its Systems Planning and Requirements Software (SYSPARS), a document generation program using a Q&A format.To access and download the SYSPARS software: https://www.logsa.army.mil/lec/syspars/download.cfmSYSPARS output is exported to Microsoft Word and then massaged to eliminate “rough edges” and add any additional information the author wants to have in the plan.SYSPARS is frequently updated as guidance and best practices change and should be downloaded when it is to be used to ensure the most current iteration is being used Unpublished changes to SYSPARS (if any) are found on the AMIS website.BL: SYSPARS makes life easier for the planner.

IUID Implementation Plans

Slide36

SYSPARS IUID PLAN CONTENTS

SYSPARS

SYSPARS Helps Ensure that the IUID Plan Covers All the Bases!

Q & A format

Many multiple choice questions

Identifies many “school

solutions

” by offering optional boilerplate text.

Slide37

Using SYSPARS

AMIS provides the IUID Subject Matter Expertise (SME) for updating of the SYSPARS IUID planning module and can field questions relating to use of the IUID module of SYSPARS.

When the draft

IUID plan

is completed, it requires

coordination

as follows:

First (concurrently) with the LCMC, AMIS and all organizations that the plan says will do something to implement it.

Based on that coordination, make appropriate changes and then coordinate with LDAC.

Based on that LDAC coordination, make appropriate changes and forward through channels for signature.

Once the plan has received final approval, forward a signed copy to LDAC.

We reiterate that SYSPARS is frequently updated as regulations, directives and procedures change and should be downloaded when it is to be used

, to ensure the most current iteration is being used. Using an older plan as a template may produce a non-compliant or incomplete plan.

Continuing Problem: Due to a programming backlog

, there are often multiple policy and procedure updates not yet posted to SYSPARS software

. Solution:

AMIS publishes a list of needed updates to the SYSPARS output

.

Refer to that list on the AMIS IUID webpage and modify the plan as indicated, prior to sending it out for coordination

.

THE CURRENT VERSION OF SYSPARS IS 2.9, RELEASED IN MAY 2019

Slide38

DFARS 252.211-7003 requires that IUID item marks be compliant with MIL-STD-130 (latest version)MIL-STD-130N w/Ch1 requires that item marks:Be encoded with syntax IAW ISO/IEC 15434Meet mark quality requirements of ISO/IEC 15415, AIM DPM 1-2006 or AS9132 (supplier’s option)Ensuring that IUID marks meet those standards requires:Validation (as defined in MIL-STD-130N w/Ch 1) to ensure that the required information is encoded in the mark using proper semantics and syntax; it is performed with an electro-optical imaging device capable of reading the machine readable information (and linked to validation software)Verification (as defined in MIL-STD-130N w/Ch 1) to assess the quality of the data matrix symbol and assigning a grade to results; it is performed with a electro-optical verification device (NOTE: A :”bar code reader” or “scanner” cannot perform verification.)

Item Mark Quality Assurance

Slide39

DFARS 252.211-7003 (Dec 2013 and later) requires that IUID items’ packaging marks be compliant with MIL-STD-129 (latest version)NOTE: Earlier versions of DFARS 252.211-7003 do not require packaging marks to be compliant with MIL-STD-129, however the MIL-STD-129 requirement may be imposed by other contractual provisions.MIL-STD-129R w/ch1 requires that packaging marks:Be encoded using a PDF417 mark with syntax IAW ISO/IEC 15434*Meet quality requirements of ISO/IEC 15438Ensuring that IUID marks meet those standards requires:Validation to ensure that the required information is encoded in the mark using proper syntax and semantics. (In the absence of validation software, validation may be performed manually.)Verification to assess the quality of the PDF417 symbol. (NOTE: Few verifiers can accommodate the size of the PDF417 mark. If verification is not possible, readability should be checked.)Experience is that a very large percentage of packaging marks are non-compliant.

