PWS_PSM130_PROD_MOOG_CCAs (11 APRIL 2024) DRAFT.docx

11 APR 2024

AN/PSM-130 APS PRODUCTION

CUI

ATTENTION

Performance Work Statement

Project Title: AN/PSM-130 LAV25 CIRCUIT CARD DIAGNOSTIC APPLICATION PROGRAM SET (APS)

11 – APRIL 2024

Controlled by: DEVCOM AC Controlled by: FCDD-ACW-NT CUI Category(ies): OPSEC Limited Dissemination Control: Distribution C POC: Wallace Lee, 973-724-3862

ATTENTION

All individuals handling this information are required to protect it from unauthorized disclosure.

Handling, storage, reproduction, and disposition of the attached document(s) must be in accordance with 32 CFR Part 2002 and applicable agency policy.

Access to and dissemination of Controlled Unclassified Information shall be allowed as necessary and permissible to any individual(s), organization(s), or grouping(s) of users, provided such access or dissemination is consistent with or in furtherance of a Lawful Government Purpose and in a manner consistent with applicable law, regulations, and Government-wide policies.

Standard Form 901 (11-18) Prescribed by GSA / ISOO | 32 CFR 2002

CUI

PERFORMANCE WORK STATEMENT (PWS) FOR

AN/PSM-130 LAV25 CIRCUIT CARD DIAGNOSTIC APPLICATION PROGRAM SET (APS)

03 Jul 2023 Prepared by:

APPLICATION PROGRAM SET PROGRAM MANAGER AUTOMATED TEST EQUIPMENT PROGRAM (ATEP) MARINE DEPOT MAINTENANCE COMMAND MARINE CORPS LOGISTICS COMMAND

ALBANY, GA 31704

Controlled by: MARCORLOGCOM Controlled by: MDMC, ESCT CUI Category: CTI (Controlled Technical Information) Distribution Statement C POC: Richard Foyt; Richard.foyt@usmc.mil

1.0 INTRODUCTION

ATEP is responsible for the research, analysis, acquisition support, fielding, and lifecycle management of a wide range of test systems, equipment, tool sets, and Automatic Test Systems (ATS) equipment. Aging systems, spare parts shortages, and high operating tempo negatively impact the material readiness of the Fleet Marine Force. Long- term sustainability of the equipment is a continuing challenge requiring new initiatives to effectively address equipment wear, excessive age, and the rising cost of spares. As part of the Marine Corps Logistics Modernization efforts, the maintenance infrastructure has been evolving from one structured to support involvement in major theater wars to a much more agile and flexible maintenance capability designed to support limited engagements within simultaneous regional conflicts, peace keeping duties, and disaster or humanitarian relief. In keeping with this approach, Marine Corps Automated Test Systems provide users with an organic, deployable capability to test a wide range of electronic and electro-optic systems and subsystems, enabling them to accurately and effectively troubleshoot and repair critical weapon systems as far forward as possible.

2.0 BACKGROUND

The Marine Corps has a requirement for an organic test capability that will enable maintainers to consistently and accurately perform automated testing of Light Armored Vehicle (LAV) Circuit Card Assemblies (CCAs). The capability to effectively screen and troubleshoot system components is essential to maintaining a high level of combat readiness for the LAV systems. The United States (U.S.) Army Combat Capabilities Development Command Armaments Center (DEVCOM AC), Weapons and Software Engineering Center (WSEC), Networked Lethality and System Readiness Technologies (NLSRT), Tactical Applications Branch (TAB) will assist the Marines to fill this requirement.

3.0 SCOPE

This Performance Work Statement (PWS) identifies the tasks the contractor shall perform in conjunction with production and delivery of Application Program Sets (APS) in support of LAV Systems. This APS consists of both Test Program (TP) Software and Test Program Hardware (TPH).

References to Government within this PWS refer to the Marine Corps Logistics Command, Marine Depot Maintenance Command, Electronics, Software, Calibration, & Test Division, Marine Corps Logistics base, Albany Georgia.

4.0 APPLICABLE DOCUMENTS

The following documents form a part of this PWS to the extent specified herein. In the event of conflict between the applicable documents and this PWS, the PWS shall take precedence. All second tier and below references cited in mandatory compliance documents shall be considered as guidance only. Nothing in this document supersedes applicable laws and regulations unless a specific exemption has been obtained.

