‘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

The purchase and use of counterfeits can be avoided if one (a) acquires electronic parts from the original component manufacturer (OCM) or the OCM’s authorized distributors, or (b) can confirm the hand offs of parts to the OCM or the OCM’s authorized distributors. Some Independent Distributors acquire electronic parts from an OCM or the OCM’s authorized distributors and can confirm these transactions. In the case of electronic parts acquired from the open market, however, suppliers generally cannot confirm traceability to the OCM or the OCM’s authorized distributors. It is this inability to confirm traceability to the OCM or the OCM’s authorized distributors that prompts the need to apply inspections, tests and other methods designed to avoid the procurement and use of counterfeits. This procurement risk mitigation process is described in SAE Aerospace Standard AS5553.[1] Taking a cue from government and industry subject matter experts, the US Congress included this expectation in the original legislation that initiated the final rule under DFARS Case 2012-D055.[2]

An organization meets the traceability requirements of AS5553 and the objective of DFARS 252.246–7007(c)(2) and (4) [3] if the organization establishes and applies processes and procedures that …

(a) assure procurement from the OCM or the OCM’s authorized distributors The organization needs not seek out traceability (and associated artifacts mapping the path to the OCM) when it purchases parts from the OCM itself or when it purchases parts from the OCM’s authorized distributors. The organization’s procurement and receiving records confirming the organization’s source should suffice.

(b) confirm traceability to the OCM for parts procured from other suppliers If the organization uses a supplier to acquire material on the organization’s behalf (such as an SDB to meet FAR requirements for small business set asides), that supplier needs to provide evidence that it acquired the material from the OCM itself or from the OCM’s authorized distributors (e.g. the organization directs the sourcing to the OCM or the OCM’s authorized distributors and the organization previously evaluated the supplier’s ability to follow instructions). The organization’s procurement and receiving records confirming its supplier’s source should suffice.

(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. If the organization finds a compelling need to seek out material from a supplier who plans to acquire material from, or possesses inventory acquired from other suppliers who are not the OCM or the OCM’s authorized distributors (e.g. purported ‘authentic OEM surplus’, part sourced from the open market, etc.), the organization should seek out and evaluate the integrity of supply chain traceability information mapping the path to the OCM (e.g. contact the intermediaries and OCM to verify the evidence provided is associated with the parts supplied, etc.) and seek out information to verify adequate storage and handling. In the absence of verifiable traceability data and proof of adequate storage and handling, and in the absence of support from the OCM, the organization should see to the performance of tests and inspections designed to detect counterfeit electronic parts. The outcome of these tests and inspections should serve as the basis for “credible evidence” providing “reasonable doubt that the electronic part is authentic”.

When selecting tests and inspections to detect counterfeits, DFARS 252.246–7007[4] [5] calls for selection based on minimizing risk to the Government, [6] and requires that determination of risk shall be based on …

  1. the assessed probability of receiving a counterfeit electronic part;
  2. the probability that the inspection or test selected will detect a counterfeit electronic part; and
  3. the potential negative consequences of a counterfeit electronic part being installed (e.g., human safety, mission success) where such consequences are made known to the Contractor.

 

The following diagram taken from AS5553[7] presents a notional relationship between the selection and application of tests and inspections to detection counterfeit electronic parts commensurate with product risk.

rm_as5553fige2testevalchart

Standards activity is underway to assist contractors and subcontractors in the selection inspections and tests to detect counterfeit parts, to describe the procedure for these inspections and test, and to define acceptance and rejection criteria for those inspections and tests.[8]

Henry Livingston


[1] AS5553 Appendix B – Purchasing Process, Figure B3 – Procurement Risk Mitigation.

[2] H.R.1540: National Defense Authorization Act for Fiscal Year 2012, Sec. 818. Detection and Avoidance of Counterfeit Electronic Parts

[3] DFARS 252.246–7007 (c) (4) Processes for maintaining electronic part traceability…

[4] DFARS 252.246–7007 (c) (2) The inspection and testing of electronic parts…

[5] DFARS 252.246–7007 (c) (7) Methodologies to identify suspect counterfeit parts…

[6] DFARS 252.246–7007 (c) (2) The inspection and testing of electronic parts…

[7] AS5553 Figure E1- Test Evaluation Risk Stack Chart

[8] Proposed AS6171, Test Methods Standard; General Requirements, Suspect/Counterfeit Electrical, Electronic, and Electromechanical Parts

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