Trends in Standards Activity – Changes in Scope and Gaps in Product Authentication Requirements

During engagements in standards activity surrounding counterfeit avoidance and detection, I observed two recent trends that to my knowledge have not been widely publicized to the user community at large:

  • Changes to the scope of these standards
  • Gaps in product authentication requirements between standards directed to contractors vs standards directed to part distributors

The Scope of Counterfeit Avoidance and Detection Standards

It is widely recognized and understood that “counterfeit parts” are a subset of “fraudulent parts”. The current version of AS5553 (intended for use by contractors and Government customers) focusses on “counterfeit electronic parts” only.

The standards committee developing the revision to AS5553 (intended to replace the current version and serve an international user community) has proposed to expand the scope of the document to encompass “fraudulent parts” in general. While a number of us involved since the inception of the SAE International G19 committee anticipated expansion in scope over time to some degree, the expansion to encompass “fraudulent/counterfeit parts” as described in the pre-ballot draft of AS5553A goes beyond what I believe to be prudent and appropriate.

It is my understanding that concerns exist that current high level QMS standards and documents do not sufficiently address certain forms of “fraudulent parts” and a solution being considered is to expand the scope of AS5553 to address these gaps. I strongly recommend the user community (1) assess the degree to which apparent gaps in standards coverage for “fraudulent parts” (other than “counterfeit parts”) exists, (2) assess whether or not this expansion in scope is appropriate, and (3) assess whether or not the proposed revision to AS5553 fills gaps in standards coverage for “fraudulent parts” in general. In February 2012, I prepared an essay concerning the proposed AS6174 (developed by G21) which is relevant to this discussion.

It is my view that if existing high level QMS standards and documents do not adequately address other forms of “fraudulent parts”, SAE might consider updating existing high level QMS standards or develop new standards to address those issues. This will enable existing resources to be directed to where significant risks presently lie and avoid diluting the execution of, and effectiveness of, policies, practices and standards by casting too wide a net.

Gaps in Product Authentication Requirements

In January 2012, I prepared an essay concerning authenticity inspections and tests. In this essay, I discussed how despite the inspection and testing protocol applied by Independent Distributors and “Brokers”, counterfeit products continue to escape detection. Recent standards development activity has included a significant debate over (1) what minimum tests and inspections are necessary to detect counterfeits versus (2) the capabilities of Independent Distributors and “Brokers” to conduct or effectively outsource certain tests and inspections.

I strongly recommend the user community review forthcoming standards proposal and compare differences in the minimum tests and inspections expected of Independent Distributors and “Brokers” (such as proposed standard AS6081) versus the tests and inspections necessary to detect various forms of counterfeit parts (such as those described in AS5553). An additional essay I prepared in March of 2012 describes a number of issues to consider.

It is very important for the user community to understand that should standards such as AS6081 require Independent Distributors and “Brokers” to perform a minimum suite of simple/low-cost screening inspections (which may fall short of the full set of tests and inspections necessary to detect various forms of counterfeit parts), it will be left to the buyer (such as the defense contractor) to determine what further tests and inspections are necessary to detect various forms of counterfeit parts; not to the Independent Distributor or “Broker”. When reviewing these standards proposal, the user community should also bear in mind the requirements introduced in Section 818 of the FY2012 NDAA.

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4 thoughts on “Trends in Standards Activity – Changes in Scope and Gaps in Product Authentication Requirements

  1. Ronald Edmunds says:

    ISO 9000 and AS9100 require in 7.4.1 that all purchased product meet the all of the purchase requirements, whether it is heat-treating requirements, material specifications or electronic components. It is the responsibility of the purchaser to ensure that conformity all of the products before they are incorporated into the end items they are providing to their customers. When the transmission goes out in my Ranger I’m not calling Mazda (transmission OEM), I’m calling Ford.

  2. Dale Hosack says:

    So the essence of AS6081 is that the Defense contractor receives no assurance that product is not counterfeit, and therefore it adds no value. Correct?

    • Others think differently I am sure, but I would say AS6081 (the 2nd ballot draft) provides limited assurance. My personal belief is that the bar could be raised to substantially reduce the probability of a counterfeit part quality escape. I chose my words carefully here because it is also my belief that even with the most rigorous test and inspection regimen, I would be reluctant to guarantee that counterfeits would not escape; I am not aware of other A&D equipment producers who would.

      Perhaps others know differently, but I am not aware of definitive and specific claims about assurance from suppliers who plan to apply the minimum tests and inspections proposed in AS6081. My earlier essays that describe what I believe is necessary for a high level of assurance may help shed some light on my skepticism about the effectiveness of AS6081 as proposed thus far despite any specific claims some may offer.

