A reader of this blog approached me with an excellent question about my 24 March post “More On The Role Of Traceability And Inspections, Tests And Other Methods In Counterfeit Electronic Part Avoidance“. In this post, I stated that an organization could “(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.” The reader, however, cannot find support for that contingency in DFARS 252.246-7007. I wish to share my response ….
When I read the DFARS clause, I can interpret various ‘system elements’ in a number of different ways. I have heard different interpretations from various US Government and industry representatives. In my opionion, some of these interpretations do not make sense and others approach the impossible.
Some examples that do not make sense and are generally impossible to accomplish concern system element #4, ‘processes to maintain electronic part traceabilty’. Some interpret this to mean that one must maintain traceability to the OCM for all electronic parts regardless of the supplier, including open market parts where such traceability generally does not exist or cannot be reliably verified. With this extreme interpretation, the net result would be that most all purchases from suppliers that are not the OCM or its authorised distributors would not comply with DFARS 252.246.7007. If this is truely the expectation of Section 818 of the FY2012 NDAA, the final rule under DFARS Case 2012-D055, and resultant DFARS clause should have been reduced to one simple, albeit impracticable, statement ….
“Obtain electronic parts from the original manufacturers of the parts or their authorized dealers.”
There would be no need to call for a ‘contractor electronic parts detection and avoidance system’ with twelve elements describing a collection of practices designed to avoid, report and quarantine suspect counterfeits.
The opinions expressed in my recent blog postings represent my personal view of how an organization can meet AS5553 and the objectives of DFARS 252.246.7007. I acknowledge, however, that others think differently and have privately expressed concerns about how elements of DFARS 252.246.7007 are extremely difficult if not impossible to accomplish.
It is my sincere hope that both Industry and DoD can settle on effective and executable requirements within the framwork of DFARS 252.246.7007.