The following further describes my thoughts and opinions on the role of traceability and inspections, tests and other methods in effective counterfeit electronic part avoidance. …
An organization meets the traceability requirements 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
The organization needs not seek out traceability (and associated artifacts mapping the path to the OCM) when it purchases parts from the OCM itself or when it purchases parts from the OCM’s authorized distributors. The organization’s procurement and receiving records confirming the organization’s source should suffice.
(b) confirm traceability to the OCM for parts procured from other suppliers
If the organization uses a supplier to acquire material on the organization’s behalf (such as an SDB to meet FAR requirements for small business set asides), that supplier needs to provide evidence that it acquired the material from the OCM itself or from the OCM’s authorized distributors (e.g. the organization directs the sourcing to the OCM or the OCM’s authorized distributors and the organization previously evaluated the supplier’s ability to follow instructions). The organization’s procurement and receiving records confirming its supplier’s source should suffice.
(c) apply inspections, tests and other methods designed to intercept and avoid the use of counterfeits when unable to confirm traceability to the OCM or the OCM’s authorized distributors.
If the organization finds a compelling need to seek out material from a supplier who plans to acquire material from, or possesses inventory acquired from other suppliers who are not the OCM’s authorized distributors (e.g. purported ‘authentic OEM surplus’, part sourced from the open market, parts acquired from DLA, etc.), the organization should seek out and evaluate the integrity of supply chain traceability information mapping the path to the OCM (e.g. contact the intermediaries and OCM to verify the evidence provided, verifying the evidence provided is associated with the parts supplied, etc.) and seek out information to verify adequate storage and handling. In the absence of verifiable traceability data and proof of adequate storage and handling, and in the absence of support from the OCM, the organization should see to the performance of tests and inspections designed to detect counterfeit electronic parts. The outcome of these tests and inspections should serve as the basis for “credible evidence” providing “reasonable doubt that the electronic part is authentic”.
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NOTE: Acquiring material from the OCM or the OCM’s authorized distributor remains the most effective way to avoid counterfeit electronic parts. Seeking out material from a supplier who plans to acquire material from, or possesses inventory acquired from other suppliers who are not the OCM’s authorized distributors, should only be considered when compelling need precludes acquiring material from the OCM or the OCM’s authorized distributor.