      I would be interested to know if other cases exist where standards have been issued with the understanding that the task at hand may be incomplete and leave unfinished business for the user to address. If there are such cases, do the standards make this clear and what can we learn from their implementation?

  3. The following is correspondance I sent this afternoon to SAE staff and G19 members about the compelling need for awareness communications to the user community about current standards activity re counterfeit parts avoidance and detection.

    —–

    Tuesday, May 01, 2012 4:23 PM

    To: G19, G19CI and G19D

    The aerospace & defense community will need to be educated about revision A to AS5553 and this material will be very useful in that regard. A&D community education concerning AS6081 will also be needed.

    I do have specific suggestions about what to consider for this sort of briefing. During engagements concerning SAE standards activity surrounding counterfeit avoidance and detection, I observed two significant developments that to my knowledge have not been widely publicized to the user community at large:
    •Scope of Counterfeit Avoidance and Detection Standards
    •Gaps in Product Authentication Requirement

    In addition to informing those who will be implementing these standards for the first time, those who are familiar with AS5553 (but not directly involved in the development of the proposed revision to the standard or the companion proposed document AS6081) need to be informed of the implications of these changes. Allow me to elaborate further.

    Scope of Counterfeit Avoidance and Detection Standards

    It is widely recognized and understood that “counterfeit parts” are a subset of “fraudulent parts”. The current version of AS5553 (intended for use by contractors and Government customers) focusses on “counterfeit electronic parts” only. SAE’s G19CI subcommittee has proposed to expand the scope of the document to encompass “fraudulent parts” in general. While a number of us involved since the inception of the SAE International G19 committee anticipated expansion in scope over time to some degree, the expansion to encompass “fraudulent/counterfeit parts” as described in the pre-ballot draft of AS5553A goes well beyond what I speculate most users expect. It is critical that the user community (both Industry and Government) be made aware of this significant proposal. The anticipated users of AS5553A should be advised of the following:
    •An assessment of the degree to which gaps exist today with respect to coverage for “fraudulent parts” (other than “counterfeit parts”) in current QMS and lower level standards
    •The magnitude of problems caused by these gaps in standards when compared to the counterfeit parts problem
    •The rationale behind expanding the scope of AS5553 vs. updating existing high level QMS standards or developing new standards
    •How the AS5553 document specifically addresses forms of “fraudulent parts” in addition to what is presently covered by AS5553; identify examples covered in the proposed version of AS5553 vs. current version of AS5553 vs. the elements of the supply chain that are typically associated with these forms of “fraudulent parts”
    •Changes to one’s business systems that will be necessary to encompass fraudulent part avoidance and detection vs. counterfeit part avoidance and detection; identify where within the supply chain these changes will be needed

    This proposed expansion in scope is also on the table for AS6081. The items above, therefore, should also be addressed with respect to the implementation of AS6081, particularly with regard to how it is to be implemented in conjunction with AS5553.

    Gaps in Product Authentication Requirements

    Standards development activity associated with AS6081 has included a significant debate over (1) what minimum tests and inspections are necessary to detect counterfeits versus (2) the capabilities of Independent Distributors and “Brokers” to conduct or effectively outsource certain tests and inspections. It is critical that the user community (both Industry and Government) be made aware of this significant proposal and its relationship to the implementation of AS5553.
    AS6081 as proposed will expect Independent Distributors and “Brokers” to perform a minimum suite of simple/low-cost screening inspections which may fall short of the full set of tests and inspections necessary to detect various forms of counterfeit parts. The user community needs to be informed of the implications of this proposal:
    1.The majority of Independent Distributors and “Brokers” supplying product sourced from the open market do not have the capability to perform or effectively outsource inspections and tests other than those that would detect some forms of obvious fakes.
    2.It will be left to the buyer (such as an equipment contractor, US DoD procurement organization or UK MoD procurement organization) to determine what further tests and inspections are necessary to detect various forms of counterfeit parts.
    3.The buyer must have the knowledge necessary to select additional tests and inspections to fill in gaps left behind by Independent Distributors and “Brokers”; the buyer must see to the execution of those additional tests and inspections and assess the results.
    4.The buyer must flow down expectations of Independent Distributors / “Brokers” in the event counterfeit parts escape tests and inspections performed by the Independent Distributor / “Broker”, but are detected through additional tests and inspections performed by the buyer or at the direction of the buyer by a third party laboratory.

    Given the forthcoming policies and regulation changes expected from the US DoD in response to Section 818 of the FY2012 NDAA, the need for this awareness and education is all the more compelling.

    Regards,
    Henry Livingston

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