Category Archives: COTS

COTS and Challenges to Implementing the Proposed DFARS Rule on “Detection and Avoidance of Counterfeit Electronic Parts”

In its June 2000 report on “Commercial Item Acquisition: Considerations and Lessons Learned“, DoD advises that the use of commercial items “frequently means embracing commercial business practices that are embedded in the commercial item” and “many DoD requirements must be adjusted to accommodate both the vendor’s anticipated uses of the commercial item and the vendor’s business practices”. The Proposed DFARS Rule on “Detection and Avoidance of Counterfeit Electronic Parts”, however, fails to address these realities.

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Focus Areas for an A&D Contractor Industry Counterfeit Prevention Strategy

A high level counterfeit prevention strategy is needed to address standards gaps and to resolve implementation issues that, to some degree, are driven by new and forthcoming US Government requirements directed to the aerospace and defense (A&D) Contractor Industry. Collaboration between A&D Contractor Industry companies is key to developing such a strategy, focusing limited resources and driving meaningful implementation at appropriate levels within the supply chain.

I offer the following thoughts on focus areas to include in a high level counterfeit prevention strategy developed from the perspective of A&D contractors.

 

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Where Policy, Legislation, Standards and Practicality Collide – Counterfeit Parts Prevention Issues Requiring Government / Industry Collaboration to Address

Legislation and regulatory requirements and standards gaps continue to present aerospace & defense industry and US government users with significant implementation challenges with respect to counterfeit part avoidance and detection. The counterfeit parts issue is similar to the lead-free electronics issue in that regulations drive the need for standards, but technical challenges and supply chain limitations must be recognized so that reasonable and implementable regulations and policies are developed in response to the threat. Though many of these challenges have been discussed in Industry and Government forums and described in trade literature and the media, many remain unresolved.

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Cisco takes on rogue suppliers with device to ID counterfeit parts – Nextgov.com

Computer equipment maker Cisco soon will release a tool that automatically detects imitations of its branded products on federal customer systems…

More @ Nextgov.com

FY2012 NDAA – The Use of COTS and Challenges to Implementing New DoD Requirements

Over the past decade DoD has increased its use of “commercial items” in order to provide the DoD with the latest available technology and to reduce cycle times and lower program costs. In its June 2000 report on “Commercial Item Acquisition: Considerations and Lessons Learned“, DoD described “an era of unprecedented change in the make-up and nature of the national and defense industrial bases” and provided guidance in the acquisition and support of commercial items. The use of commercially available off-the-shelf (COTS) equipment and assemblies (see DFARS 202.101) presents challenges to implementing the requirements described within Section 818 of the FY2012 NDAA: Detection and Avoidance of Counterfeit Electronic Parts.

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