C.  "Unique Tooling"

Comment: Two respondents noted that the statute and the August 3, 2009, implementing memorandum use the term "unique tooling," not "special tooling." Both recommended that DFARS 207.106(S-73) be revised to use the term "unique tooling" and to add a definition to that paragraph as follows: "For DoD purposes, unique tooling shall mean special tooling as defined in Federal Acquisition Regulation 2.101(b)."

Response: DoD has determined that the use of "special tooling" in 207.106(S-73) correctly implements the statute, and no change is necessary.

Respondents agree that "unique tooling" and "special tooling" have the same meaning. However, there is no reason to use "unique tooling" in the coverage and then define it using a reference to FAR 2.101. That would contravene the FAR drafting convention to use a single term consistently to express the same meaning.