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.