Attachment 0033- Department of Defense Guide to Item Unique Identification Quality Assurance.doc

Department of Defense Guide to Item Unique Identification Quality Assurance

Version 1.0 November 20, 2009 Office of the Deputy Under Secretary of Defense

(Acquisition, Technology & Logistics) Preface

Item Unique Identification (IUID) is an emerging initiative whose value in multiple areas of private sector and Government business enterprise is growing in recognition. Across the globe, manufacturers and users of IUID technology, as well as those using the associated data, depend on agreed-upon standards and specifications to enable all participants involved to maximize the usefulness of this technology and concept. The early and comprehensive integration of quality assurance into the IUID process optimizes opportunity for full compliance with all specifications, standards, and Department of Defense (DoD) requirements.

This document is intended to provide readers with an understanding of the quality assurance practices applicable to IUID. IUID Quality Assurance (QA) is three-fold in nature, consisting of 1) process quality , 2) physical marking quality, and 3) data quality. This guide is intended to address the application of quality assurance practices for IUID to each of these areas.

Proper application of quality assurance principles and DoD requirements to IUID will help successfully provide to DoD items appropriately marked and correctly encoded – facilitating the accrual of the intended benefits of this program.

To obtain optimal benefit from this IUID Quality Assurance Guide, the reader should possess a basic familiarity with the IUID concept and process as it pertains to DoD policy and the fundamental terms and definitions associated with IUID. Publicly available information on basic IUID concepts and DoD policy is viewable on the Defense Procurement and Acquisition Policy (DPAP) Program Development and Implementation (PDI) website at: http://www.acq.osd.mil/dpap/pdi/uid/index.html. It is strongly recommended that those readers unfamiliar with the IUID concept and DoD IUID policy review the data contained therein prior to reading this guide.

The following table of contents contains five major sections, with each section addressing a different point in the IUID process. Whether the reader is a small-business owner who needs to understand how quality assurance is applied to IUID or if the reader is a Government quality assurance representative (QAR) seeking to determine if a contractor is delivering an IUID-compliant item, this document provides the guidance and references leading to an understanding of IUID quality assurance requirements and responsibilities.

Of special note, a section addressing IUID within contracts is included to illustrate the importance of including IUID within contracts and how to properly do so within the standard contracting format schema. Specific contract sections discussed include:

· Section B – Supplies or services and prices/costs;

· Section C – Description/specifications/statement of work;

· Section E – Inspection and acceptance;

· Section F – Deliveries or performance; and

· Section I – Contract clauses

Using DoD IUID Registry data and corresponding two-dimensional (2D) Data Matrix symbol marks in conjunction with automated information systems (AISs) to manage items is the ultimate objective and value-creator of IUID. This guide focuses on enhancing the foundation for future improvements in the areas of acquisition, supply chain management, maintenance (including serialized item management (SIM)) and property management systems by optimizing quality assurance in the IUID process. For further information on IUID marks and data in practice, see The Concept of Operations for IUID-Enabled Maintenance in Support of DoD Materiel Readiness at:

http://www.acq.osd.mil/log/mpp/uid/LR502C7_Rev1_FINAL_FINAL_01_19_07.pdf Certain sections of this document conclude with a list of “Additional Links.” These links are intended to supplement the text and embedded links provided in the section’s content.

Questions or comments related to this document can be directed to the eBusiness Policy Support Center (eBPSC) at 1-877-376-5787 (1-800-ePOLSUPPORT) or defensepolicysupport@ebpsc.org.

Table of Contents iiPreface

1What is IUID Quality Assurance?

3IUID Basics

6Contracting

13Data Matrix Symbol Quality: Planning & Design

22IUID Marking

31Data Collection & Submission

38Receipt & Acceptance

42Summary of Key Concepts

43Appendix A – Acronyms

45Appendix B – DoD IUID Registry Correction Request Form

46Appendix C – Contract Construction Examples

What is IUID Quality Assurance?

Quality assurance (QA) is a process for the systematic monitoring and evaluation of the various aspects of a project, service, or facility to ensure that standards of quality are being met.

Applied to IUID, QA means planning for, conveying, and meeting the IUID policy requirements as effectively as possible, at every step of the functional process, and every time performed. The goal of IUID quality assurance is the repeated delivery of Data Matrix marks and UII data that is compliant in all ways with Government requirements as called forth in the applicable contract. Note: Strive to avoid IUID-requirement variation in contracts, it can and will undermine QA.

To produce repeatable processes at a large scale within both commercial and Government environments, QA evaluation must occur to identify and prevent potential areas of variation from compliance. By implementing thorough and complete initial IUID training to the right people, by tracking IUID trend statistics, and by creating and monitoring IUID error reports to preclude future errors throughout the enterprise, time and money are saved while risk is decreased.

Following a discussion of IUID basics, the sections highlighted in this document include five IUID process steps:

( Contracting ( Data Matrix Symbol Quality: System Planning and Design

( IUID Marking

( Data Collection & Submission

( Receipt & Acceptance

Contracting. The first step to successful integration of quality assurance into the IUID process for new acquisition items is the clear and unambiguous description of requirements in the contracting vehicles (i.e., Request for Proposal (RFP), Request for Quotation (RFQ), contract). Standardized and clearly described requirements allow the vendor/supplier to properly plan for the inclusion of IUID into their manufacturing process.

