PREFACE 1 
FURTHER CHANGES IN ACQUISITION REFORM:  
ELIMINATION OF THE WAIVER REQUIREMENT  
TO USE MIL-SPECS AND MIL-STDS 

1998 – Acquisition Reform: 
One of the major emphases added to the 10th edition was related to the “Acquisition Reform” policy of the Department of Defense (DoD) and its constituent government agencies.  The intent of Acquisition Reform was to change the way government agencies defined the requirements for systems and materiel, and the associated engineering data (Technical Data Packages (TDPs)) to be procured by the government.  In short, the overseeing government authority dictated that government agencies should “avoid government-unique 
requirements and rely more on the commercial marketplace.”  The intent was to move the definition of requirements to commercial and non-government sources where possible.

With regards to engineering drawing practices, the most significant impact of this reform was a new preference for the use of non-military specifications and standards in cases where they adequately met the needs of the project.  That is, military specifications (MIL-SPECS) and military standards (MIL-STDS) were no longer the preferred standardization tools for defining engineering drawing requirements on government projects.  Government agencies had to obtain a waiver to use certain MIL-SPECS and MIL-STDS on their procurement documents.  Likewise, contractors also were restricted in their ability to use and reference certain MIL-SPECS and MIL-STDS without obtaining a waiver.  If government-specific requirements were critical, a preference to use performance-based specifications (MIL-PRF) rather than MIL-SPECS and MIL-STDS was also stated.

The idea to use non-government specifications and standards was sound: it alleviated the government of the burden and associated expense of developing and maintaining specifications and standards which in many cases were almost identical in scope to non-government standards; it eliminated the sometimes overly restrictive requirements imposed by MIL-SPECS and MIL-STDS, thereby reducing the cost to the government and ultimately the taxpayer; it required procuring agencies to very carefully consider how restrictive and costly the requirements they imposed in their contracts and purchase orders were; lastly, it made no sense to duplicate non-government specifications and standards merely to fit in with the government procurement model – upon closer inspection there was no real need to reinvent every wheel, so-to-speak.  Indeed, my first foray into the world of national standards development was as a member of the Drawing Practices Group (DRPRG) which was tasked with converting MIL-STD-100 into a non-government standard, which eventually led to the creation of ASME Y14.100, which is the foundation upon which the later revisions of the DRM is built.

2005 – A Change is in the Air: The Waiver Requirement is Waived.

In 2005 the Department of Defense reversed the waiver requirement to use MIL-SPECS and MIL-STDS on procurement documents – this change in stance can be found in DoD Policy Memo 05-3, the content of which is included below.  The change was in response to the difficulty, extra work, and extra expense that government agencies had experienced when there was a real need for a MIL-SPEC or MIL-STD that fell under waiver requirements.  People and agencies procuring systems for the government “got the message” about carefully considering the cost implications of every specification and standard referenced in a procurement document.  According to sources in the defense community, the culture had changed, and Acquisition Reform had its desired effect.  The time had come to move on.  As stated in the memo, this was not a call to return to “the old way of doing business.”  The DoD had evolved, the beneficial changes brought about by Acquisition Reform had become part of the DoD culture, and it was time to lift a potentially unnecessary restriction.  Of course, time will tell how this all plays out.

The material in Section 2 and the rest of the DRM has been revised to reflect the removal of the waiver requirement.

Excerpt from DoD Policy Memo 05-3:

“MEMORANDUM FOR THE STANDARDIZATION EXECUTIVES OF THE MILITARY DEPARTMENTS AND DEFENSE AGENCIES

SUBJECT: Policy Memo 05-3, ‘Elimination of Waivers to Cite Military Specifications and Standards in Solicitations and Contracts’

On October 14, 2004, the Under Secretary of Defense for Acquisition, Technology and Logistics signed the Defense Acquisition Guidance. Paragraph 11.6 of this Guidance states that "it is no longer required to obtain a waiver from the Milestone Decision Authority to cite military specifications and standards in solicitations and contracts."

We are in the process of preparing a formal change to DoD 4120.24-M, "Defense Standardization Program Policies and Procedures," to eliminate the waiver requirement from this document to be consistent with the Under Secretary's direction. Until such a formal change can be issued by the DoD Directives Office, this policy memorandum deletes Section C3.8 and all of its paragraphs and subparagraphs regarding waivers from DoD 4120.24-M.

I request that you take appropriate action to ensure that everyone in your acquisition and logistics communities is aware that a waiver to cite military specifications and standards in solicitations and contracts is no longer required. As noted in the Defense Acquisition Guidance, however, this waiver elimination should not be interpreted as returning to the "old way of doing business," but as recognition of the cultural change that took place in DoD regarding the proper application of specifications and standards. We need to ensure that those in the acquisition and logistics communities have the flexibility to assess program requirements, make good decisions, and where appropriate, require conformance to military specifications and standards.”