Industry Standards:

ANSI/EIA-649 - National Consensus Standard for Configuration Management ASME Y14.100 - Engineering Drawing Practices JEDEC JESD625-A - Requirements for Handling Electrostatic Discharge Sensitive Devices J-STD-001 – Joint Industry Standard – Requirements for Soldered Electrical and Electronic Assemblies ASQ Q9001 – Quality Management System Requirements

Military Standards:

MIL-STD-130N – DOD Standard Practice for Identification Marking of U.S. Military Property DoDD 5000.64 11/02/06 - Accountability and Management of DoD-Owned Equipment and Other Accountable Property DoDD 4140.1-R - DOD Supply Chain Materiel Management Regulation

For Guidance Only:

MIL-HDBK 61A - Configuration Management Guidance (2001)

Attachments:

Attachment 1 - Production Acceptance Test Plan (PATP) Attachment 2 - Drawing Package (CTI) Attachment 3 – Development TIRs

5.0 REQUIREMENTS

5.1 Fabrication Requirements. The contractor shall build-to-print eleven (11) Application Program Sets (APS) AN/PSM-130 Part Number/ Drawing number 13020A0000. The contractor is only responsible to fabricate new items from the AN/PSM-130 Motor controller and Annunciator development. New Test Programs added to the AN/PSM-130 are listed in Table I. Test Program cables will be built to support these items.

Table I. Production Unit Under Test requirements

LEM & PSU Current Sense, U13

PB (Assembly Power & Brake) PS, U12

Gate Drive (IGBT Upgrade), U18

EL MCAC 200 Amp, U10

TR MCAC 250 Amp, U8

SO (Optimiser) 200 Amp, U11

SO (Optimiser) 250 Amp, U9

15 Volt Power Supply, U14

Gun Control Unit Logic A1

Regulator, Voltage

Annunciator

Test Program Hardware each ID

5.2 The contractor will modify the first four Low-Rate Initial Production (LRIP) Quantity items to match the current as drawn package (Attachment 2). Attachment 3 Development TIRs delineates discrepancies noted during the Validation & Verification testing of the LRIP units.

5.2.1 Item Unique Identification (IUID) Requirements. The Contractor shall implement specific UID markings as defined in MIL-STD-130N, DoD Instruction 5000.64, DoD 4140.1-R, and DFARS clause 252.211- 7003.

a. The two-dimensional IUID data matrix shall be machine-readable with scanning devices and shall be accompanied by the corresponding human readable markings.

b. All 2D data matrix markings shall be permanently affixed or engraved and have the ability to withstand and perform within the same environmental conditions as the APS.

c. Whenever practical, the location of the markings on the item shall ensure its readability. Proposed size and location of UID markings shall be presented to the Government for approval.

d. All end items, spare parts, and components that exceed $5,000 when purchased separately shall also be marked with the UID prior to delivery to the Government.

5.2.2 Data Plate Requirements. The Contractor shall use MIL-STD-130N as a guide when developing the data plates. The minimum data plate requirements are listed below:

a. Nomenclature

b. National Stock Number (NSN)

c. Design Activity (MFR ID Cage Code)

d. Serial Number

e. Government Ownership Designation: US Property

f. Contract Number

g. 2-dimensional UID data matrix

h. Unique Item Identifier (UII)

5.3 Meetings, Reviews and Reports

5.3.1 Technical Interchange Meeting (TIM). TIMs may be scheduled on an as-required basis to conduct detailed technical or contract-related discussions. Scheduling will be coordinated jointly between the Government and the Contractor. TIMs will be conducted at the Contractor’s facility. The Contractor shall provide an agenda, resources and materials required for presentations, and meeting minutes, to include any action items, for all TIMs. The first TIM will be scheduled for 60 days after the Post Award Conference.

(CDRLA001, DI-ADMN- 81249C Conference Agenda) (CDRLA002, DI-ADMN-81250C Conference Minutes)

5.3.2 Post Award Conference. The Post Award Conference shall be scheduled within 14 working days after contract award. The Post Award Conference shall be held at the Contractor’s facility. The Contractor and Government shall discuss the Contractor's technical proposal. Proposed schedules shall be reviewed. The Contractor shall provide the minutes.