Data Matrix Symbol Quality: System Planning and Design. The inclusion of quality assurance is not a haphazard process but one that is deliberately and thoughtfully integrated into the overall material manufacturing/handling process as early in the item development process as possible. QA should positively verify and validate the processes, skills, and equipment used to produce or physically manage the IUID of an item.

IUID Marking. The DoD IUID requirement is delineated in MIL-STD-130, Identification Marking of U.S. Military Property, providing references and descriptions for physical marking, Unique Item Identifier (UII) syntax and semantic standards and numerous examples to aid in meeting DoD IUID requirements.

Data Collection and Submission. The full use of IUID across DoD can only be accomplished by associating the UII and linked pedigree data to the item and making that association available to all entities having a valid need to view and use it. This is accomplished by collecting the UII and associated pedigree data and storing it in a centrally located database available for use. This database is the DoD IUID Registry. The use of specified web-enabled applications and formats to systematically feed the DoD IUID Registry helps ensure required and other appropriate data elements are correctly submitted for storage and use.

Receipt & Acceptance. The goal of this step is to validate the process used to create and apply an item’s UII to the item using a valid Data Matrix symbol will produce compliant marks and data when accepted into Government property accountability systems. The inability to accomplish this step exposes DoD to the vulnerability of incorrect or inaccurate material accounting for personal property items in its accounts.

Taken together, these five steps can be used to produce a comprehensive, actionable contract-level quality assurance plan and processes that optimizes the opportunity for compliant IUID marks and data.

IUID Basics A 1998 Government Accountability Office (GAO) review raised concerns regarding the Department of Defense’s (DoD) management of its equipment inventory. DoD needed a way to identify tangible assets individually in a manner that would be globally unique and unambiguous, have the ability to ensure data integrity and data validity throughout the life of the asset, and support multi-faceted business applications and users.

In response to the GAO’s assessment, the DoD met with domestic and international partners to determine the best approach for identifying items and maintaining those items’ life-cycle information from the moment they entered DoD inventory. The resulting initiative was called Item Unique Identification (IUID).

IUID is accomplished by marking each qualifying item with a permanent two-dimensional (2D) Data Matrix symbol and registering the symbol’s encoded Unique Item Identifier (UII) in the DoD IUID Registry. Because the Data Matrix symbol is machine-readable, IUID marking greatly reduces data-entry error and improves the accuracy of inventory and acquisition records. Note: Machine-readability does not improve inventory and acquisition records if the underlying data is not correct. Ensure item data is correct and machine-readability will maintain that correct data throughout the item’s lifecycle.

The Data Matrix symbol is encoded with the data element or elements necessary to construct a UII, which is the globally unique and unambiguous alpha-numeric code assigned to every qualifying item in DoD inventory.

Unique Item Identifiers, along with a set of select item identification data, are stored in the DoD IUID Registry, which allows controlled access to information such as acquisition cost and life cycle support data. The DoD IUID Registry is hosted and operated by the Defense Logistics Information Service (DLIS) and serves as the authoritative source for item acquisition cost and similar acquisition-based pedigree data.

Benefits

IUID Policy is designed to help the defense community to:

· Achieve lower life-cycle cost of item management

· Provide item visibility

· Supply item data necessary for top-level logistics and engineering analysis

· Provide an accurate source for property and equipment valuation/accountability

· Improve access to historical data for use during systems design and throughout the life of an item

· Provide better item intelligence for the warfighter for operational planning

· Reduce workforce burden through increased productivity and efficiency

· Assist in the identification, segregation, and ultimate reduction of counterfeit items and parts Recently, IUID was recognized as a critical enabler in the process to improve physical accountability for Nuclear Weapons Related Material (NWRM). In a memorandum dated 16 October 2008 entitled, “Nuclear Weapons-Related Materiel (NWRM)” the Under Secretary of Defense (Acquisition, Technology and Logistics) directed all individual items of NWRM be accounted for and managed by serial number meeting the standards of DoDI 8320.04 Item Unique Identification (IUID) Standards for Tangible Personal Property. Included is a requirement for a 100 percent physical inventory count by UII, at least semi-annually, for all NWRM not tracked as part of an end item. Further, it was directed that “All receipts for NWRM shall be validated at the individual item level by UII …” This memo demonstrates that increasing numbers of policy makers, strategic planners, program managers and others throughout DoD are recognizing the value added by including IUID data in their management and operational calculus.

Resources The UID Policy Office, which is within the Office of the Secretary of Defense’s Defense Procurement, Acquisition Policy, & Strategic Sourcing (DPAP) Program Development and Implementation (PDI) Office, maintains its home page at:

http://www.acq.osd.mil/dpap/pdi/uid/index.html From that page, users can access IUID policy, guidance, outreach and communications materials, and the latest news occurring in the IUID community.

