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  • Question

    How do I find a regulation showing that production machinery is a "stand alone" and isn't considered "IT" Also That I don't need a Afway/Netcents waiver for production service type purchases. I've went to my local Computer/MCCR group they referred me to Contracting which I know has nothing to do with demanding this step nor do they care what network the item your buying goes on if you do in fact need an approved CSRD.


    Answer

    From a contracting perspective the first place to start is with the Federal Acquisition Regulation (FAR) and looking at definitions for Information Technology and Supplies and see which definition fits your "production machinery".
     
    Under FAR 2.101 the definition of "Information Technology" is as follows:
    “Information technology” means any equipment, or interconnected system(s) or subsystem(s) of equipment, that is used in the automatic acquisition, storage, analysis, evaluation, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information by the agency.
    (1) For purposes of this definition, equipment is used by an agency if the equipment is used by the agency directly or is used by a contractor under a contract with the agency that requires --
    (i) Its use; or
    (ii) To a significant extent, its use in the performance of a service or the furnishing of a product.
    (2) The term “information technology” includes computers, ancillary equipment (including imaging peripherals, input, output, and storage devices necessary for security and surveillance), peripheral equipment designed to be controlled by the central processing unit of a computer, software, firmware and similar procedures, services (including support services), and related resources.
    (3) The term “information technology” does not include any equipment that--
    (i) Is acquired by a contractor incidental to a contract; or
    (ii) Contains imbedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, analysis, evaluation, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. For example, HVAC (heating, ventilation, and air conditioning) equipment such as thermostats or temperature control devices, and medical equipment where information technology is integral to its operation, are not information technology.
     
    Under FAR 2.101 the definition of "Supplies" is as follows:
    “Supplies” means all property except land or interest in land. It includes (but is not limited to) public works, buildings, and facilities; ships, floating equipment, and vessels of every character, type, and description, together with parts and accessories; aircraft and aircraft parts, accessories, and equipment; machine tools; and the alteration or installation of any of the foregoing.
     
    I do recommend that you locate your local base version of the AFI 33-103, Requirements Development and Processing -- most local commands have their own supplement to this instruction which can be found at http://www.e-publishing.af.mil  and it will give you specific guidance on when and how to process the CSRD if it is required, if in fact you are buying IT and you can also find additional information at the AFWAY website https://www.afway.af.mil/


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