(CDRL A001, DI-ADMN- 81249C Conference Agenda) (CDRL A002, DI-ADMN-81250C Conference Minutes)

5.3.3 Status Reports. The Contractor shall provide Monthly Status Reports. (CDRL A003, DI-MGMT-80368A Progress/Status Report)

5.3.4 Configuration Management. The Contractor shall implement and maintain an internal Configuration Management Program (CMP) for the TPH throughout the life of the contract. The CMP will include areas governing Configuration Identification and Configuration Control.

5.3.5 Configuration Identification Baseline. The Configuration Identification Baseline for each item of the TPH is established in the drawing package (Attachment 2). The Configuration Identification Baseline shall be maintained by the Contractor throughout the production process, and is subject to review by the Government at any time. Changes to the Configuration Identification Baseline shall be submitted for approval in the form of an Engineering Change Proposal (ECP) or Request for Variance (RFV).

(B001, Engineering Change Proposal) (B002, Request for Variance)

5.3.6 Configuration Control. The Contractor shall establish configuration control to record, evaluate, document and incorporate as appropriate any proposed changes to the Configuration Identification Baseline. The Contractor shall not alter the design, form, fit, or function of the TPH without approval from the Government. An ECP shall be prepared and submitted by the Contractor for approval for any proposed change in design, form, fit, or function of the TPH. The need to deviate from the written procedures or materials contained in engineering drawings or other technical documentation shall be requested via submission of an ECP or RFV. MIL-HDBK-61 and ANSI/EIA-649 provide guidance for preparing these configuration control documents. Sufficient supporting data to evaluate the proposed change, such as drawings, supplemental drawings, sketches, specifications, or manufacturer's data sheets, shall be submitted with ECPs. ECPs shall be submitted by the contractor, and shall be limited to those that are necessary or offer significant benefit to the Government. If it is necessary to temporarily depart from the authorized configuration, the contractor shall prepare and submit a RFV. MIL-HDBK-61 and ANSI/EIA-649 provide guidance for preparing these configuration control documents. Authorized deviations are a temporary departure from the requirements and do not constitute a change in an approved baseline. Submission of recurring deviations is discouraged and shall be minimized. Where it is determined that a change should be permanent, the contractor shall process an ECP.

5.4 Acceptance Testing

5.4.1 Production Acceptance Test Plan (PATP). The Government will utilize the Production Acceptance Test Plan, Attachment 1, to verify that the APSs conform to the requirements of the PWS. The Contractor may review and provide comments to the PATP NLT 90 working days before acceptance testing begins.

5.4.2 Acceptance Testing. The Government shall perform acceptance testing in accordance with the PATP.

Acceptance testing will be conducted at the contractor’s facility. The Contractor shall provide a point of contact to support acceptance testing and maintain sufficiently qualified technical personnel, as required, to resolve any issues that may arise during testing. Test Discrepancy Reports (TDR) will be submitted to the Contractor for any discrepancies identified during testing. The Contractor shall be responsible for addressing and resolving all deficiencies identified during acceptance testing within 20 working days of test completion. A copy of the final Test Report will be provided to the Contractor.

6.0 EQUIPMENT AND SERVICES

6.1 Government Furnished Property (GFP). The government will provide Government Furnished Equipment (GFE) and Government Furnished Information (GFI) as specified below. CDRL A004, DI-MGMT-82173

6.2 (CTI) Government Furnished Information (GFI). It is the responsibility of the Contractor to review and analyze the Government Furnished Information for use in the APS production effort. Inaccuracies or incompatibilities in the government-supplied data shall not mitigate the Contractor's responsibility for production of the APSs. The Government will assist the Contractor in locating additional data should the Contractor determine that other information or data is necessary for the APS production. The GFE/GFI/GFM supplied by the Government can only be used for this contract unless approved by the Government.

6.2.1 (CTI) Engineering Drawing Package. An Engineering Drawing Package will be supplied by the Government as GFI. The Contractor shall utilize the Government furnished drawing package to build the item to print. In the event that the Contractor determines that drawing changes are required due to non-availability of parts or other factors, the Contractor shall submit an Engineering Change Proposal (ECP) in accordance with para. 5.3 of this PWS. The ECP shall include proposed changes to Government furnished drawings and/or new drawings as required to address the proposed configuration. All drawing changes or new drawings shall comply with ASME Y14.100.