Every year the UID Policy Office sponsors multiple UID Forums that provide a full itinerary of IUID presentations and training sessions. UID Forum information can be obtained at: www.UIDforum.com Resources available for introducing both Government and contractor parties to IUID include:

The Basics: IUID 101 http://www.acq.osd.mil/dpap/UID/attachments/iuid-101-20060130.pdf The DoD Guide to Uniquely Identifying Items http://www.acq.osd.mil/dpap/UID/attachments/DoDUIDGuide.pdf Integrated List of Existing IUID Definitions http://www.acq.osd.mil/dpap/UID/attachments/Integrated%20List%20of%20Existing%20IUID%20Definitions.doc IUID Policy & Regulations http://www.acq.osd.mil/dpap/pdi/uid/policy_and_regulations.html DoD IUID Registry Data Submission Information http://www.acq.osd.mil/dpap/pdi/uid/data_submission_information.html IUID Frequently Asked Questions http://www.acq.osd.mil/dpap/pdi/uid/faq.html IUID Toolkit http://www.iuidtoolkit.com IUID Overview Tutorial http://www.iuidtoolkit.com/overview Item Unique Identification DAU Continuous Learning Module (CLM200) https://learn.dau.mil/html/clc/Clc.jsp IUID DFARS Clauses

DFARS 252.211-7003, Item Identification and Valuation http://www.acq.osd.mil/dpap/dars/dfars/html/current/252211.htm#252.211-7003 DFARS 252.211-7007, Reporting of Government-Furnished Equipment in the DoD Item Unique Identification (IUID) Registry http://www.acq.osd.mil/dpap/dars/dfars/html/current/252211.htm#252.211-7007 Contracting

Across DoD, the value of IUID in improving asset visibility, maintenance management and financial accountability is becoming increasingly clear. The key to achieving these substantial benefits leading to enhanced support to the warfighter begins with including IUID requirements in contracts in a manner that adheres to standard contract construction policy. This communicates clearly and without ambiguity to both contractor and Government representatives what is required with respect to IUID.

The importance of creating acquisition contracts that are clear, unambiguous, and comprehensive in their IUID requirements cannot be overstated. Individual contract sections should not only clearly communicate IUID requirements respective of their section’s content and format, but be written in a manner that provides an improved overall understanding of IUID requirements when all sections are taken together.

Poorly or ambiguously written contracts may significantly reduce the ability to achieve desired IUID goals, adversely impact maintenance and similar support programs dependent upon IUID (e.g. serialized item management) and consequent levels of warfighter support. Such impact may linger throughout the operational life of the item(s) delivered.

Poorly constructed contracts are likely to:

Increase the workload and expense to contractor and Government in rectifying errors and clarifying ambiguities;

Contribute to erroneous data or data of poor quality being introduced into the DoD IUID Registry and other DoD databases for financial, accounting, maintenance, distribution, and warehousing purposes;

Contribute to poor decision making by warfighters, program managers, PEOs, maintenance personnel; budget and financial personnel and others who rely on accurate item data in the course of their professional duties; and

· Increase costs to manage a given class or type of item compared to what the cost would be with an IUID program providing accurate item data.

· Result in incomplete data packages that will increase cost of subsequent marking.

One of the most pervasive and insidious problems with respect to clearly communicating IUID requirements within contracts is the issue of properly constructing contract line item numbers (CLINs). IUID QA planning, part marking, data submission, and delivery acceptance all become more challenging when a contract does not contain CLINs created in a manner consistent with DoD instructions. The adverse effects of poorly written CLINs are being magnified by the growing number of DoD-wide standard item delivery requirements – such as IUID and the use of Wide Area Workflow (WAWF) – that require precise, standardized contract structure in order to successfully flow data electronically through multiple automated systems.

Properly Constructing a RFP / RFQ / Contract for IUID

A properly constructed contract with respect to IUID will have references to IUID requirements placed in several specific sections of the RFP/RFQ/contract in a standardized and mutually supportive format providing a clear, comprehensive, and consistent communication of IUID requirements. The sections most important to IUID are:

· Section B – Supplies or services and prices/costs;

· Section C – Description/specifications/statement of work;

· Section E – Inspection and acceptance;

· Section F – Deliveries or performance; and

· Section I – Contract clauses

Section B – Supplies or Services and Prices/Costs (Contract Line Items)

The importance of properly constructing contract line items is critical to achieving a number of IUID focused acquisition goals. The deleterious effects of poorly constructed line items cannot be overstated. Because modern DoD eBusiness automated information systems rely on information passed electronically using standardized data formats it is critical that contracts be constructed so that correct and accurate information is recorded into these systems. This is especially true upon receipt and acceptance into Government accountability records. This data will be used throughout the life of the item(s). Further, the procurement contracting officer (PCO) should construct the contract with the receipt and acceptance process in mind such that the Government quality assurance representative (QAR) inspecting and receiving the item(s) on behalf of the Government has a clear understanding of what the contractor is expected to deliver with respect to IUID. See also the sub-section of this guide entitled, Section E – Inspection and Acceptance.