* An exception applies to ammunition and explosives

Packaging Mark Quality Assurance

Slide40

Relying completely on DCMA inspection and acceptance processes to ensure that items are properly marked and registered is not advisable.Some contracts are not administered by DCMA. Items accepted at destination are at particularly high risk for bad marks.For contracts that are administered by DCMA, while DCMA has published IUID QA processes to be followed by their Quality Assurance Specialists, DCMA IUID quality assurance has occasionally missed IUID data deficiencies.Contracts for items requiring IUID and permitting payment by Government Purchase Card (GPC) are at risk for non-registration in the IUID Registry.DFARS 252.211-7003 and 252.232-7003 require that the supplier use Wide Area Workflow (WAWF) to submit a micro purchase receiving report with UID Tab; some suppliers are unaware of that requirement. IUID registration does not occur until the item’s acceptor posts their acceptance action to the WAWF receiving report.

DCMA: Defense Contract Management AgencyQA: Quality Assurance

IUID High Risk Area - #1

Slide41

Incorrectly Encoded DatamatrixMark – Why?

Supplier +

Acceptor +Materiel Developer

SOLUTIONCreate a good planOversee execution of the planEnsure marks are validated.

AR 700-145 3-6c

.

The MATDEV will ensure that all contract for new equipment, major modifications,

reprocurements

of equipment,

and spares will require a separate contract line item number with a contract data requirements list using an IUID

Marking Activity, Validation and Verification Report (DI-MGMT-81804A).

Slide42

Unregistered UII – Why?

Supplier +

Acceptor +Requiring Activity

SOLUTIONCreate a good planOversee execution of the plan

AR 700-145 3-4b

.

Requiring activities are responsible to ensure that within 14 days of item acceptance all newly procured or

recapitalized items will be registered if marked using the DFARS contract clause 252.211–7003.

Slide43

DFARS: Defense Federal Acquisition Regulation SupplementDODI: Department of Defense InstructionFAR: Federal Acquisition Regulation

Ensuring DFARS 252.211-7003, including a schedule or other attachment listing all items requiring IUID is included in contracts for tangible personal property.DFARS 211.274-2 (currently under revision) requires that vendors apply IUID to all delivered items with a unit price of $5000 or greater as well as those meeting other specified criteria. (See below for a major exception to that requirement.)DFARS 211.274-6 requires that the clause at DFARS 252.211-7003 be included in contracts, however, in order to require that IUID be applied to any items other than delivered items with a unit price of $5000 or greater, a list of those items must either be inserted at the appropriate spot in the clause or provided as an attached schedule or similar document.Note that: DFARS 211.274-2 provides an exception for items acquired under FAR Parts 8 or 12; if advantageous, the government may choose to mark with IUID after delivery. A revision of DFARS 252.211-7003 better accommodating the new IUID criteria published in DODI 8320.04 and eliminating reference to the “$5000 mandate” is in process. In the interim, recent Army guidance* has approved omitting IUID for delivered items with a unit price of $5000 or greater, if they do not require unique item level traceability.

* PARC Policy Alert #18-39

IUID High Risk Area -

#2

Slide44

High Risk Areas - #2 (Cont)

CFR: Code of Federal RegulationsDFARS: Defense Federal Acquisition Regulation SupplementPGI: Procedures, Guidance and Information

Current Text of DFARS 211.274-2, also known as 48 CFR 211.274-2:

(a) It is DoD policy that

DoD item unique identification, or a DoD recognized unique identification equivalent, is required fo

r

all delivered items

, including items of contractor-acquired property delivered on contract line items (see PGI 245.402-71 for guidance when delivery of contractor acquired property is required) -

(1)

For which the Government's unit acquisition cost is $5,000 or more

;

(2)

For which the Government's unit acquisition cost is less than $5,000

when the requiring activity determines that item unique identification is required

for mission essential or controlled inventory items;

or

(3) Regardless of value

for any

-

(i)

DoD serially managed item

(reparable or

nonreparable

) or subassembly, component, or part embedded within a subassembly, component, or part;

(ii)

Parent item

(as defined in 252.211-7003(a))

that contains the embedded subassembly, component, or part

;

(iii)

Warranted serialized item

;

(iv)

Item of special tooling or special test equipment, as defined at FAR 2.101

, for a major defense acquisition program that is designated for preservation and storage in accordance with the requirements of section 815 of the National Defense Authorization Act for Fiscal Year 2009 ( Pub. L. 110-417); and

(v)

High risk item

identified by the requiring activity

as vulnerable to supply chain threat, a target of cyber threats, or counterfeiting

.

