‘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.

Introduction

DoD published an amendment to the DFARS requiring “covered contractors” to establish and maintain an acceptable “Counterfeit Electronic Part Detection and Avoidance System”[2] and to flow down the substance of system requirements in subcontracts. The DFARS 252.246–7007 applies the central tenets recommended by industry and US Government subject matter experts:

  • Obtain electronic parts, whenever possible, from original manufacturers or their authorized distributors
  • Perform due diligence when purchases from sources of supply other than the original manufacturer and its authorized distribution chain are necessary
  • Notify government and industry of suspected counterfeits when they are encountered

A “Counterfeit Electronic Part Detection and Avoidance System” described in DFARS 252.246–7007 must include risk-based policies and procedures that address the following elements:

  1. The training of personnel.
  2. The inspection and testing of electronic parts ….
  3. Processes to abolish counterfeit parts proliferation.
  4. Processes for maintaining electronic part traceability….
  5. Use of suppliers that are the original manufacturer, or [an authorized supplier] ….
  6. Reporting and quarantining of counterfeit electronic parts and suspect counterfeit electronic parts.…
  7. Methodologies to identify suspect counterfeit parts and to rapidly determine if a suspect counterfeit part is, in fact, counterfeit.…
  8. Design, operation, and maintenance of systems to detect and avoid counterfeit electronic parts and suspect counterfeit electronic parts….
  9. Flowdown of counterfeit detection and avoidance requirements….
  10. Process for keeping continually informed of current counterfeiting information and trends ….
  11. Process for screening GIDEP reports and other credible sources of counterfeiting information to avoid the purchase or use of counterfeit electronic parts.
  12. Control of obsolete electronic parts ….

The following diagram presents an overview of a holistic counterfeit electronic parts avoidance and detection process and illustrates the interrelationship between key elements of an effective “Counterfeit Electronic Part Detection and Avoidance System”. This diagram is taken from SAE Aerospace Standard AS5553, Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition Revision A.[3]

RM_AS5553FigB3ProcurementRiskMitigation

DFARS Clause 252.246-7007 encourages the use of Government or industry recognized standards, such as AS5553, for the design, operation, and maintenance of systems to detect and avoid counterfeit electronic parts and suspect counterfeit electronic parts.[4] In this series of essays, I offer my thoughts on establishing and implementing a “Counterfeit Electronic Part Detection and Avoidance System” that complies with DFARS Clause 252.246-7007; and describes 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.

Henry Livingston


[1] Federal Register Vol. 79, No. 87 at p. 26108, 252.246–7007 Contractor Counterfeit Electronic Part Detection and Avoidance System

[2] Ibid.

[3] AS5553 Figure B3 – Procurement Risk Mitigation

[4] DFARS 252.246–7007 (c) (8) Design, operation, and maintenance of systems to detect and avoid counterfeit electronic parts and suspect counterfeit electronic parts.

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