To help meet the challenge in this area Defense Acquisition University (DAU) developed the Continuous Learning Module entitled Contract Format and Structure for the DoD e-Business Environment (Contracts CLC033) which emphasizes the importance of following DFARS 204.71, Uniform Contract Line Item Numbering System (http://www.acq.osd.mil/dpap/dars/dfars/html/current/204_71.htm). This module may be taken for credit or audited for no credit as needed to refresh the viewer on proper CLIN structure and can be accessed from the DAU site at https://learn.dau.mil/html/clc/Clc.jsp.

DFARS Subpart 204.71 – Uniform Contract Line Item Numbering is the authoritative reference that defines how to properly structure and number contract line items, subline items, and exhibit line items.

Further, DFARS 252.211-7003 (b) states “The Contractor shall deliver all items under a contract line, subline, or exhibit line item.”

When the rules of DFARS 204.71 are violated, DFARS 252.211-7003 (b) also often ends up violated. As stated above, the single most common problem encountered in contract construction that adversely affects IUID (among other issues) is poorly constructed CLINs. Among the most common is lumping multiple separately identifiable items within one CLIN. This causes confusion to contractors and Government item-acceptors on which of the multiple items must be marked, how many of the items must be marked, and how the items should be valued and registered in the DoD IUID Registry.

WAWF only accepts one UII per unit per contract line item number (CLIN), subline item number (SLIN), or exhibit line item number (ELIN). When different IUID-qualifying items are placed on one contract line, there is a significant process breakdown. This process breakdown could result in delays in item acceptance, increased contractor costs, increased Government costs, and a reduction in the operational value of the IUID.

Often the DFARS clause violations stem from lacking the answer to the core question: “What exactly is a Contract Line Item?”

DFARS 204.7103

provides the answer:

Contract line items shall have all four of the following characteristics:

(1) Single unit price. The item shall have a single unit price or a single total price;

(2) Separately identifiable. A contract line item must be identifiable separate from any other item(s) or service(s) on the contract;

(3) Separate delivery schedule. Each contract line item or service shall have its own delivery schedule, period of performance, or completion date expressly stated (“as required” constitutes an expressly stated delivery term); and

(4) Single accounting classification citation.

Review Appendix C of this guide to see examples of properly and improperly constructed CLINs and learn the impact of each. The examples are not exhaustive of all possible improper constructs but do provide the two most common examples seen providing clear understanding of the deleterious effects of poorly constructed CLINs.

Section C – Description/Specifications/Statement of Work The format of Section C can vary from document to document. Adherence to some basic concepts will maximize the clarity of the IUID requirement and minimize opportunity for confusion and ambiguity. There are no policy directed requirements for verbiage or format. With respect to IUID, the goal is to ensure a qualified bidder (or contract awardee) can be reasonably expected to understand the requirement in full and deliver an IUID compliant item to the Government.

Some concepts to follow include:

· Provide a clear and precise statement regarding the inclusion of IUID as part of the deliverable(s) or outcome of the manufacturing process. For example, the following language could be included:

All end items, components, sub-components, assemblies, sub-assemblies and parts meeting IUID requirements (see DFARS 252.211-7003) shall be marked with IUID-compliant 2D Data Matrix symbols in accordance with the latest version of MIL-STD-130.

· Identify the IUID tasks to be performed without specifying how the tasks should be performed. For example, it is valid to require that IUID be accomplished using one of the approved MRI marking protocol standards authorized within MIL-STD-130N (or latest version) without specifying which authorized standard protocol is to be used. Additionally, do not specify which UII construct shall be used.

· Include a requirement that a pre-production sample of the machine-readable IUID mark, with verification results, be provided to the project management office for validation.

· Include a requirement that the machine-readable IUID marks that will be required on items when they are delivered under contract must be permanently placed on the items when they are subjected to contractually-required performance testing and that any mark serviceability problems will be reported in the test reports.

· Include a requirement that all applicable technical documentation be updated to incorporate the UII.

Note: Section C language is optional for IUID and should only be necessary when defining specific initial-implementation, nonrecurring tasks.

Section E – Receipt and Acceptance

Properly constructing Section E – Receipt and Acceptance creates an architecture in which the QAR or other qualified acceptance representative is adequately prepared for the responsibility of ensuring the contractor delivers an IUID compliant product to Government. Many contracts for supplies or services for DoD are administered through the Defense Contract Management Agency (DCMA). It is DCMA philosophy that quality assurance inspections conducted incident to delivery of items under contract to the Government will not routinely require a technically rigorous inspection of the item(s) being delivered. Hands-on reviews may be necessary for certain items, but in many instances a validation of the quality assurance program and processes used to ensure conformance to contract requirements will be used. The quality assurance process must include some form of Data Matrix symbol mark verification using an industry-standard verifier instrument to sample marks during the production process – a successful read using a 2D symbol imager/scanner does not qualify as item mark verification.

When writing a contract it is important to use this policy as guidance when delineating receipt and inspection criteria for IUID.

It is also important to specify how the IUID portion of the quality assurance inspection will occur. For example, this may be accomplished by reviewing the contractor quality assurance plan for IUID and results of contractor compliance testing (where appropriate) on statistically valid samples of items.

Some specific issues to consider when developing Section E include specifying:

· Where inspection and acceptance will occur. This allows the contractor and inspecting agent to ensure IUID QA documentation, testing records, IUID registration data, etc. are collected and available for presentation in advance of item delivery.

