Does the Defense contractor’s electronic property management system meet the intent of FAR 52.245-1 section (f)(1)(ii) to “…identify as Government owned in a manner appropriate to the type of property (e.g., stamp, tag, mark, or other identification)”? Or does the Special Tooling require a physical ownership marking (i.e. “GOV”) in addition to its unique identification that is traceable to the contractor’s property record which also notes the assets ownership as GOV?
Open full Question Details
Generally speaking, no the Defense contractor’s electronic property management system does not meet the intent of FAR 52.245-1(f)(1)(ii). The intent for Government property to be physically marked with an indication of Government ownership is inferred by the examples given (i.e., stamp, tag, mark, or other identification). Physically marking Government property with an indication of Government ownership assists in ensuring that Government property isn’t confused with contractor-owned property and subsequently used for unauthorized purposes. Based on the background information provided, there is nothing that prevents the Special Tooling from being marked with an indication of Government ownership since it is already engraved or permanently labeled with “GOV.” An exception would be if it is impractical to mark the property because it would interfere with the functioning of the item. In that case, the contractor would have to address how such property will be indicated as Government property. This is something that should be discussed with the assigned property administrator.