6.3 Government Furnished Equipment (GFE). The following GFE will be provided to the contractor within 90 days After Date of Contract (ADC): CDRL A004, DI-MGMT-82173

7.0 Delivery. The contractor shall deliver eleven (11) APS units per the following instructions:

a) The serial number range for APS units shall begin with 005 and be assigned sequentially thereafter.

b) Transit cases are sufficient for shipping units to destination.

c) All deliveries should be coordinated through the following POC and shipped to the address provided:

POC:

Mr. Rick Foyt richard.foyt@usmc.mil 229-639-7693

Shipping address:

MARINE CORPS LOGISTIC BASE ALBANY

ATTN: TRADES ATEP ATS PGRM BROOM BLVD

ALBANY GA 31704-5000

8.0 PERIOD OF PERFORMANCE:

The period of performance for this effort shall be 12 months from contract award.

9.0 PLACE OF PERFORMANCE: At Picatinny Arsenal, NJ and at Contractor’s facility

10.0 SECURITY/OPSEC REQUIREMENTS: The Security Classification Level is UNCLASSIFIED.

10.1 The information provided to the contractor will be unclassified and/or Controlled Unclassified Information (CUI). The contractor is not required or expected to have a Facility Clearance and contractor personnel supporting this effort are not required to possess Personnel Clearance Levels. Any contractor personnel requiring access to U.S. Government CUI shall possess a completed background investigation (minimum of a T-1/NACI) for this Public Trust Position. The Contractor shall furnish certificates of completion for the following security required training activities identified in section 10 of this PWS in accordance with CDRL A005, DI-MGMT-81862.

10.2 AT Level 1 Training.

(U) All contractor employees, including subcontractor employees, requiring access to Department of Defense installations, facilities, or controlled access areas shall complete AT Level I awareness training within 45 calendar days after contract start date or effective date of incorporation of this requirement into the contract, whichever applies and within 12 months prior to travel outside of the US, then annually thereafter. The contractor shall submit certificates of completion for each affected contractor employee and subcontractor employee to the COR (or to the contracting officer, if a COR is not assigned) within 14 calendar days after completion of training by all employees and subcontractor personnel. AT level I awareness training is available at the following website: https://jkodirect.jten.mil/ for CAC holders (Course number "-US007"). Non-CAC-holders may go to: https://jko.jten.mil/courses/AT-level1/launch.html.

10.3 Access and General Protection/Security Policy and Procedures. All contractor employees, including subcontractor employees, shall comply with all installation and facility access and local security policies and procedures (provided by the Government representative), and security/emergency management exercises. The contractor shall also provide all information required for background checks to meet installation access requirements to be accomplished by the installation Provost Marshal Office, Director of Emergency Services, or Security Office. Contractor workforce must comply with all personal identity verification requirements (CFR clause 52.204-9, Personal Identity Verification of Contract Personnel) as directed by DoD, HQDA and/or local policy. In addition to the changes otherwise authorized by the changes clause of this contract, should the Force Protection Condition (FPCON) at any individual facility or installation change, the Government may require changes in contractor security matters or processes. During FPCONs Charlie and Delta, services/installation access may be discontinued/postponed due to higher threat. Services will resume when FPCON level and or threat is reduced to an acceptable level as determined by the Installation Commander. Contractor personnel working on an installation are required to participate in the Installation Random Antiterrorism Measures Program as directed. Contractors may be subject to and must comply with vehicle searches, wearing of ID badges, etc. Failure to comply with policies and procedures could result in barred access onto the installation.

10.4 iWATCH (See Something, Say Something) Training. “The contractor and all associated subcontractors shall brief all employees on the local iWATCH program (training standards provided by the requiring activity Antiterrorism Officer). This local developed training will be used to inform employees of the types of behavior to watch for and instruct employees to report suspicious activity to the COR. This training shall be completed within 45 calendar days of contract award and within 30 calendar days of new employees commencing performance with the results reported to the COR NLT 60 calendar days after contract award. The contractor shall submit certificates of completion for each affected contractor employee and subcontractor employee to the COR (or to the contracting officer, if a COR is not assigned) within 14 calendar days after completion of training by all employees and subcontractor personnel.” Slides available to COR at https://www.milsuite.mil/book/docs/DOC-284984