· Who has authority to inspect. This will facilitate the inspector’s preparation by reviewing the IUID requirements of the contract and coordinate with the contractor for the IUID portion of the receipt and acceptance process.

· How the inspection and acceptance will be conducted. A well written contract (including Sections B, C, E and I) will delineate clearly what the contractor must do to demonstrate IUID compliance.

· Reference Contract Data Requirements Lists (CDRLs) if appropriate. If specific procedures or IUID QA documentation are required to be developed by the contractor and approved by the Government, there should be an appropriate CDRL. This CDRL would then be referenced in Section E.

Section F – Deliveries or Performance Section F – Deliveries or Performance describes the time, place, and method(s) for delivering the supplies or services specified by Section B’s CLINs. Each CLIN must have a separate delivery schedule, period of performance, or completion date.

The PCO will list the ship-to destination(s), quantities, and delivery dates for each CLIN/SLIN/ELIN. At time of Government acceptance, required contract data will be submitted to the DoD IUID Registry.

Section F’s data is significant to IUID because each item that enters the DoD IUID Registry must have its own unique, accurate set of DoD acquisition-contract data, including acceptance date and destination information. If item delivery schedules or destinations are not clearly defined, contractors will have difficulty reporting accurate and timely IUID data.

Section I – Contract Clauses

DFARS 252.211-7003, Item Identification and Valuation http://www.acq.osd.mil/dpap/dars/dfars/html/current/252211.htm#252.211-7003 DFARS 211.274-5(a) prescribes that DFARS 252.211-7003 be placed in 1) all DoD contracts for the delivery of items and 2) all DoD contracts containing DFARS 252.211-7007.

DFARS 252.211-7003 conveys the IUID requirement to contractors that new items must be marked in accordance with the latest version of MIL-STD-130 and registered in the DoD IUID Registry. If DFARS 252.211-7003 is not included in a contract, or subsequently the clause is waived by the Government, the Government cannot hold the contractor responsible for providing IUID-compliant items.

DFARS 252.211-7003 must be included in all contracts containing DFARS 252.211-7007 to eliminate any ambiguity in the requirements for assigning UIIs and registering data in the DoD IUID Registry for Government Furnished Equipment.

DFARS 252.211-7007, Reporting of Government-Furnished Equipment in the DoD Item Unique Identification (IUID) Registry http://www.acq.osd.mil/dpap/dars/dfars/html/current/252211.htm#252.211-7007 In accordance with DFARS 211.274-5 (b)(1), DFARS 252.211-7007 should be placed in solicitations and contracts that contain FAR 52.245-1, Government Property or FAR 52.245-2, Government Property Installation Operation Services.

IUID Do’s and Don’ts in Contracts

Defense Acquisition University module CLC033 includes a number of important contract-quality Do’s and Do Not’s:

Do

· Include the IUID clause

· Specify which line items for deliverables with a Government unit acquisition cost less than $5,000 the IUID clause applies to in DFARS 252.211-7003 (c)(1)(ii)

· Identify any embedded components to be uniquely identified, as referenced in DFARS 252.211-7003 (c)(1)(iii)

· Include DFARS 252.232-7003 to require use of Wide Area Workflow (WAWF)

· Include DFARS 252.211-7003 when including DFARS 252.211-7007

· Ensure that each deliverable has a separate CLIN, SLIN, or ELIN and a defined delivery schedule

· Ensure inspection and acceptance criteria address IUID

· Include the most recent versions of MIL-STD-130 and MIL-STD-129

Do Not

· Lump dissimilar items together as ‘lot’ or ‘kit’

· Specify which UID construct is to be used

· Require that the contractor use a specific identifier for an enterprise, part, or serial number when constructing any UII

· Impose unusual payment or acceptance procedures through poorly constructed CLINs, SLINs, and ELINs in RFPs, RFQs, and contracts.

· Use a prior contract award as a template if the prior award was poorly structured

Additional Links

· FAR Part 15.204, Preparing requests for proposals and requests for quotations (Uniform Contract Format) http://www.arnet.gov/far/current/html/Subpart%2015_2.html#wp1125227

· FAR Part 16, Types of Contracts http://www.arnet.gov/far/current/html/FARTOCP16.html

· DFARS 211.274-2, Policy for unique item identification.

http://www.acq.osd.mil/dpap/dars/dfars/html/current/211_2.htm#211.274-2

· DFARS 211.274-4, Policy for item unique identification of Government property.

http://www.acq.osd.mil/dpap/dars/dfars/html/current/211_2.htm#211.274-4

· DFARS 211.274-5, Contract clauses.

http://www.acq.osd.mil/dpap/dars/dfars/html/current/211_2.htm#211.274-5

· DFARS 204.7104, Contract subline items.

http://www.acq.osd.mil/dpap/dars/dfars/html/current/204_71.htm#204.7104

· DFARS 204.7105, Contract exhibits and attachments.

http://www.acq.osd.mil/dpap/dars/dfars/html/current/204_71.htm#204.7105 Data Matrix Symbol Quality: Planning & Design

Planning

As with all quality planning, IUID quality planning should be initiated early in the item development process. It should aim to achieve controls over the processes, equipment, and skills required for assessing an item’s compliance. As a technical parameter of a larger end item or component system of assemblies or parts, IUID should be reviewed and examined as one element of an overall quality assurance process within the contract.

