New DoD regulations encourage the use of industry standards to establish and implement a “Contractor Counterfeit Electronic Part Detection and Avoidance System” and to serve as criteria for assessing the adequacy the contractor’s system.
Several industry standards have been developed over the past few years that include counterfeit parts and materials prevention practices and more standards are on the way. These new standards cover a varying scope of activity and target a variety of users within the supply chain. The following is a gap analysis listing industry standards associated with counterfeit avoidance and detection.
This gap analysis identifies the intended user and shows the general scope for each standard. This analysis also identifies industry standards that have been formally adopted by DoD – this subset of standards has been vetted through standards offices within DoD and have been found to be suitable to meet general DoD requirements. An earlier essay discusses what DoD adoption means and how it relates to DoD’s use of an adopted standard.
Requirements for the selection and use of industry standards are inconsistent and ambiguous within existing regulations concerning counterfeit electronic parts and within proposed modifications to these regulations. DFARS clause 252.246-7007 refers to “current Government- or industry-recognized standards” in one of the system elements and refers to “appropriate industry standards” in another. The proposed rule under DFARS Case 2014-D005 calls for the use of “DoD-adopted counterfeit prevention industry standards and processes” when identifying a ‘trustworthy supplier’ and selecting tests. On the other hand, when describing requirements for obtaining electronic parts, the proposed rule requires the use of “established counterfeit prevention industry standards and processes” when identifying trusted suppliers and selecting tests. If a contractor uses a ‘non-trusted supplier’, the proposed rule discusses the contractor’s responsibilities for inspection, testing, and authentication “in accordance with existing applicable industry standards.” The end result is the potential for (1) inconsistent selection and application of standards by industry, and (2) inconsistent assessment of contractor systems by government officials.
Rulemaking activity underway presents an opportunity to remedy inconsistencies and ambiguities in requirements for the selection and use of industry counterfeit prevention standards. This activity should take into account where DoD adopted industry standards are to be used versus other industry standards. The diversity of existing and forthcoming industry standards presents a compelling need for guidance in selecting standards for use in establishing and implementing a “Contractor Counterfeit Electronic Part Detection and Avoidance System” and assessing the adequacy of these systems.
 Federal Register Vol. 79, No. 87 at p. 26108, 252.246–7007 Contractor Counterfeit Electronic Part Detection and Avoidance System
 Federal Register Vol. 80, No. 182 at p. 56939, Defense Federal Acquisition Regulation Supplement: Detection and Avoidance of Counterfeit Electronic Parts — Further Implementation (DFARS Case 2014–D005)