10.5 For contractors requiring CAC. Before CAC issuance, the contractor employee requires, at a minimum, a favorably adjudicated National Agency Check with Inquiries (NACI) or an equivalent or higher investigation in accordance with Army Directive 2014-05. The contractor employee will be issued a CAC only if duties involve one of the following: (1) both physical access to a DoD facility and access, via logon, to DoD networks on-site or remotely; (2) remote access, via logon, to a DoD network using DoD-approved remote access procedures; or (3) physical access to multiple DoD facilities or multiple non-DoD federally controlled facilities on behalf of the DoD on a recurring basis for a period of 6 months or more. At the discretion of the sponsoring activity, an initial CAC may be issued based on a favorable review of the FBI fingerprint check and a successfully scheduled National Awareness Check With Inquiries T1 at the Office of Personnel Management.

10.6 For contractors that do not require CAC, but require access to a DoD facility or installation. Contractor and all associated subcontractor employees shall comply with adjudication standards and procedures using the National Crime Information Center Interstate Identification Index (NCIC-III) and Terrorist Screening Database (Army Directive 2014-05/AR 190-13); applicable installation, facility and area commander installation and facility access and local security policies and procedures (provided by Government representative); or, at OCONUS locations, in accordance with status-of-forces agreements and other theater regulations.

10.7 Threat Awareness Reporting Program. (For all contractors.) Per AR 381-12, Threat Awareness and Reporting Program (TARP), contractor employees must receive annual TARP training by a counterintelligence (CI) agent or other trainer as specified in 2-4b. This training shall be completed within 12 months after contract start date or effective date of incorporation of this requirement into the contract, whichever applies, and then annually thereafter. The contractor shall submit documentation of completion for each affected contractor employee and subcontractor employee to the COR (or to the contracting officer, if a COR is not assigned) within 14 calendar days after completion of training by all employees and subcontractor personnel. Training can be executed by a local CI agent, online via the Army Learning Management System at https://www.lms.army.mil (and search for TARP), or by contacting the Tri-State Resident Agency, at usarmy.pica.usacic.list.308th-picatinny-fo@army.mil and 973-724-5446.

10.8 IA/Information Technology (IT) Training. All contractor employees, including subcontractor employees, employees must complete the DoD Cyber awareness training before issuance of network access and annually thereafter. All contractor employees working IA/IT functions must comply with DoD and Army training requirements in DoDD 8570.01, DoD 8570.01-M, and AR 25-2.

10.9 Government Furnished Equipment. All contractor employees, including subcontractor employees, will return all issued U.S. Government owned equipment which includes travel laptops, mobile devices, Common Access Cards, installation badges, and/or access passes to the COR when the contract is completed or when a contractor employee no longer requires access to the installation or facility.

10.10 Information Management Army Information Technology/IA: The Contractor shall be capable of accessing, handling, receiving, and storing UNCLASSIFIED documents, equipment, hardware, and test items, using the applicable standards of CUI information. Controlled Unclassified Information (documents designated as CUI and/or LIMITED DISTRIBUTION) shall be submitted by a controlled means using USPS mail, DoD Safe Access File Exchange (SAFE) website and/or DoD Army approved encryption software as per AR 25-1.

10.11 For contracts that require a covered system at contractor's facility. Requires the addition of: "If covered system support requirements apply, include provision 252.239-7017 into the solicitation, clause 252.239-7018 into the contract, and follow guidance at 239.73." (See DEVCOM AC Form 255 Annex A)

10.12 Export Control Laws/International Traffic in Arms Regulation. DFARS Clause 252.225-7048, Export-Controlled Items applies to this effort. All documents determined to contain export controlled technical data will be marked with the following notice: WARNING: -This document contains technical data whose export is restricted by the Arms Export Control Act (Section 2751 of Title 22, United States Code) or the Export Control Reform Act of 2018 (Chapter 58 Sections 4801-4852 of Title 50, United States Code). Violations of these export laws are subject to severe criminal penalties. Disseminate in accordance with provisions of DoD Directive 5230.25 and DoD Instruction 2040.02.