Throughout an item’s life cycle, well crafted and properly executed IUID quality controls will help ensure design compatibility, compliance, and documentation accuracy. IUID mark application and review steps, including verification and validation as appropriate based on the standard selected by the contractor, during production and inspection will help achieve a state of compliance with IUID policy and reduce the quantity of non-compliant IUID marks that enter DoD inventory.

IUID should be addressed and included in all phases of item development and design, including with models and prototypes that enter DoD inventory, during low-rate production, and during full-rate production. By implementing IUID and IUID related quality assurance processes from time of initial concept and design, costly non-recurring engineering changes can be avoided and the full value of management by IUID can be realized.

If not present, IUID quality assurance requirements should be added to company part marking design standards, which quality assurance staff will utilize to confirm items meet IUID marking requirements. Requirements that shipping containers be marked with a machine-readable symbol listing the UII(s) within the container, as described in MIL-STD-129P with Change 4 (or latest version), Military Marking For Shipment and Storage, should also be detailed in internal quality documentation.

As necessary, inspection and testing techniques and supplies should be updated to include processes for ensuring IUID quality.

Additionally, all quality processes, actions, observations, and test results should be formally recorded and updated in a centralized and approved quality assurance database for access and reference. This documentation will serve as a reference archive for use in determining trends, monitoring IUID program and QA effectiveness, and identifying areas for quality-process improvements.

New System Design & Development When a Department of Defense contract calls for the development of a new system or part, IUID will be required for all qualifying items by the presence of DFARS 252.211-7003 in the contract.

MIL-STD-130N (or latest version) notes that product designers must include in product definition data specific requirements as to marking content, size, location, and application process. This includes types of marks (direct and indirect, intrusive and non-intrusive). Review IUID QA Guide section entitled IUID Marking for more detailed information.

When designing a new system, the primary IUID determinations that must be made are 1) where the IUID 2D Data Matrix symbol will be applied and 2) the type of marking method used for the IUID Data Matrix symbol. Review IUID QA Guide section entitled IUID Marking for more detailed information.

Wherever possible, the engineering decisions for location and type of application should be made based on documented results from previous analysis and experience. Consider using the same marking methodology that is used on the item for other human and machine-readable information if it meets the same mark durability requirement. This strategy may save significant amounts of time and money in determining optimal marking methods based on parameters of substrate material composition, configuration and marking method.

The Direct Part Marking Matrix hosted by the University of Alabama at Huntsville’s Rotorcraft Systems Engineering and Simulation Center (RSESC) is a helpful source of marking information located at https://rsesc.uah.edu/DPM/. This tool is available to the public (registration is not required) and comprised of input from Government and contractor test data sheets. It has been designed to support the direct mark-method determination process by sharing information and prior test results from open sources. No portion of the RSESC website contains proprietary information. Note: Data obtained from the Direct Part Marking Matrix should be used as a reference and guide only. Users are responsible for the outcome of their marking efforts.

The site will present a matrix from which to select substrate material and marking method (Figure A) from which a list of documents (if any pertain) show results from previous tests to use a specified combination of substrate and method (Figure B).

Figure A – RSESC Marking Matrix Figure B – RSESC Search Result Showing the First of 32 Documents

When selecting a type of marking method many parameters must be considered. It is critical that the environment or environments the item will occupy be taken into consideration. The endurance of a mark is highly contingent upon a marking method carefully selected with consideration given to several parameters such as the:

a) Three-dimensional configuration of the item;

b) Composition of the substrate (i.e., metallic vs. ceramic vs. plastic);

c) Operational environment (i.e., temperature extremes, friction, salinity, humidity, corrosive or abrasive elements encountered);

d) Expected operational life span;

e) Placement of the item (is a component or assembly within an end item) so that the Data Matrix symbol is readily accessible.

When marking models and prototypes of a new system or part, the chosen mark method should be tested for its durability, validity, and verifiability. When the selected mark method requires the acquisition of equipment or software to apply the IUID Data Matrix, the reliability and performance of those application tools must also be controlled. Regular data validation and mark verification should take place to ensure equipment is continually applying compliant marks with results recorded to demonstrate compliance. If questionable results are noted, scanning or verifying a known good mark should be sufficient to ensure the integrity of the equipment. A requirement to ensure such testing (validation and verification) occurs should be included in overall quality assurance planning.

MIL-STD-130N (or latest version) provides 2D Data Matrix symbol size parameters. Once determined, the precise symbol size, the symbol marking method, and the symbol location for a new system must be specified on engineering documents. Any deviation from MIL-STD-130 requirements should be discouraged and/or justified as a potential cost increase. When justified, deviations from the latest version of MIL-STD-130 must be specified in the contract or order.

Although engineering documentation should detail IUID marking specifications, documentation instructions must not require a future item producer to use a Government specified UII type, certain format code, or specific data qualifiers.

