Comparison of Nuclear and Aerospace Quality Requirements for “Suspect/Counterfeit Items (S/CI)” – A Model for Government and Industry to Consider

During the NASA Quality Leadership Forum last week, representatives from U.S. Department of Energy (DOE) presented a briefing on the DOE nuclear regulatory framework and a comparison of nuclear and aerospace quality requirements for counterfeit prevention. (i.e. “DOE O 414.1D Attachment 3 – Suspect/Counterfeit Items Prevention” versus “AS5553A – Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition”)

The DOE representatives described a number of potential outcomes from understanding the compatibility of nuclear and aerospace requirements:

– Provide a basis for evaluating a suppliers and contractors’ S/CI program that is compliant with DOE or SAE requirements

– Suppliers and Contractors can use as a tool for self-assessment

– Facilitate expansion of supplier base

– Increase confidence in transferability of supplier S/CI programs

– Support upcoming FAR changes for S/CI reporting across agencies

DOE also offered this comparison as groundwork for a potential collaborative project between the ASME Committee on Nuclear Quality Assurance (NQA) and the SAE International committees developing counterfeit avoidance and detection standards (G-19 Counterfeit Electronic Parts Committee and G-21 Counterfeit Materiel Committee Committee).

In addition to these potential uses identified by DOE, this approach could be used by government agencies and industry to perform a comprehensive gap analysis across standards. A contractor could also use this approach to assess its own compliance program for counterfeit parts avoidance and detection against new legislation and forthcoming regulations.

I strongly encourage industry organizations and government agencies to consider this work by DOE as a model for collaborative efforts in assessing standards and compliance programs.

The following documents are provided courtesy of DOE:

Briefing re “DOE Nuclear Regulatory Framework and Comparisons of Nuclear & Aerospace Quality Requirements”

Comparison of DOE O 414.1D and SAE AS5553A Suspect/Counterfeit Items (S/CIs) Requirements

Hats off to Duli Agarwal and Bud Danielson! Thank you for making this available for our benefit.

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