Monthly Archives: October 2015

‘Contractor Counterfeit Electronic Part Detection and Avoidance Systems’ … Part 3

The Role of Inspections and Tests, Traceability and Other Methods in Counterfeit Electronic Part Detection and Avoidance

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Assessing DOD’s Assured Access to Micro-Electronics in Support of U.S. National Security Requirements

Hearing: “Assessing DOD’s Assured Access to Micro-Electronics in Support of U.S. National Security Requirements”
House Armed Services Subcommittee on Oversight and Investigations
Oct 28 2015

Witnesses:

  • Ms. Kristen Baldwin – Principal Deputy Assistant Secretary of Defense for Systems Engineering
  • Mr. André Gudger – Acting Deputy Assistant Secretary of Defense for Manufacturing and Industrial Base Policy
  • Mr Brett Hamilton – Division Chief Engineer for Trusted Microelectronics, Naval Surface Warfare Center – Crane
  • Ms Marie Mak – Director, Acquisition and Sourcing Management Team, GAO

The repository for this hearing is here.

Defense Federal Acquisition Regulation Supplement: Requirements Relating to Supply Chain Risk

DoD has adopted as final, with changes, an interim rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement a section of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2011, as amended by the NDAA for FY 2013. This final rule allows DoD to consider the impact of supply chain risk in specified types of procurements related to national security systems. …

More at Federal Register

‘Contractor Counterfeit Electronic Part Detection and Avoidance Systems’ and Compliance with DFARS Clause 252.246-7007 — Introduction

US Government regulations and industry standards addressing counterfeit electronic parts detection and avoidance have blossomed over the past several years and will evolve over the foreseeable future. This is particularly true of regulations governing DoD acquisition and ongoing standards activity to better align industry standards with these regulations. In the meantime, DoD organizations and their contractors must work within the framework established by regulations introduced a year or so ago.[1]

The following is the first in a series of essays describing my thoughts on establishing and implementing a “Counterfeit Electronic Part Detection and Avoidance System” that complies with DFARS Clause 252.246-7007; and how SAE Aerospace Standard AS5553 can be used to articulate requirements for a “Counterfeit Electronic Part Detection and Avoidance System” and to serve as criteria for assessing the adequacy the system.

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FAR / DFAR Case Update (26 Oct 2015)

Status updates from the ‘Open Cases Reports’ …

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Extension of Comment Period and Meeting Announcement re Detection and Avoidance of Counterfeit Electronic Parts—Further Implementation (DFARS Case 2014-D005)

“DoD is hosting a public meeting to obtain the views of experts and interested parties in Government and the private sector regarding further implementation of the requirement for detection and avoidance of counterfeit electronic parts, as required by a section of the National Defense Authorization Act for Fiscal Year 2012…

The public meeting will be held on November 13, 2015, from 1 p.m. to 4:30 p.m., EST. Registration to attend this meeting must be received by November 9, 2015. …

The comment period for the proposed rule published on September 21, 2015 (80 FR 56939) is extended. Comments on the proposed rule should be submitted in writing … on or before December 11, 2015, to be considered in formation of the final rule.”

More at …

Extension of Comment Period and Meeting Announcement re Detection and Avoidance of Counterfeit Electronic Parts—Further Implementation (DFARS Case 2014-D005)

FAR / DFAR Case Update (19 Oct 2015)

Status updates from the ‘Open Cases Reports’ …

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Counterfeit Prevention Standards Gap Analysis — 8 Oct 2015 Update

[ Updated 8 Oct to reflect feedback re the 30 Sep version ]

Here is an update to the standards gap analysis I have been maintaining. It now includes …

  • ISO/IEC 20243:2015 – Information Technology — Open Trusted Technology ProviderTM Standard (O-TTPS) — Mitigating maliciously tainted and counterfeit products
  • AS6886, Counterfeit Materiel; Assuring Acquisition and Use of Authentic and Conforming Refrigerant
  • Proposed, ARP6328 Guideline for Development of Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition Systems
  • MIL-STD-3018 Department of Defense Standard Practice, Parts Management
  • MIL-STD-11991A Department of Defense Standard Practice, General Standard for Parts, Materials, and Processes

Counterfeit Prevention, Detection and Avoidance Standards Gap Analysis for Hardware Products (Updated 8 October 2015)

Henry Livingston