Also in accordance with MIL-STD-130N (or latest version), when practicable, IUID Data Matrix symbols and their human-readable information (HRI) text must be accessible to both human and machine readers. IUID Data Matrix symbols and HRI on labels, on data plates, or as direct part marks should be designed to last the expected life of the item (or until the first rebuild).

See the IUID Marking section of this document for further detail on quality specifications for IUID Data Matrix marks.

Existing System Modification

In instances where IUID is required for an existing item the necessity for advance, deliberate planning to include quality assurance processes prior to commencing a marking program remains critical. A starting point is to examine the existing marking method and location and consider adapting it to IUID requirements by adding a Data Matrix symbol. It is generally a lower risk approach and may also incur fewer resourcing requirements leading to reduced overall cost.

A benefit of adding IUID to an existing system is having the knowledge of previous successful or unsuccessful marking methods. Often the current method of marking other data (such as serial number, part number, or type designation) on an item is the ideal method for IUID marking.

Company quality standards may be utilized to centralize changes required to implement IUID. Text changes should be considered versus physical drawing changes.

Suggestions on how to minimize non-recurring engineering costs are located in the Guidelines for Engineering, Manufacturing and Maintenance Documentation Requirements for UID Implementation Version 1.2 at:

http://www.acq.osd.mil/dpap/UID/attachments/guides/uid-engdocguidever1_2-20070416.pdf.

Non-Compliance Controls

When non-compliant IUID Data Matrix marks are identified, these instances should be documented and replaced/obliterated prior to entering DoD inventory. Non-compliant direct part marks should be obliterated in accordance with MIL-STD-130N (or latest version).

Responsible staff, equipment, or documentation should receive instructions for corrective actions to prevent repeat failures. Re-marked items shall be inspected, validated, and verified. Results must be recorded and distributed to all involved quality control personnel and available for review by Government QARs when requested.

Training

Adequate classroom or on-the-job training on IUID concepts and quality assurance standards and processes should be provided for all quality control personnel. Quality assurance personnel have a responsibility to understand IUID’s purpose and requirements and IUID’s role as a parameter of an overall system.

Developed by the UID Policy Office, Defense Acquisition University (DAU) modules for Item Unique Identification (CLM200) and IUID Marking (CLE040) are three-hour foundation training courses appropriate for both Government and industry use.

Product Design Engineers

Design engineers must be aware of the IUID requirement in a contract and the impact of IUID on a newly developed system. Product design engineers must know the type of mark required by IUID (ECC200 Data Matrix) and the requirements for mark verification and validation. Design engineers should be aware that MIL-STD-130N (or latest version) is the standard for identification marking of military property and includes the requirements governing IUID marking as well as other machine readable information (MRI) and human readable markings. (This is most easily accomplished by including such requirements in Section C – Statement of Work/Performance Work Statement of the RFP/RFQ and the contract.) Design engineers also must understand the need to communicate IUID requirements throughout engineering documentation.

2D Data Matrix Symbol Labelers, Taggers, and Direct-Part Markers IUID marking staff members have a responsibility to understand the equipment or vendor being used to create IUID Data Matrix marks. Markers must understand how to recognize and report equipment failure. If a laser etch machine ceases etching into parts as deeply as normal, this performance failure must be reported. If labels are printing nonuniformly or with poor contrast, this must be reported. Mass IUID mark production by equipment that is incorrectly tagging, affixing, or applying UIIs to items will lead to extensive non-compliance.

Suppliers

In accordance with DFARS 252.211-7003(g), prime contractors are required to flow down the IUID DFARS 252.211-7003 clause to all applicable subcontractors. Prime suppliers must meet the requirements of the prime contract by guaranteeing the uniqueness of the UIIs generated and marked on items, marking items in accordance with the latest version of MIL-STD-130, and by only registering DoD prime contract data in the DoD IUID Registry.

Suppliers responsible for providing parts with IUID must have the same quality control processes in place as a prime contractor. The requirement and responsibility for early and comprehensive planning for the inclusion of IUID in the manufacture of an item and the development and inclusion of appropriate QA processes is not limited to the prime contractor or vendor.

Although the prime contractor is ultimately responsible for delivering IUID-compliant items and parts, when the IUID requirement is properly flowed down, all supply-chain partners contractually obligated to a prime contractor for the delivery of an item are equally liable for the requirement inherent in DFARS 252.211-7003 and standards and processes as called out in MIL-STD-130N (or latest version) and MIL-STD-129P Change 4 (or latest version).

Quality Assurance Representatives

Internal QARs should have familiarity in quality processes, including non-conformance tracking and statistical sampling, for the company delivering goods or products under contract.

If IUID assessment will be conducted as part of the receipt and acceptance process, an understanding of how to use equipment to determine a pass or fail test result must be in place. QARs must also learn how to test-for, recognize, report, and document equipment failure.

Sampling

MIL-STD-130N (or latest version) allows required MRI marking quality conformance to be based on a sampling plan (e.g. ISO/IEC 2859-1, MIL-STD-1916, ANSI-Z1.4). IUID marks should be sampled by manufacturers/suppliers for compliance. If the quantity of items is small, then all IUID marks should be tested for marking-standard conformance.

