Boiling the Ocean – A review of FAR Case 2012–032: Higher-Level Contract Quality Requirements

A number of us within the aerospace and defense community have discussed the need to incorporate requirements for detection and avoidance of counterfeit electronic parts into key Quality Management System (QMS) standards (e.g. ISO 9000, AS9100, etc.). With FAR Case 2012–032, DoD, GSA, and NASA are proposing to amend the Federal Acquisition Regulation (FAR) to include counterfeit avoidance and detection standards among other higher-level quality standards in solicitations and resultant contracts. While this is a step in the right direction, the scope of this case extends far beyond DoD and electronic parts.

This case proposes to add two new industry standards that pertain to quality assurance for avoidance of counterfeit items:

  • SAE AS5553, Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition
  • SAE AS6174, Counterfeit Materiel; Assuring Acquisition of Authentic and Conforming Materiel

Subject matter experts within the aerospace and defense industry and US government agencies  have accomplished a great deal in recent years toward defining specific requirements and for counterfeit avoidance with respect to counterfeit electronic parts. SAE Standard AS5553 has been recognized by industry and US Government subject matter experts as the standard of choice for use in avoiding counterfeit electronic parts. Some US aerospace and defense companies have encouraged DoD to apply AS5553 when addressing Section 818 of the NDAA for FY 2012 (Pub. L. 112–81, enacted December 31, 2011).

Counterfeit avoidance practices for all other materiel, however, has not been well defined. SAE Standard AS6174 in its present state does not provide clear direction or focus to help industry or government implement meaningful or effective counterfeit avoidance policies or risk management approaches. The SAE G21 committee has initiated steps to identify types of materiel requiring attention, but this work has just begun and it is unlikely that specific requirements and expectations will be developed to address all materiel types. Extending the scope of counterfeit prevention requirements beyond electronic parts is premature.

Rather than establishing broad requirements that encompass all materiel commodities, FAR Case 2012–032 should focus on specific products that present the greatest counterfeiting risk, such as electronic parts. Before including coverage for other materiel types, the FAR case should (1) call for routine assessment of trends to determine the extent to which other materiel commodities emerge as a significant counterfeiting risk, and (2) encourage development of standards to address these other materiel types. 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.

H Livingston

For more discussion about AS6174, see …

A critique of draft SAE Standard AS6174 Counterfeit Materiel, H Livingston, 25 Feb 2012

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One thought on “Boiling the Ocean – A review of FAR Case 2012–032: Higher-Level Contract Quality Requirements

  1. Owen Peters says:

    Rather than “casting too wide a net” it appears to me that the DoD is fishing with a couple of nets, 2012-055 (electronics) and 2012-032 (all else). As long as they focus on a risk based approach it seem appropriate to me.

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