What happened to DFARS 252.245–7001? Why was it deleted and referred back to the poorly worded FAR 52.245-1(f)? Why was the superior NFS 1852.245–74(b) and (c), and 2 CFR Part 200.313 left untouched?
252.245 RESERVED | Acquisition.GOV
The Lost Clause: DFARS 252.245–7001
252.245–7001 Tagging, labeling, and marking of government-furnished property
As prescribed in 245.107(3), use the following clause:
TAGGING, LABELING, AND MARKING OF GOVERNMENT-FURNISHED PROPERTY (APR 2012)
(a) Definitions. As used in this clause—Government-furnished property is defined in the clause at FAR 52.245–1, Government Property.
Serially-managed item means an item designated by DoD to be uniquely tracked, controlled, or managed in maintenance, repair, and/or supply systems by means of its serial number.
(b) The Contractor shall tag, label, or mark Government-furnished property items identified in the contract as subject to serialized item management (serially-managed items).
(c) The Contractor is not required to tag, label, or mark Government-furnished property previously tagged, labeled, or marked.
CFR-2021-title48-vol3-sec252-245-7000.pdf
Deletion Not Consolidation
The wording concerning the marking of government property in FAR 52.245-1(f)(1) is just not the same as the wording of DFARS 252.245–7001, neither of which is particularly good.
FAR 52.245-1(f)(1)(ii) — Receipt of Government Property. The Contractor shall receive Government property and document the receipt, record the information necessary to meet the record requirements of paragraph (f)(1)(iii)(A)(1) through (5) of this clause, identify as Government owned in a manner appropriate to the type of property (e.g., stamp, tag, mark, or other identification), and manage any discrepancies incident to shipment.
To call it a consolidation is inaccurate.
- Consolidation of DoD Government Property Clauses | www.dau.edu
- Federal Register :: Defense Federal Acquisition Regulation Supplement: Consolidation of DoD Government Property Clauses (DFARS Case 2020-D029)
The Value of NFS 1852.245–74(b) and (c), as well as 2 CFR Part 200.313
The language in the following regulations is also very valuable:
NFS 1852.245–74(b) — Equipment shall be marked in a location that will be human readable, without disassembly or movement of the equipment, when the items are placed in service unless such placement would have a deleterious effect on safety or on the item’s operation.
NFS 1852.245–74(c) — Concurrent with equipment delivery or transfer, the Contractor shall provide the following data in an electronic spreadsheet format: (2) Unique Identification Number (License Tag) and (4) An explanation of the data used to make the unique identification number.
1852.245-70 through 1852.300
2 CFR Part 200.313 — Equipment: (d) Management requirements. (1) Property records must be maintained that include a description of the property, a serial number or other identification number…. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated.
2 CFR 200.313 – Equipment.
Could There Be a Grand Unifying Property Marking Regulation?
Yes!
Loss Prevention Standards 1224 and 1225 – My Property ID Registry
