Parts Obsolescence and the Final Rule for DFARS Case 2012-D055

The Final Rule for DFARS Case 2012-D055 includes “control of obsolete electronic parts” among the elements of a “counterfeit electronic part detection and avoidance system”. The analysis of public comments acknowledges “parts obsolescence is a matter of concern because it can create vulnerabilities in the supply chain”. The final rule, however, does not specifically address the collaboration between DoD and its contractors necessary for proactive obsolescence management. Requirements introduced in the NDAA for FY 2014, provides an opportunity to address this.

The NDAA for FY 2014 includes provisions that require DoD to implement a process to identify and replace obsolete electronic parts included in acquisition programs.

National Defense Authorization Act for Fiscal Year 2014, Public Law 113–66,
Sec. 803. Identification and Replacement of Obsolete Electronic Parts.

The outcome may foster the collaboration between DoD and its contractors necessary to address a significant vulnerability to counterfeit parts.

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NOTE: I made an error in my research for my recent essay presenting analysis of the final rule for DFARS Case 2012-D055. I incorrectly stated that provisions for obsolete electronic parts did not make it into the NDAA for FY 2014. The text of the essay has been corrected accordingly.

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