10.13 For contracts that require access to Classified Information / Potential Critical Program Information (PCPI)/ Critical Program Information (CPI)/ Science & Technology Protection Plan (S&TPP). Requires the addition of: "All contractor employees, including subcontractor employees, shall comply with any applicable Security Classification Guides (SCG), Interim Program Protection Plan (IPPP)/ Program Protection Plan (PPP)/ or Science & Technology Protection Plan (S&TPP) as provided by the COR. The contractor shall comply with DOD and DA technology protection requirements in DODI 5200.39, DODI 5000.83, AR 70-1, AR 70-77, and DA PAM 70-3.”

10.14 For Contracts that require access to Controlled Unclassified Information (CUI). "Include DFARS clause 252.204-7012, which requires the contractor to comply with NIST 800-171. Also include DFARS provision 252.204-2019 into solicitations. Acquisition officials should follow procedures outlined in DFARS 204.73 and verify vendors have an adequate NIST SP 800-171 summary assessment score within the Supplier Performance Risk System (within PIEE). If the score does not show a medium- or high-level assessment with a score of 110 or better (as described in the "NIST SP 800-171 DoD Assessment Methodology"), include clause 252.204-7020 and obtain the vendor's "System Security Plan" and "Plan of Action" for NIST SP 800-171 verification and assurance by Army security officials.

10.15 For Contracts that require access to Controlled Unclassified Information (CUI). Requires the addition of: "Compliance to NIST SP 800-171. Contractor employees that will require access to CUI will follow all DoD (DoDI 5200.48) and Army policies regarding access to CUI, and the handling, storage, transmission, and destruction of CUI. Contractor employees are required to complete initial CUI training (Found at: https://securityawareness.usalearning.gov/cui/index.html) within 30 days of start of performance on the contract, and then annually thereafter. All CUI must be transmitted via encrypted email channels or DoD Safe Access File Exchange (SAFE) website (https://safe.apps.mil/)."

10.16 For Contracts That Require Development of a Contractor OPSEC Program (Required if place of performance will be at contractor facilities): "The contractor shall have an identified certified Level II OPSEC coordinator per AR 530-1. The contractor shall develop an OPSEC Standard Operating Procedure (SOP)/Plan within 90 calendar days of contract award, to be reviewed and approved by the responsible Government OPSEC officer through coordination of the COR. This plan will include a process to identify critical information, where it is located, who is responsible for it, how to protect it, and why it needs to be protected. Submit contractor OPSEC Plans to the COR." (CDRL A006, DI-MGMT-80934C)

10.17 OPSEC Program (Required if the place of performance on a USG facility): "This contract requires the application of Operations Security (OPSEC) IAW AR 530-1, and/or the local User Agency policies and programs (unclassified technology). Classified material must be handled in accordance with the 32 CFR Part 117. User Agency will provide OPSEC guidance/requirements. The contractor is not required to write an OPSEC Plan in support of this effort but must receive an Initial OPSEC Brief within 30 calendar days of reporting for duty. All contractor employees must complete annual OPSEC Level I training." (OPSEC Awareness for Military Members, DOD Employees and Contractors GS130.16) website: https://www.cdse.edu/Training/Operations-Security/ (CDRL A006, DI-MGMT-80934C)

10.18 For Contracts That Require OPSEC Training. "Per AR 530-1 (or 32 CFR Part 117), new contractor employees, including subcontractor employees, must complete initial (Level I) OPSEC training within 30 calendar days of reporting for duty and annually thereafter provided by the appropriately designated OPSEC level II trained OPSEC Officer/Coordinator." Level I OPSEC training is available at the following website: https://www.cdse.edu/Training/Operations-Security/ (Course # GS130.16)

10.19 Public Release of Information: "Per AR 530-1 (or 32 CFR Part 117), an OPSEC review is required prior to all public releases. All government information intended for public release by a contractor will undergo a government OPSEC review prior to release."

11.0 ACCIDENTS AND INCIDENTS: The Contractor shall immediately report within 24 hours any major accident or incident, including fire, which results in any of the following: one (1) or more disabling injuries, damage to Government property exceeding $10,000, disruption of program plans or production schedules, degradation of the safety of equipment under contract such that personal injury or property damage may be involved, or identifies a potential hazard which requires correction action. The Contractor shall prepare an Accident/Incident report for each incident (DI-SAFT-81563, CDRL A007).

The contractor employees, including subcontractor employees, shall comply with all building, installation, facility and security policies and procedures such as all fire drills and building evacuations. The contractor shall report their evacuation immediately to their COR to confirm compliance.

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