Missing Definition of ‘Trusted Supplier’ in the proposed DFARS Rule on “Detection and Avoidance of Counterfeit Electronic Parts”

The Federal Register Notice concerning the proposed DFARS Rule on “Detection and Avoidance of Counterfeit Electronic Parts” [1] describes partial implementation of the National Defense Authorization Act for Fiscal Year 2012 [2], including “the use of trusted suppliers” [3]. Within its criteria for an acceptable “Contractor Counterfeit Electronic Part Avoidance and Detection System”, the proposed rule includes “Use and qualification of trusted suppliers”. The proposed rule, however, does not include a definition for the term “trusted supplier”, nor does the new DoD counterfeit prevention policy [4] include a definition for this term.

Example of Counterfeit Prevention for Bare Die Products

When describing counterfeit prevention for microelectronic products, literature and standards tend to focus on packaged products. After the original release of AS5553, G19 committee participants discussed the need for counterfeit avoidance and detection protocols directed toward bare die products.

Counterfeit Prevention and Materiel Inventory

I recently received correspondence from an A&D contractor representative who observes “there seems to be little published about what suppliers have/are doing with material they already have.” 

A Case Study – “Counterfeit capacitors in the supply chain”

The following paper presents an interesting case study and investigation into a suspect counterfeit capacitor finding …

Concern drives education about counterfeit components says Arrow’s Mike Calabria – ECIA

Standards Update – SAE G19AD Authorized Distributor Committee

SAE International formed a new subcommittee to the G-19 Counterfeit Electronic Parts Committee …

Focus Areas for an A&D Contractor Industry Counterfeit Prevention Strategy

A high level counterfeit prevention strategy is needed to address standards gaps and to resolve implementation issues that, to some degree, are driven by new and forthcoming US Government requirements directed to the aerospace and defense (A&D) Contractor Industry. Collaboration between A&D Contractor Industry companies is key to developing such a strategy, focusing limited resources and driving meaningful implementation at appropriate levels within the supply chain.

I offer the following thoughts on focus areas to include in a high level counterfeit prevention strategy developed from the perspective of A&D contractors.

 

DLA QTSL Update

DLA posts its ‘Listing of Testing Suppliers‘.

DOD gets serious about supply chain security — Washington Technology

Federal contractors are going to be hearing the words “supply chain” a lot over the next 18 months. Having a certifiably secure supply chain will eliminate a potential mark against your selection as a source, just as having the appropriate contract vehicles eliminates friction. …

 More at Washington Technology.

NOTE: Though the author is correct about the attention “supply chain” is getting on The Hill, the fine points concerning NDAA2013 Section 833 are not accurately described. Note “reader comments” posted by Bob Metzger.

Where Policy, Legislation, Standards and Practicality Collide – Counterfeit Parts Prevention Issues Requiring Government / Industry Collaboration to Address

Legislation and regulatory requirements and standards gaps continue to present aerospace & defense industry and US government users with significant implementation challenges with respect to counterfeit part avoidance and detection. The counterfeit parts issue is similar to the lead-free electronics issue in that regulations drive the need for standards, but technical challenges and supply chain limitations must be recognized so that reasonable and implementable regulations and policies are developed in response to the threat. Though many of these challenges have been discussed in Industry and Government forums and described in trade literature and the media, many remain unresolved.