Category Archives: Clauses

Docket DARS-2015-0038, Detection and Avoidance of Counterfeit Electronic Parts–Further Implementation (DFARS Case 2014-D005

Comment period is closed for Docket DARS-2015-0038, Detection and Avoidance of Counterfeit Electronic Parts–Further Implementation (DFARS Case 2014-D005).
Written comments are available at Regulations.gov

‘Contractor Counterfeit Electronic Part Detection and Avoidance Systems’ … Part 5

Obsolescence Management and Its Relationship to Counterfeit Electronic Part Avoidance

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‘Contractor Counterfeit Electronic Part Detection and Avoidance Systems’ … Part 4

Abolishing Counterfeit Electronic Parts Proliferation through Reporting, Quarantining, and Screening Reports from Credible Sources

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‘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

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

US Government regulations and industry standards addressing counterfeit electronic parts detection and avoidance have blossomed over the past several years and will evolve over the foreseeable future. This is particularly true of regulations governing DoD acquisition and ongoing standards activity to better align industry standards with these regulations. In the meantime, DoD organizations and their contractors must work within the framework established by regulations introduced a year or so ago.[1]

The following is the first in a series of essays describing my thoughts on establishing and implementing a “Counterfeit Electronic Part Detection and Avoidance System” that complies with DFARS Clause 252.246-7007; and how SAE Aerospace Standard AS5553 can be used to articulate requirements for a “Counterfeit Electronic Part Detection and Avoidance System” and to serve as criteria for assessing the adequacy the system.

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Counterfeit Prevention Clauses and Potential False Claims Act Exposure

In an earlier essay, I described how the pace and exuberance of counterfeit prevention requirements flow down activity on the part of prime and upper tier contractors has accelerated with the introduction of NDAA2012§818. Many observe that it has become commonplace for a number of prime and upper tier contractors to include overly broad counterfeit parts clauses in their purchase order term and conditions, largely due to speculation on the details of forthcoming regulations.

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