Monthly Archives: October 2016

Changes to Counterfeit Parts Regulations Merit Review, Revision to Industry Practices – Robert S. Metzger

Here is a paper published in the Bloomberg BNA Federal Contracts Report on 25 October…

Changes to Counterfeit Parts Regulations Merit Review, Revision to Industry Practices
by Robert S. Metzger

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FAR / DFARS Case Update (21 Oct 2016)

Status updates from the ‘Open Cases Reports’ …

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FAR / DFARS Case Update (17 Oct 2016)

Status updates from the ‘Open Cases Reports’ …

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Public Comments re DFARS Case 2016-D013: Amendments Related to Trusted Suppliers

Public Comments re DFARS Case 2016-D013, Amendments Related to Trusted Suppliers, are available from regulations.gov

FAR / DFARS Case Update (11 Oct 2016)

Status updates from the ‘Open Cases Reports’ …

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DFARS clause 252.246-7008, RMA returns and stock rotation material

The following was included in correspondence I sent to the SIA and ECIA this afternoon …

DFARS Case 2014-D005 amended DFARS clause 252.246-7007, Contractor Counterfeit Electronic Part Detection and Avoidance System, and introduced a new clause that will apply to non-CAS covered contracts and flow downs – 252.246-7008, Sources of Electronic Parts.

The amendment to DFARS clause 252.246-7007 states that the flowdown is not to apply to Original Component Manufacturers (OCMs). Though an apparent error needs to be fixed, the new clause 252.246-7008 is not to be flowed down to OCMs either. I view this as a good thing generally and have been a proponent of context sensitive flowdowns rather the one size (tries to) fit all situation we had before this amendment was released in August.

That said, there is a provision within 252.246-7008 that will affect Authorized Distributors  (ADs) and will also reach OCMs. Take a look at 252.246-7008(b)(3)(i)(B) and at 252.246-7008(b)(3)(ii)(A). …  Continue reading

National Defense Industrial Association (NDIA) Comments on DFARS Case 2016-D013, “Amendments Related to Sources of Electronic Parts.”

NDIA submitted comments on DFARS Case 2016-D013, “Amendments Related to Sources of Electronic Parts.” Read more at NDIA.org.

Final Rule re: “Department of Defense (DoD)’s Defense Industrial Base Cybersecurity Activities”

“This final rule responds to public comments to the interim final rule published on October 2, 2015. This rule implements statutory requirements for DoD contractors and subcontractors to report cyber incidents that result in an actual or potentially adverse effect on a covered contractor information system or covered defense information residing therein, or on a contractor’s ability to provide operationally critical support….”

More at federalregister.gov

FAR / DFARS Case Update (30 Sep 2016)

Status updates from the ‘Open Cases Reports’ …

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