Monthly Archives: February 2012

The time is right for the NCMA Webinar on NDAA Section 818: Detection and Avoidance of Counterfeit Electronic Parts

This coming Wednesday (29 February), the National Contract Management Association is conducting a webnar on the counterfeit electronic part detection and avoidance requirements introduced in the FY2012 NDAA. …

I received correspondence with excellent questions concerning the timing of this event …

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A critique of draft SAE Standard AS6174 Counterfeit Materiel

The SAE International G-21 Counterfeit Materiel Committee recently distributed a ballot among its members to approve proposed standard AS6174 Counterfeit Materiel; Assuring Acquisition of Authentic and Conforming Materiel. The following is a critique from my first blush review of this proposal.

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CODSIA letter to DOD re: “Implementation of Section 818 … “

Council of Defense and Space Industry Associations (CODSIA) letter to DOD re: “Implementation of Section 818, Detection and Avoidance of Counterfeit Electronic Parts, National Defense Authorization Act (NDAA) for Fiscal Year 2012”

CODSIA Letter dated 21 February 2012

Competition In Contracting Act (CICA) and FAR Part 6 — Perceived Constraints in Supplier Selection

U.S. Government policies and practices should emphasize the importance of procurement practices and product traceability over individual component verification and detection methods. Since the evidence suggests that counterfeit parts enter the supply chain via purchases made from independent distributors and brokers, electronic parts should be purchased, where possible, directly from the original manufacturer, or from a distributor, reseller or aftermarket supplier that is franchised or authorized by the original manufacturer.

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Clamping down on counterfeits | EDN

New law pushes responsibility and costs for detecting and replacing counterfeit electronics down to defense subcontractors and, potentially, commercial suppliers.
Tam Harbert, contributing editor — EDN, February 22, 2012

Clamping down on counterfeits | EDN.

FY2012 NDAA – Original Component Manufacturer (OCM) Support

During the U.S. Senate Armed Services Committee hearing concerning counterfeit electronic parts in the Department of Defense supply chain, Committee members and witnesses discussed the importance of support from the Original Component Manufacturer (OCM) to determine the authenticity of parts that may have been acquired from sources other than the OCM or its authorized suppliers. Witnesses discussed how the OCM’s decision to discontinue product manufacturing cuts off the supply of product from low risk sources and elevates the need for OCM support to identify counterfeits among the remaining supply circulating in the open market.

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A question for market analysts …

I read with great interest the Valentine’s Day IHS iSuppli press release about the dramatic increase in the reports of counterfeits. What further observations can market analysts offer? Helpful information would include the following….

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FY2012 NDAA — A Risk Management Approach to Counterfeit Parts Avoidance

According to Section 818 of the FY2012 NDAA, DOD is expected to issue or revise guidance applicable to Department components to implement a risk-based approach to minimize the impact of counterfeit or suspect counterfeit electronic parts. The “Risk Management Guide For DoD Acquisition” states that risk management is critical to acquisition program success and “helps ensure program cost, schedule, and performance objectives are achieved at every stage in the life cycle and to communicate to all stakeholders the process for uncovering, determining the scope of, and managing program uncertainties”. The “Risk Management Guide” stresses collaboration between the government office and the contractor — “the government shares the risk with the development, production, or support contractor (if commercial support is chosen), and does not transfer all risks to the contractor”.

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DOJ Press Release re “California Business Owner Sentenced to 30 Months in Prison For Conspiring to Sell Counterfeit Microelectronics to the U.S. Military”

February 15, 2012

WASHINGTON — Mustafa Abdul Aljaff, 32, a business owner from Newport Coast, California, was sentenced today to 30 months in prison for conspiring to sell counterfeit integrated circuits to the United States military, defense contractors, and others….

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