Monthly Archives: March 2016

ICC’s BASCAP highlights link between counterfeiting and terrorism at the United Nations

The International Chamber of Commerce (ICC)’s Business Action to Stop Counterfeiting and Piracy (BASCAP) addressed United Nations (UN) delegates on how the trade in counterfeit and pirated goods helps to finance organized crime and terrorism. …

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FAR / DFAR Case Update (28 Mar 2016)

Status updates from the ‘Open Cases Reports’ …

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Proposed Rule re DFARS Case 2016-D010: Cost of Remedy for Use or Inclusion of Counterfeit Electronic Parts

DoD is proposing to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to implement a section of the National Defense Authorization Act for Fiscal Year 2016 that amends the allowability of costs of counterfeit electronic parts or suspect counterfeit electronic parts and the cost of rework or corrective action that may be required to remedy the use or inclusion of such parts.

Defense Federal Acquisition Regulation Supplement: Costs Related to Counterfeit Electronic Parts

The proposed rule would revise section 231.205-71 to read as follows:

231.205-71 Costs related to counterfeit electronic parts and suspect counterfeit electronic parts.

(a) Scope. This subsection implements the requirements of section 818(c)(2), National Defense Authorization Act for Fiscal Year 2012 (Pub. L. 112-81), as modified by section 833, National Defense Authorization Act for Fiscal Year 2013 (Pub. L. 112-239) and section 885 of the National Defense Authorization Act for Fiscal Year 2016 (Pub. L. 114-92).

(b) The costs of counterfeit electronic parts and suspect counterfeit electronic parts and the costs of rework or corrective action that may be required to remedy the use or inclusion of such parts are unallowable, unless—

(1) The contractor has an operational system to detect and avoid counterfeit parts and suspect counterfeit electronic parts that has been reviewed and approved by DoD pursuant to 244.303;

(2) The counterfeit electronic parts or suspect counterfeit electronic parts are Government-furnished property as defined in FAR 45.101 or were obtained by the contractor in accordance with the clause at DFARS 252.246-70XX, Sources of Electronic Parts [as proposed to be added at 80 FR 56939, September 21, 2015]; and

(3) The contractor—

(i) Discovers the counterfeit electronic parts or suspect counterfeit electronic parts; and

(ii) Provides timely (i.e., within 60 days after the contractor becomes aware) notice to the cognizant contracting officer(s).

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

Proposed revision B to SAE AS5553 is now in the formal balloting process. The outcome of the collaborative work between industry subject matter experts and US DoD representatives, in my view, created a proposed revision to AS5553 that will be useful toward articulating requirements for a “Counterfeit Electronic Part Detection and Avoidance System” that aligns well with recent DoD regulations.

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.  Proposed revision B includes changes to better align with DFARS Clause 252.246-7007. I strongly encourage US Defense contractors and their subcontractors, and DoD organizations to support this forthcoming revision to AS5553.

Last fall, I prepared the following paper which offers guidance to contractors and subcontractors in establishing and implementing a “Counterfeit Electronic Part Detection and Avoidance System” that complies with DFARS Clause 252.246-7007. Though this paper refers to revision A to AS5553, I believe the guidance offered remains relevant to proposed revision B to AS5553 and the forthcoming ARP6328.  ….

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

 

NOTE: This paper is a compilation of material published in earlier posts (i.e. ‘Contractor Counterfeit Electronic Part Detection and Avoidance Systems’ – Parts 1 through 6, Oct and Nov 2015)

FAR / DFAR Case Update (18 Mar 2016)

Status updates from the ‘Open Cases Reports’ …

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“JEDEC tackles counterfeiters with new standard”

“JEDEC has published JESD243, which addresses manufacturers’ responsibilities in the fight against counterfeit electronic parts. … ”

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My personal opinion … This ‘standard’ ranks very high among the more self serving standards I have seen in the counterfeit avoidance world.

H Livingston

FAR / DFAR Case Update (11 Mar 2016)

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FAR / DFAR Case Update (7 Mar 2016)

Status updates from the ‘Open Cases Reports’ …

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FAR / DFAR Case Update (4 Mar 2016)

Status updates from the ‘Open Cases Reports’ …

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President Of Aviation Parts Company Arrested For Fraudulently Supplying Defective Airplane Parts To U.S. Government | Department of Justice

Paul Skiscim, President of Aerospec, Inc., was arrested on federal charges of supplying defective airplane parts to the federal government for use in its aircraft, including military aircraft. …

More at Department of Justice