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IUID High Risk Area - #3

Ensuring that IUID marks have the correct data, properly encoded

.

Note: Pratt and Whitney reported early in their IUID program that over 50% of sample marks provided by their subcontractors were encoded incorrectly. Compliance has vastly improved since then, but to minimize that risk, you:

Must

contractually

require vendors to provide the DOD Data Item Description DI-MGMT-81804A Verification and Validation

Report, as mandated

by AR

700-145

May

require suppliers to provide an IUID Marking Plan and/or sample marks prior to production and use one of several free military or commercial programs to check encoding (to “validate”)

Should

check the original part number if used in the UII and in Wide Area Workflow (WAWF) to ensure that it is the part number “assigned by the enterprise at asset creation”.

May

contractually require the vendor to (1) validate and verify marks using sampling procedures conforming to ISO 2859-1 and/or (2) retain the resulting validation and verification reports, subject to government inspection. Then periodically review them to ensure that marks are compliant

May

contractually require other mark QA procedures

NOTE: DFARS 252.211-7003 (Mar 2016) now requires (for contracts including a version of that DFARS clause dated Dec 13 or later) validation and verification of marks with an AIT device, but does not require furnishing the government with proof that was done

.

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PL AMIS has reviewed over 550 IUID Plans. These are some of the common mistakes we find:Created using an outdated version of SYSPARS Version 2.7 (Jan19) is current!Obsolete or useless references (more is not always better)Inadequately addressing quality assurance of the item marks. Per DFARS and MIL-STD, marks require both verification and validation quality checks.Contractually specifying a requirement for compliance with MIL-STD-130N w/ch1 does not ensure that the mark will be in compliance. Also note that DCMA personnel do not own the hardware required to measure mark compliance. The only way for the organization that actually makes the mark to ensure it is compliant is to have a verifier, which produces both verification and validation reports. AR 700-145 (18 Feb 2016) specifies a minimum verification/validation requirement.Contractually, DFARS 252.211-7003 requires contractors to verify that item marks conform to MIL-STD-130 (latest version) and para 5.2.7 of MIL-STD 130N w/ch1 requires validation and verification.

DCMA: Defense Contract Management Agency DFARS: Defense Federal Acquisition Regulation SupplementQA: Quality AssuranceSYSPARS: Systems Planning and Requirements Software

Common IUID Plan Errors

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DFARS: - Defense Federal Acquisition Regulation SupplementQA – Quality AssuranceSYSPARS – Systems Planning and Requirements Software

Common IUID Plan Errors (Cont)

Failing to address quality assurance of the marking of the

packaging

of items

with IUID

DFARS 252.211-7003 (Dec 13 and later) requires packaging of IUID items to be marked IAW MIL-STD-129 (latest) = MIL-STD-129R w/ch1

AR 700-145 requires that QA of the packaging’s marks be addressed in the plan. Many plans don’t.

In our experience, marking of packaging is wrong more often than right.

Validation software to check MIL-STD-129 compliance is not widely available, but a manual process is and it is available for download from the AMIS IUID web page.

Failing to

read the IUID plan output in MS Word

before circulating it for coordination

.

Check for internal conflicts (i.e. both specifying the items that will receive IUID and concurrently stating that the contractor will recommend items to receive IUID.)

Check for grammar, incomplete sentences, content in the wrong paragraph, repetition, etc.

Check for clarity. Is it possible for the reader of the plan to misinterpret what you are trying to communicate? If so, fix it before coordinating it

.

If you didn’t use SYSPARS, check content against the minimum requirements of para 3-1, AR 700-145.

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DFARS: Defense Federal Acquisition Regulation SupplementDODI: Department of Defense InstructionGFP Government Furnished PropertyiRAPT: Invoicing, Receipt, Acceptance and Property Transfer OSD: Office of the Secretary of DefenseWAWF: Wide Area Work Flow

Looking to the Future

Expect:

OSD will act to revise the criteria that mandate IUID by amending DFARS 211.274-2 (and eliminating the “=/>$5000 rule”).

DFARS 252.211-7003 will be revised to better conform to the revised IUID criteria codified in DODI 8320.04.

The IUID Registry will no longer be the “GFP Master Data Source

”. DFARS 252.211-7007 and DODI 8320.04 will be changed to reflect that.

