E.  End of the Service Life of the Item

Comment: One respondent noted that section 815(a) requires that the special tooling be preserved "through the end of the service life of the end item associated with such a program." The respondent believes that "end item" refers to a "component" of the major system, not the major system itself. As noted by the respondent, it is possible that one component of a system may be replaced over the course of the production of the system as a whole, and it would be wasteful to maintain the special tooling for the now-obsolete component until production ends for the major system.

Response: DoD agrees with the respondent that it is possible, even likely, that one or more individual components of a major system will be replaced over the life of the major system. However, DoD points out that DoD policies are focused at the system level, and the requirement in section 815 is for a plan for the preservation and storage of the tooling associated with the production of hardware for a major defense acquisition program. DoD thinks that any complete plan would include the possibility of replacement upgraded components and would not contemplate maintaining and storing any special tooling for components that are no longer a part of the major system end item.