The Role of Traceability and Inspections, Tests and Other Methods in Counterfeit Electronic Part Avoidance (Part 1)

Earlier this week, a US DoD colleague asked me to post more thoughts on traceability in the context of counterfeit parts avoidance.  Here is my current view on subject… 

The origins of traceability for the purpose of counterfeit electronic part avoidance derived from the fact that counterfeit electronic parts tend to enter the supply chain through the open market. The purchase and use of counterfeits can be avoided if one (a) acquires electronic parts from the original component manufacturer (OCM) or the OCM’s authorized distributors, or (b) can confirm the hand offs of parts to the OCM or the OCM’s authorized distributors. Some Independent Distributors acquire electronic parts from an OCM or the OCM’s authorized distributors and can confirm these transactions. In the case of electronic parts acquired from the open market, however, suppliers generally cannot confirm traceability to the OCM or the OCM’s authorized distributors. It is this inability to confirm traceability to the OCM or the OCM’s authorized distributors that prompts the need to apply inspections, tests and other methods designed to avoid the procurement and use of counterfeits. This procurement risk mitigation process is described in SAE Aerospace Standard AS5553. [1] Taking a cue from government and industry subject matter experts, Congress included this expectation in the original legislation that initiated the final rule under DFARS Case 2012-D055. [2]

An organization meets the traceability requirments of AS5553 and the objective of DFARS 252.246–7007(c)(2) and 252.246–7007(c)(4) if the organization establishes and applies processes and procedures that … 
(a) assure procurement from the OCM or the OCM’s authorized distributors; or 
(b) confirm traceability to the OCM for parts procured from other suppliers; or 
(c) apply inspections, tests and other methods designed to intercept and avoid the use counterfeits when unable to confirm traceability to the OCM or the OCM’s authorized distributors. 
 
 
[1] SAE Aerospace Standard AS5553, Appendix B – Purchasing Process, Figure B3 – Procurement Risk Mitigation
 
[2] H.R.1540: National Defense Authorization Act for Fiscal Year 2012, Sec. 818. Detection and Avoidance of Counterfeit Electronic Parts

 

~ ~ ~ ~

Here is an earlier post that elaborates on item ‘b’ above …

Partnering With Small Business in the Fight Against Counterfeit Electronic Parts

 

 

Advertisements

7 thoughts on “The Role of Traceability and Inspections, Tests and Other Methods in Counterfeit Electronic Part Avoidance (Part 1)

  1. Maxwell Westmoreland says:

    What about traceability to the Contract Electronics Manufacturer (CEM) who manufactures electronic parts for an OCM using the formulas, processes and specifications of the OCM?

  2. Maxwell Westmoreland says:

    The AS5553A defines the Contract Electronics Manufacturer (CEM) separately from the OCM, thus the OCM could be what is being referred to as a “factory-less” manufacturer. In this context, a manufacturer does not necessarily have to be the fabricator of the parts. I think this situation has to be recognized when traceability to the original manufacturer is a requirement.

    • Understood…. My view is if I buy parts and receive parts from the OCM, my procurement and acceptance records suffice. That goes for fabless operations and OCMs with captive foundries (which could be more than one) and use outsourced assembly/packaging and test operations (which also could be more than one).

      Are there any SIA members out there who care to comment?

  3. Phillip J Zulueta says:

    Henry is correct. We would define what Maxwell describes, as a subcontractor to the OCM, not a CEM. We understand that there are many fabless component manufacturers. They design and develop the initial process, but the device fabrication is performed by one organization and the packaging may or may not be performed by another organization. The definition of CEM in AS5553A is a manufacturer of assemblies, i.e., using EEE parts (or components). AS5553A specifically states: “CONTRACT ELECTRONICS MANUFACTURERS (CEM): An organization that produces goods using EEE parts, under the label or brand of another organization. CEMs provide such services to organizations based on their own or the customers’ designs, formulas, and/or specifications.”

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s

%d bloggers like this: