GFE Audit - Violation? GFE Location Controls

#1
Hello,

I have been doing quality audits for a long time. I am a certified lead AS9100D auditor.

I am current conducting a program government property. There are a lot of moving parts and I am seeking inputs. Our command media is in line with DFARS 52.245-1, 252.211-7007, etc., which is also on the contract along with 252.211.7001-7004

We have COMSEC material that is logged into NSA database.

We have material that has been sold off to the government and is now GFE. Some items were sent out to a flight test event with government approval.

A CDRL report was recently sent to the customer accurately representing the location of all the property. This was submitted by the program property coordinator via his own program inventory log.


However, the building also has a separate GFE coordinator who is responsible for issuing GFE tags for these items and entering them into a different database called Sunflower. Only a fraction of these items have been entered and tagged so far after being sold off for months, including some that are out at the field test and others items located at our facility. Many of the inventory locations in this database are outdated and incorrect. They are using a new database and I’m sure there’s a transition period involved. The command media is very vague about using this database. Technically, the items are traceable to the other completed lof.

However, it seems like administrator had more than enough time to get them entered and tagged. His excuse is that they’re not actively being used, which isn’t totally true.


There are also boxes of GFE on a shelf with other boxes of non-GFE. The GFE is not identified and I’m pretty sure is considered comingling, which is a direct violation of federal requirements.

I’d appreciate anyones inputs on this before I fail the audit and write it up as a finding.

thanks
 
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