Note:  

As of April 2008 DoD 4120.24-M is still active; the revisions described above are in process.  However, as stated above, the Policy Memo deletes the section in DoD 4120.24-M that mandates waivers for invoking MIL-SPECS and MIL-STDS.

The Preface detailing the history and effects of Acquisition Reform from Section 2 in the 10th Edition of the DRM has been moved to new Non-Mandatory Appendix C at the end of Section 2.

PREFACE 2 CHANGES IN MIL-DTL-31000C AND THEIR EFFECT ON TDPS 

General Description of Changes in MIL-DTL-31000C:

1. In July 2004 MIL-DTL-31000 was revised from revision B to revision C.  In general, revision C of MIL-DTL-31000 includes material addressing four new topics:
2. New content supporting the use of 3D data as part or all of a Technical Data Package (TDP) has been added.
3. New content on special packaging instructions drawings/models has been added.
4. New content on the use of digital approval systems has been added.
5. New content in Appendix A instructs procurement officials to require software documentation in the TDP for each software product in a statement of work has been added.

Several other changes related to cancelled military standards and other government documents.

1. All references to the Dept. of Defense Index of Specifications and Standards (DODISS) have been removed and replaced by references to the Acquisition Streamlining and Standardization Information System (ASSIST) database.
2. Reference to the following MIL standards has been removed:

1. 1. MIL-STD-974
   2. MIL-E-5007
   3. MIL-E-8593
   4. MIL-M-38761/1
   5. MIL- HDBK-248 

The major change to MIL-DTL-31000 was the addition of new material addressing three-dimensional (3D) digital data used as all or part of a TDP.  With this recognition of the expanding role of 3D data, two new types of TDPs were required to differentiate between TDPs based on 2D and 3D data (Type 2D and Type 3D).

The coverage of 3D data in MIL-DTL-31000C parallels the shift in industry toward greater use of 3D data throughout the design-manufacturing-operation-decommissioning lifecycle of a product and thus is consistent with general trends in industry.  Accordingly, an attempt to standardize the use of 3D data in industry has been addressed by the standard ASME Y14.41-2003 Digital Product Definition Data Practices.  Careful review of the changes related to 3D data in MIL-DTL-31000 reveals an alignment between MIL-DTL-31000C and ASME Y14.41-2003.  In keeping with this trend, a new chapter (SECTION 26) has been added to this DRM, addressing the use of 3D digital data as a design deliverable and as part of a TDP.  Thus, a major emphasis of this revision of the DRM has been to address the use of 3D data as part of the design process. 

MIL-DTL-31000C includes several additional requirements for using of 2D and 3D data that are not found in ASME Y14.41-2003.  The following are quotes from MIL-DTL-31000C: 

1. In general, solid models shall be in accordance with (ISO) 10303 Standard for the Exchange of Product model data (STEP), or in a native 3D CAD format capable of being exported to ISO 10303 STEP format.” 
   Note: ISO 10303 is not referenced in ASME Y14.41-2003, and adherence to the STEP format defined in ISO 10303 is not required by ASME Y14.41-2003.
2. “When 3D TDP data is used, the solid models shall display classification marking clearly visible when the solid model is first opened.” 
   Note: ASME Y14.41-2003 states that “the security marking shall be constantly displayed for all mediums of views” which is slightly different than requiring the classification markings to be visible when the solid model is first opened.  However, the requirements in ASME Y14.41-2003 seem to include the requirement above. 
3. “A 3D TDP shall be of detail and content sufficient for the support of production, engineering and logistics support, and be based on fully parametric, computer based solid model and capable of generating, when specified, 2D engineering drawings.”   
   Note: ASME Y14.41-2003 does not explicitly require models to be fully parametric. 
4. “Both Type 2D and Type 3D TDPs shall open in the appropriate software without regeneration errors or warnings.” 
   Note: ASME Y14.41-2003 does not include this requirement. 
5. “Data on 2D drawings based on the 3D solid models shall be sourced to the maximum extent possible from the 3D solid model. There shall be no conflict in data between the 3D solid model and its associated 2D drawing.” 
   Note: ASME Y14.41-2003 does not explicitly state that 2D drawings should be sourced to the maximum extent possible from the 3D solid model.  However, ASME Y14.41-2003 does lead the reader to this conclusion. 

MIL-DTL-31000B stated that TDPs based on digital data are preferred.  MIL-DTL-31000C expands this preference by stating “3D based TDPs are generally preferred especially when the item is mostly mechanical in nature, is subject to a significant number of interfaces with other systems, or in which future design upgrades and changes are likely.”  Thus the recognition of the importance of 3D data and even a preference for its use has been stated in the document.

Several of the TDP Option Selection Worksheets in MIL-DTL-31000C have been modified and new worksheets have been added to address the use of models in a TDP. 

The following material lists the major changes in MIL-DTL-31000 on a clause-by-clause basis.