HQDA G-4 and/or ASA(ALT) will publish implementing

guidance (to include

defining the

HITL

process)

for Army Directive 2016-21/AR 710-3.

The

DOD Guide to Uniquely Identifying Items

, Version 3.0, 2 Dec 14 will be revised.

ASA

(ALT) and the

Acquisition

community will remain responsible to ensure that newly acquired items requiring IUID are marked prior to acceptance by the government and registered via

iRAPT

/WAWF.

Slide49

AMC: Army Materiel Command

Expect

IUID criteria applicable to foreign military sales is likely to change.

Army G-4 will continue its delegation to AMC of responsibility to ensure that legacy items meeting mandatory IUID criteria are marked and registered and that the industrial base replaces any additive IUID marks with IUID marks embedded in equipment data plates/labels when the equipment undergoes depot-level maintenance

As the Army Executive Agent for legacy item marking, AMC will continue executing an enterprise-oriented Army IUID legacy marking program for Class II, and VII; the program will support initial unit-level application of additive IUID marks to identified unmarked class II and VII legacy items requiring IUID and sustainment (replacement) of marks that become detached or unreadable. (Note: You can contact the AMC IUID team at:

usarmy.redstone.usamc.mbx.iuid@mail.mil)Additional emphasis will be placed on ensuring that non-standard (non-NSN) items are cataloged in the Army Enterprise Materiel Master (AEMM), allowing those items’ SIM status to be determined and documented.MIL-STD-130 w/ch1 will be revised NLT 1Q FY 20

Looking to the Future

Slide50

Important References

Army Regulation 70-1, Army Acquisition Policyhttps://armypubs.army.mil/epubs/DR_pubs/DR_a/pdf/web/ARN3845_AR70_1_FINAL.pdfArmy Regulation 700-145, Item Unique Identificationhttps://armypubs.army.mil/epubs/DR_pubs/DR_a/pdf/web/r700_145.pdfArmy Directive 2016-21, Interim Serialized Item Management (SIM) Policyhttps://armypubs.army.mil/epubs/DR_pubs/DR_a/pdf/web/Army%20Directive%202016-21%20FINAL.pdfDA Pamphlet 700-145, Item Unique Identification Procedures https://armypubs.army.mil/epubs/DR_pubs/DR_a/pdf/web/ARN5049_DAPam700_145_FINAL.pdfThe DOD Guide to Uniquely Identifying Items (the “bible” of IUID): https://dodprocurementtoolbox.com/site-pages/overview-implementationMilitary Standard 130N w/ch1 (Identification Marking of U.S. Military Property) https://quicksearch.dla.mil/qsDocDetails.aspx?ident_number=35521Military Standard 129R w/ch1 (Military Marking for Shipment And Storage) http://quicksearch.dla.mil/qsDocDetails.aspx?ident_number=35520

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Important References (Cont.)

AMC Guide to Mark Sustainment (how to replace bad marks) http://www.usarmyamis.army.mil/AIT.htmlArmy IUID Implementation Plan http://www.usarmyamis.army.mil/CustomerSupport/Final-ImplementationPlan-v3-OGC_5MAR.pdfSystems Planning and Requirements Software (SYSPARS) - program download and user guide (currently under revision to better conform to AR 700-145)https://www.logsa.army.mil/#/lec/sysparsSYSPARS updates http://www.usarmyamis.army.mil/AIT.htmlAMIS IUID Web Page (a gold mine of links to IUID resources)http://www.usarmyamis.army.mil/AIT.htmlSupplier Tips for Getting IUID Done Right (Helpful tips for contractors)http://www.usarmyamis.army.mil/CustomerSupport/SupplierTips_GettingIUIDDoneRight.docx

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One Source of IUID Planning Help

AMIS website: http://www.usarmyamis.army.mil/AIT.htmlNote: This “Essential Information for (IUID Implementation) Planners” briefing is available for download, as are numerous other reference publications.AMIS IUID POC:Email: usarmy.belvoir.peo-eis.list.amis-iuid@mail.mil (703) 806-0547 or DSN 656-0547

When it comes to most aspects of IUID implementation, we’ve been there and done

that, or know people who have.