IUID Recommendations for the Quality Assurance / Engineering Team Process Control

· Plan for and utilize statistical process controls for IUID requirements by establishing upper and lower control limits and a sampling plan.

· Understand the requirements as called out in DFARS 252.211-7003, MIL-STD-130N (or latest version) and MIL-STD-129P Change 4 (or latest version).

· Determine the IUID 2D Data Matrix marking method is consistent with the item’s expected operational life span, physical configuration and anticipated environmental challenges.

· Communicate with customers and document users when engineering documentation is designed or changed to include IUID.

· Inspect Data Matrix symbol application equipment and Data Matrix symbol verification and validation equipment to ensure that the mark placed on an item and the data returned about that mark are accurate.

· Ensure external standards governing engineering, part marking, container marking, and Data Matrix symbol encoding are followed. See MIL-STD-129P with Change 4 (or latest version), MIL-STD-130N (or latest version), and the IUID Marking section of this document for guidance.

Document Control

· Add IUID to corporate/enterprise internal quality assurance documentation.

· Ensure new engineering documentation for qualifying items includes instructions on how to provide IUID.

· Develop an actionable quality assurance plan to include ensuring upgrade of engineering documentation for items that were designed without IUID when IUID becomes an item requirement.

· Document all IUID-related planning, review, audit, training, supplier, and customer actions.

· Document corrective actions, engineering documentation changes, and design and development activities.

· Document all 2D Data Matrix symbol testing, verification, and validation results.

Testing Control

· Obtain Automatic Identification Technology (AIT) equipment, to include a verifier, to confirm (through validation and verification where appropriate based on contractor selected MRI-protocol standard used) that IUID functionality corresponds with item design.

· Conduct quality assurance testing on at least a statistically significant sampling of all Data Matrix marks.

· Determine what qualifies as a failed IUID mark and record and investigate all IUID failures.

· Utilize control charts, which plot production values over time, to identify and manage IUID Data Matrix symbol validation and verification variation.

Training Control

· Ensure classroom and/or on-the-job training is in place for staff use of AIT equipment and staff use of Data Matrix symbol application equipment.

· Ensure training that conveys design and review considerations, including applicable IUID requirements, is provided to all quality assurance personnel.

By performing internal quality control audits and testing to measure compliant marks produced, track non-conformance, and continually record ongoing IUID statistics, both contractors and Government can reduce the number of non-compliant items that enter DoD inventory and ensure marking errors are rapidly identified and corrected.

Additional Links

· DCMA Product Assurance Guidebook http://guidebook.dcma.mil/226/guidebook_process.htm

· DoD Directives, Instructions, and Publications related to IUID http://www.acq.osd.mil/dpap/pdi/uid/directives.html

· Program Manager IUID Planning Roadmap v1.2a http://www.acq.osd.mil/dpap/UID/attachments/pm-iuid-planning-guide.pdf IUID Marking

To meet IUID policy requirements, all qualifying items must be marked with an ECC200 Data Matrix symbol containing the item’s UII data element(s), encoded in accordance with ISO/IEC 15434 syntax and semantics of ISO/IEC 15418 or Air Transport Association Common Support Data Dictionary (ATA CSDD).

MIL-STD-130N (or latest version) is the DoD standard that governs all IUID marking. The current version of the document is available at http://assist.daps.dla.mil/quicksearch.

MIL-STD-130N defines “item” as a single hardware article or a single unit formed by a grouping of subassemblies, components, or constituent parts” and “part” as one item, or two or more items joined together, that is not normally subject to disassembly without destruction or impairment of designed use (e.g., transistor, composition resistor, screw, transformer, and gear).

DoD 4140.1-R, DoD Supply Chain Materiel Management Regulation, defines “marking” as the application of legible numbers, letters, labels, tags, symbols, or colors to ensure proper handling and identification during shipment and storage.

In this document, the term IUID Marking includes marks applied directly to an item and marks applied indirectly to an item via another medium, such as a labels, metal plate, or tag. See the section below “Mark Methods” for further details.

Machine-readable information will meet DoD requirements when encoded in a mark (e.g., a 2D Data Matrix symbol or linear bar code) that is readable, accurate, durable, reliable, and conforms to accepted marking standards.

Planning for and developing a process that ensures these four factors are met for every mark will produce a high-quality result for both contractors and Government activities involved in part marking.

Readable marks conform to the physical parameters and rules that provide for human readability, such as legibility, and machine readability, such as image quality. It is valuable to note that even marks with high image quality may be difficult to read due to environmental factors such as surface geometry, surface reflectance, inherent contrast, mark resolution, and mark size.

Accurate symbols are those that conform to the protocols that permit the unique identity data to be correctly interpreted from the symbol content. Accuracy applies not only to the degree of compliance of the mark itself to applicable standards and specifications, but also to ensuring that the data is encoded correctly (i.e., proper syntax and semantics) and that the encoded data is the correct and complete data to place in that mark (i.e., that item’s UII and not the UII of another item).

Durable marking permits usability for the life cycle of the item to the extent possible under normal operating conditions.

Reliability is achieved…