About

My purpose in establishing this blog is to discuss a broad variety of topics associated with the counterfeit parts problem and to share insight into counterfeit avoidance methodologies. Though my personal experience and insight stems from work within the aerospace and defense industries, many of the topics and insights apply to other high reliability applications.

Henry Livingston

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12 thoughts on “About

  1. Owen Peters says:

    Henry, Here’s another article from Nextgov I thought you might be interested in.

    http://www.nextgov.com/defense/2012/12/pentagon-directive-targets-fake-parts-vulnerabilities-arms-systems/59897/

    • The DoD directive this article refers to is DoDI 5200.44, Protection of Mission Critical Functions to Achieve Trusted Systems and Networks (TSN) [http://wp.me/p263iE-li]
      This is a prime example of how DoD views the counterfeiting and tainting/tampering as two major components of a broad problem.

  2. Owen Peters says:

    Henry FYI,
    Computer Systems Across Industries at Risk from Counterfeit Electronic Components
    In a recent survey of companies across 20 different industries, 90 percent of respondents purchased counterfeit electrical components during the past six months, and nearly half—45 percent—of those purchases were made in support of computer operations, reports TodayComponents.com, a leading wholesaler of electronics and electrical components.

    http://www.prweb.com/releases/2013/3/prweb10516597.htm

    • Thanks, Owen.
      This PR piece is an odd mashup. It opens with results from a “recent survey”, but I find nothing about it from the attributed source. The rest consists of clippings from other articles and papers (some of which are dated). Seems to be more about drawing attention to the Independant Distributor author than informing the reader.

  3. Owen Peters says:

    Henry, I’d rather not dominate this space so if you would, please feel free to delete this after consideration. Perhaps you can address the issue at some point.
    Sincerely,
    Owen

    H.R. 1960—FY14 NATIONAL DEFENSE
    AUTHORIZATION BILL
    CHAIRMAN’S MARK

    While it’s early in the game Congress is working on next years NDAA. Here’s an excerpt (from the Chairman’s “Mark-up”) released yesterday which would amend Sec 818 of the 2012 NDAA as follows:

    SUBTITLE B—AMENDMENTS TO GENERAL CONTRACTING AUTHORITIES, PROCEDURES,
    AND LIMITATIONS
    Section 811—Additional Contractor Responsibilities in Regulations Relating to
    Detection and Avoidance of Counterfeit Electronic Parts
    This section would amend section 818 of the National Defense
    Authorization Act for Fiscal Year 2012 (Public Law 112–81) to provide that the
    costs associated with the use of counterfeit electronic parts, and the subsequent cost
    of rework or corrective action that may be required to remedy the use or inclusion of
    such parts, are allowable costs under Department of Defense contracts if the
    counterfeit electronic parts were procured from an original manufacturer or its
    authorized dealer, or from a trusted supplier.

    I’m not an attorney but it seems to me that the proposed amendment would broaden the “safe harbor” provisions in the original considerably. It should be interesting to hear Henry Livingston and other subject matter expert’s take on this which I would expect to be forthcoming.

    The “Mark-up”can be found here (pages 13-14):
    http://docs.house.gov/meetings/AS/AS00/20130605/100884/BILLS-113HR1960ih.pdf

    The 2012 NDAA here (amendment proposal to pages 198-199):
    http://www.gpo.gov/fdsys/pkg/PLAW-112publ81/pdf/PLAW-112publ81.pdf

    • I added my opinion of the proposal to my original post on this subject …
      http://wp.me/p263iE-If

      This proposed amendment would introduce an exception that is potentially narrower than the amendment introduced by NDAA2013§833.

      This proposal would make costs to remedy a counterfeit part quality escape allowable costs if the counterfeits were “procured from an original manufacturer or its authorized dealer or from a trusted supplier in accordance with regulations…”

      The proposed DFARS on counterfeit electonic parts avoidance and detection does not define the term ‘trusted supplier’ and it is premature to speculate on where the rule making process will lead in this area.

      An exception concerning counterfeits “procured from an original manufacturer or its authorized dealer” is an extremely narrow one. An exception with similar probability of occurrence might be a meteor strike on Capitol Hill.

  4. Owen Peters says:

    Henry,
    I’m not sure how this changes things but it was just posted on the DIBBS site…
    HIGHER LEVEL QUALITY REQUIREMENT FOR DLA AVIATION

    NOTICE: When Higher Level Quality is a requirement of a solicitation for
    DLA-Aviation, quality systems complying with MIL-I-45208 will no longer be
    acceptable. A Quality Management Program meeting the requirements of ISO
    9001:2008; a program comparable to ISO 9001:2008 or a tailored version of
    ISO 9001:2008 is required.

    • MIL-I-45208 hasn’t been an active mil spec for well over a decade now. I don’t have specific insight into this, but it appears that DLA continues to see responses to solicitations citing this specification rather than current DoD adopted QMS standards.

  5. Owen Peters says:

    Henry,
    Just posted on DIBBS Board, thought you might be interested…
    AVIATION HIGHER LEVEL QUALITY

    Effective (November 1, 2013) – DLA Aviation solicitations that include FAR 52.246-11 will require compliance with ISO 9001:2008, or a tailored program that meets the following ISO 9001:2008 paragraphs:

    https://www.dibbs.bsm.dla.mil/notices/msgdspl.aspx?msgid=718

  6. Owen Peters says:

    Good morning Henry, (This is beginning to look like a private link between the two of us)…
    Did you attend or are you privy to any information you can share that was addressed at yesterday’s DLA Land & Maritime Industry Outreach Forum re: Electrical & Electronics?

    Much appreciate any information or insight, Thanks.

    https://www.dibbs.bsm.dla.mil/notices/msgdspl.aspx?msgid=723

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