When it comes to avoiding counterfeit components, the CALCE and SMTA “Counterfeit East” symposium at the University of Maryland, College Park is a conference we look forward to attending. Counterfeit avoidance discussions continue to fall in a couple of camps: tags and tagging, test and inspection and quality/process control. On the legal side of things, last year the NDAA FY2012, Sec 818 was a big point of discussion; this time around the recent DFARS release brought with it frustration and a continued lack of clarity.
In 2010 VisionTech became one of the first companies actively prosecuted for the intentional sale and distribution of counterfeit components. When the NDAA FY2012 was signed in April 2012, Sec. 818 was distinctly ambiguous about defining “counterfeit”, “suspect counterfeit”, and “Trusted Supplier.” Lacking clear guidance in these areas, industry worked together to define these terms for themselves. Standards like SAE’s AS6081 and AS5553 have been rolled out and adopted, with SAE subcommittees working diligently simply to define critical terms to go with industry best practices.
Unfortunately, this recent DFAR is no more clearly defined, and the definitions of “counterfeit” and “suspect counterfeit” are still ambiguous. In fact, some areas of the legislation seem to conflict with the NDAA, Sec 818 – it will take a lawyer to truly understand the nature of these conflicts and to determine which one would take precedence.
Through conversations with my fellow symposium participants, there was a general sense of relief as SAE’s AS6081 and AS5553 are unofficially being accepted for the DFARS, “best practices” when it comes to showing due diligence. However, the supply chain is far from secure. Contractors are encouraged to assess suppliers by including an outline of quality and test processes and the DLA continues to face industry criticism while moving forward with requiring DNA tagging on any component supplied to them.
On the whole, the conference was a good one. There continues to be new information coming out, and we’re happy to see that the supply chain is starting to recognize the power of collaboration. Ethan, our fearless leader, did a great job during our presentation… and once again the point was clear: If you can manage your legacy systems proactively – you’re that much more secure in the face of counterfeit components.
Kaye & the GDCA Team