Category Archives: Definitions

Trusted Supplier Steering Group comments on DFARS Case 2012-D055

The Trusted Supplier Steering Group (TSSG) submitted comments on DFARS Case 2012-D055.

In its comments, the TSSG offers recommendations to avoid confusion between the requirements of the proposed DFARS and the existing “DoD Trusted Supplier Program“.

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Missing Definition of ‘Trusted Supplier’ in the proposed DFARS Rule on “Detection and Avoidance of Counterfeit Electronic Parts”

The Federal Register Notice concerning the proposed DFARS Rule on “Detection and Avoidance of Counterfeit Electronic Parts” [1] describes partial implementation of the National Defense Authorization Act for Fiscal Year 2012 [2], including “the use of trusted suppliers” [3]. Within its criteria for an acceptable “Contractor Counterfeit Electronic Part Avoidance and Detection System”, the proposed rule includes “Use and qualification of trusted suppliers”. The proposed rule, however, does not include a definition for the term “trusted supplier”, nor does the new DoD counterfeit prevention policy [4] include a definition for this term.

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A Problematic Definition of ‘Counterfeit Part’ within the Proposed DFARS Rule on Detection and Avoidance of Counterfeit Electronic Parts

The proposed definition of “counterfeit part” within the proposed DFARS Rule on “Detection and Avoidance of Counterfeit Electronic Parts” introduces a number of inconsistencies and problems.

(updated 2013/05/23 re definition of ‘legally authorized source’)

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NASA Proposes New Definitions

NASA is proposing new definitions for the terms "counterfeit goods" and "legally authorized source" for inclusion within the NASA FAR Supplement … Continue reading

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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Counterfeiting vs. Value Added Processes

I recently heard a few questions about whether or not parts subjected to “upscreening” or other value added processes should be considered counterfeit parts. This is particularly relevant to those who use distribution sources or 3rd Party Logistics (3PL) providers to perform value added work.

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Trends in Standards Activity – Changes in Scope and Gaps in Product Authentication Requirements

During engagements in standards activity surrounding counterfeit avoidance and detection, I observed two recent trends that to my knowledge have not been widely publicized to the user community at large:

  • Changes to the scope of these standards
  • Gaps in product authentication requirements between standards directed to contractors vs standards directed to part distributors

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Unfortunate use of the term ‘Trusted Supplier’

The use of the term trusted supplier within Section 818 of the FY2012 NDAA is an unfortunate choice of words on the part of Congress. It’s use here differs significantly from its current use with respect to the “DoD Trusted Foundry Program”, an accreditation plan for design, fabrication, packaging and test services across a broad technology range for specialized governmental applications.

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