DETAILS

How can

w

e

h

elp you?

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Backup

Slide54

ADDITIONAL DETAIL ON ISSUES

Issue: Ensuring suppliers encode original part number in the data matrix, without requiring use of Construct #2

Issue: Examples of marking and registration errors

Slide55

Who Selects the Construct Used to Encode the UII?

DFARS 252.211-7003

(5) Unique item identifier.

(i) The

Contractor

shall—

(A) Determine whether to—

(1) Serialize within the enterprise identifier;

(2) Serialize within the part, lot, or batch number; or

(3) Use a DoD recognized unique identification equivalent (e.g. Vehicle Identification Number);

Rationale:

IUID is intended/designed to be minimally disruptive to commercial practice.

In this case, the contractor can use their existing serialization scheme –

If they serialize within the enterprise, they use Construct #1

If they serialize within part number, they use Construct #2

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How to Ensure an Original PN is Encoded in the Datamatrix Mark

Slide57

IUID-related Defects Discovered by the USMC at Blount Island, Florida while processing Prepositioned Afloat Equipment

Examples of Marking and

Registration Errors

Slide58

Defects Found

Data matrix is damaged and cannot be read

Some part number’s in the UII do not match the item’s part number

Some UIIs do not contain the proper syntax

Some UIIs have a serial number in the UII that does not match the item serial number

Some UIIs are not in the registry

TAM:

A2043, A2044

Nomenclature:

PRC-148 Urban (V1) & (V2)

NSN:

5820-01-487-0973, 5820-01-487-0972

Manufacturer

:

Thales Corporations, Inc.

Slide59

Defects FoundData Matrix is unreadable by any scanner: Poor quality dot peen mark from manufacturerSome UIIs do not match registry dataSome UIIs are not registered at all

TAM:

D0017

Nomenclature:

M1102 MCC Trailer

NSN:

2330-01-543-5794

Manufacturer

:

Shutt Industries, Inc.

Slide60

Defects Found

Data Matrix does not contain proper syntax (i.e., header). IUID mark contains item’s literal data.

TAM:

C7033

Nomenclature:

SHOP EQUIP CONTACT MAINT VEHICLE

NSN:

4940-01-333-8471

Manufacturer

:

US Army Armament Research

Slide61

Defects FoundData Matrix does not contain proper semantics - Unknown Data Identifier found “VIN”Some marks contained syntax header with no item dataSome items were registered using VIN method and did not match IUID mark

TAM:

D0215

Nomenclature: MK970 SemiTrl TankerNSN: 2330-01-537-8217Manufacturer: Heil Trailer International

Slide62

DefectData matrix does not contain proper syntax and contains literal item data

EC: 512235 Nomenclature: TRAILER ECU GENNSN: 8340-01-533-1697Manufacturer: HDT Expeditionary Systems, Inc.

Slide63

TAM:

D0195

Nomenclature:

FLATRACK, PALLETIZEDNSN: 3990-01-537-1045Manufacturer: Summa Technology, Inc.

Defects FoundData matrix does not meet ISO format standard. Invalid ISO 15434 Header - The first 3 characters found are "CAG“

Slide64

TAM: B0640 EC: 511024Nomenclature: FLOODLIGHT SET,ELECTRICNSN: 6230-01-530-8890 / 6330LLLC10766Manufacturer: Magnum Products

Defects FoundIUID mark does not contain proper syntax (i.e., header) Manufacturer used UII Construct 2 for creating the data matrix however registered the item using UII Construct 1

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EC: 07002Nomenclature: TRICONNSN: 8145LLLCC2971Manufacturer: Charleston Marine Containers, Inc.

Defects FoundIUID marks do not contain the proper syntax. IUID marks contain literal data identifiersManufacturer registered items with UII that did not match data matrix

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TAM: A0273 / A0097Nomenclature: RADIO SET (20w) / (50w) NSN: 5820-01-557-8450 / 5820-01-565-9999 Manufacturer: Harris, Inc.

Defects FoundA0273 contained “Parent” IUID labels to be applied on the record jacket. A0097 did not come with “Parent” labels Some radio sets have the parent IUID registered and others do notSome subcomponent UIIs have not been registered

Slide67

Supplier +

Acceptor +Material Developer

Cause of Errors