‘Contractor Counterfeit Electronic Part Detection and Avoidance Systems’ … Part 1

Personnel Training and Keeping Current

The contractor and subcontractor must train personnel in counterfeit electronic parts detection and avoidance.[1] The training program should consist of general awareness training for a broad range of personnel, and more specialized and tailored training for personnel responsible to implement the organization’s “Counterfeit Electronic Part Detection and Avoidance System”.

Awareness training might include background information describing what counterfeit electronic parts are, their origins, how they enter the supply chain, vulnerabilities to counterfeit parts (e.g. obsolete and hard-to-find parts), new laws and regulations, and an overview of internal processes and methods to avoid and detect counterfeit electronic parts.

Specialized and tailored training would include supplier selection practices, procurement practices to avoid counterfeits, counterfeit detection implementation (through internal resources and/or 3rd party laboratory and analysis facilities), suspect counterfeit and counterfeit electronic part reporting practices, requirements flow down to suppliers, etc.

While a contractor and subcontractor may elect to establish its own training program (particularly for implementation of company specific policies and processes), a contractor or subcontractor could also take advantage of third party training programs, such as those deployed by SAE International concerning key industry standards, and the Government Industry Data Exchange Program concerning reporting practices. Various industry and government organizations conduct symposiums, seminars and conferences where related practices are discussed, such as the National Defense Industrial Association (NDIA), Aerospace Industries Association (AIA), American Bar Association (ABA), the Counterfeit Microelectronics Working Group host by the US Intellectual Property Rights Enforcement Center, the US DoD Defense Standardization Program Office, and many others.

Third party training programs, symposiums, seminars, conferences and other resources should be used to help keep personnel and internal processes up to date.[2] These resources provide current counterfeiting information and trends, detection and avoidance techniques, industry standards, etc.

Henry Livingston

[1] DFARS 252.246–7007 (c) (1) The training of personnel.

[2] DFARS 252.246–7007 (c) (10) Process for keeping continually informed of current counterfeiting information and trends …

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

This site uses Akismet to reduce spam. Learn how your comment data is processed.

%d bloggers like this: