CounterfeitParts_05_PreventiveMeasures

Counterfeit parts has some risks in aerospace industry. Risks include:

  • Procurement of counterfeit parts
  • Weak supplier selection process
  • Failure to detect and inspect counterfeit parts
  • Process in place is non-existent or inadequate in responding to counterfeit parts
  • Personnel unaware of counterfeit parts issue

Risk Matrix:

  • Severity * Probability = Risk
  • Severity is typically high in the aerospace business
  • Minimizing probability is the next best option. Controlled market has lower probability of counterfeit goods than open market

 

The preventive measures for counterfeit parts are:

  • Obsolescence prevention
  • Source selection (in order of priority): 
    • Original component manufacturers
    • Franchised distributors
    • Qualified Independent Distributor
  • Procurement Requirements
  • Quality system audits and/or Counterfeit parts mitigation process audits
    • Equipment providers (e.g., AS9100)
    • Distributors (e.g., AS9120)
    • Contract Manufacturer/Assembler (if they procure parts for the customer)
  • Review the supplier's returns process (RMA) as applicable
    • A weak returns process is one way an otherwise good supplier (authorized or not) could be exposed and inadvertently pass on counterfeit components.
  • Parts authentication tools

 

The procurement quality clauses are:

  • Procurement from an Authorized Source
  • Manufacturer’s/Authorized Distributor’s Certification Supply Chain Traceability Quality System Requirements (e.g., AS9120)
  • Notification of:
    •   Impoundment/quarantine.  Seller cost liability.  Reporting to other buyers and criminal investigative authorities (GIDEP, ERAI)
    •  Criminal penalties associated with falsification

 

SAE AS5553 Standard for "Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition" suggest a plan for Procurement Risk Mitigation:

Figure: Procurement Risk Mitigation Flow Diagram

All Electrical, Electronic, and Electromechanical (EEE) components included in assemblies and subassemblies being delivered per this order must have been procured by the seller directly from either the manufacturer of the item(s) or an authorized distributor of the manufacturer of the item(s). The certifications of the above mentioned (EEE) components shall be retained per the records retention requirements directed elsewhere within this order.

Any EEE (Electrical, Electronic, and Electromechanical) components and devices delivered per this order that have not been procured by the seller per this requirement must have this order amended to include a statement by the Purchasing Agent explaining and allowing the deviation from this requirement prior to delivery of the item(s) to the Buyer.

Applies to all EEE components and devices being delivered as detail items per this order, and all EEE components and devices included in assemblies and subassemblies being delivered per this order. Supplier shall approve and retain part Certificate of Conformances and upon Buyer’s request shall be made available. Upon request by the Purchasing Agent, a legible copy of any manufacturer’s or authorized distributor’s certification stated herein shall be delivered to the Purchasing Agent within 48 hours of the request.
Seller’s Certificate of Conformance shall, at minimum, include the following:

  • Seller’s Name and address
  • Seller’s and / or Buyer’s Part number and dash number
  • Batch identification for the item(s) such as date codes, lot codes, serializations, or other batch identifications.
  • Signature or stamp with title of Seller’s authorized personnel signing the certificate.

Note: Distributors shall, in addition to the above, include actual manufacturer's name for each item shipped.

Seller shall maintain a method of item traceability that ensures tracking of the supply chain back to the manufacturer of all Electrical, Electronic, and Electromechanical (EEE) components and devices included in assemblies and subassemblies being delivered per this order. This traceability method shall clearly identify the name and location of all of the supply chain intermediaries from the manufacturer to the direct source of the product for the seller. The manufacturer shall also include the manufacturer’s batch identification for the item(s) such as date codes, lot codes, serializations, or other batch identifications.

If suspect/counterfeit parts are furnished under this agreement and are found on the (site), such items shall be impounded by (site). The Seller shall promptly replace such items with items acceptable to the (site) and the Seller shall be liable for all costs relating to impoundment, removal, and replacement. (Site) may turn such items over to the U.S. Office of Inspector General, the FBI, etc. for investigation and reserves the right to withhold payment for the suspect items pending the results of the investigation.

Figure: Risk Stack Chart (From SAE AS5553 Standard)

 

SAE AS5553 Standard for "Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition" applies to many elements to reduce the risk of counterfeit parts:

To reduce risk, SAE AS5553 Standard offers to fill in more are within the following pyramid:

 

NASA Supplier Assessment System (SAS)

Prevention of counterfeit parts are very important for mission safety for NASA. 

Section 1206 of the NASA Authorization Bill 2010 requires NASA:
    "...to plan, develop, and implement a program, in coordination with other Federal agencies, to detect, track, catalog, and reduce the number of counterfeit electronic parts in the NASA supply chain."

Letter from NASA Administrator to Speaker of the House of Representatives states:
    "NASA fully concurs with GAOs recommendation for enhanced cross-agency communication, coordination, and sharing of parts quality information in order to help mitigate threats posed by defective and nonconforming parts."

NASA Authorization Bill of 2010, Section 1206, Counterfeit Parts, requires an internal Agency-wide database to track suspected and confirmed counterfeit electronic parts. SAS is sponsored by NASA Headquarters and it is a comprehensive on-line repository of supplier information. It provides information to assist the quality assurance community in evaluating and determining supplier risk. It is available to approved civil service personnel from all NASA Centers, other Government Agencies, Prime Contractors, and NASA direct support contractors.

SAS currently displays the following categories of supplier data:

 

SAE AS5553 Standard Requirements

SAE AS5553 Standard for "Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition" requires an organization to "develop and implement a counterfeit electronic parts control plan that documents its processes used for risk mitigation, disposition, and reporting of counterfeit parts…" This counterfeit electronics control plan has many requirements. For "Parts availability" requirement, the standard says that " the process shall maximize availability of authentic, originally designed … parts throughout the product’s life cycle, including management of part obsolescence…" The standard also requires sellers to "...establish and implement test and inspection activities necessary to assure the authenticity …"

According to Honeywell company, testing level can be changed according to the risk (Counterfeit Parts Detection Panel, NASA QLF 2011, Cape Canaveral FL):