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1
GE Title or job number
9/29/2015
Anti-counterfeit standards summary
July 2015
Prepared by:
Jo Vann
IEC TC107 WG3 ‘Counterfeit electronic parts; avoidance,
detection, mitigation, and disposition in avionics applications’
convener , see
http://www.iec.ch/dyn/www/f?p=103:14:0::::FSP_ORG_ID,FSP
_LANG_ID:5736,25
Member of SAE: G19A, G19AD, G19C, G19CI, AMPC, IAQG
2
GE Title or job number
9/29/2015
2
The Avionics Supply Chain
1. Parts &
Materials
Suppliers
2. Board
Assemblers
3. Avionics
OEMs,
Logistics,
Maintenance
and Repair
4. Platform
Integrators
5. Operators
& Regulators
Parts
Boards
Contract Mfg.
Suppliers CustomersSolder etc.
Suppliers
Customers
15 - 40 yr
Lifecycle
3 - 6 yr
Lifecycle
IEC/TS 62668-1/SAE AS5553A Anti-
counterfeit and IEC/TS 62239-1
ECMP
Most life cycle
costs are incurred here
and managed by ECMP
Global Supply Chain
SAE AS5553A counterfeit avoidance
Requirements
flow-down vs.
products flow-up
process is
disrupted here
Aerospace
Captive
To build products that must
meet mil-aero requirements
(what we must control)
Using COTS components
targeted for other markets
(what we cannot control)
Aerospace Electronics
• Depends on
materials and
components
developed for other
industries
• Vastly different
lifecycle applications
3
GE Title or job number
9/29/2015
What is the problem?
• In 2010/2011 the USA DoD identified upwards of a million counterfeit components
in their Military supply chain.
 This resulted in the 2012 NDAA section 818 anti-counterfeit clause which was
published May 2014 as DFAR 252.247.7007
• Researcher IHS analysed electronics industry data in 2013 concerning counterfeit
parts that were reported from 2001 until early 2012:
 More than 12 million counterfeit parts have been reported over the last five
years to 2013
 57% of counterfeit part reports involved obsolete or end of life parts.
 Nearly 37% of counterfeit parts involve components still being produced by
manufacturers.
 A single incident of a counterfeit part can cause up to 64 weeks of production line
downtime and cost up to $2.1 million to resolve.
 Counterfeit parts are mostly sold on the open market.
4
GE Title or job number
9/29/2015
Recycling - typically occurs in China
5
GE Title or job number
9/29/2015
International anti-counterfeit standards
SA
E
IEC
IEC/TC
107
WG3
G-14
AAQS
C
IEC/TS6
2668-2
G19A
IEC/TS6
2668-1
G19A
D G19C
AS6171
Test
Methods
AS6496
Franchise
d
distributor
AS6301
,AS646
2
audit
checklist
s
G19CI
AS5553
electronic
component
s
G21
AS617
4
materiels
AS9100
Rev D for
publicatio
n 2016/17
6
GE Title or job number
9/29/2015
Military Supply Chains and contract flow-down
USA
Military
UK
Military
DFARS
in
contracts
DEF STAN
05-135
anti-
counterfeit
DFAR
252.246.70
07
electrical
anti-
counterfei
t
OEM
SAE
AS5553
flow-
down to
suppliers
OEM
suppliers
SAE
AS6496
Franchised
distributors
ARP 6178
non-
franchised
distributor
SAE
AS6171
Materials
7
GE Title or job number
9/29/2015
Anti-counterfeit standards summary
Standard Market
sector
Description Comments
AS/EN/JISQ9100 Avionics OEMS General Quality Management
System
All Avionics OEMs are expected to operate
to this standard which is currently at rev C.
Next revision (rev D) for publication in
2016/2017 will include anti-counterfeit
management requirements for material,
mechanical and electrical components
SAE AS5553 General industry
but mainly used
by Avionics
OEMs
Set of 11 mandatory detailed
requirements for how to buy,
manage, and dispose of
electronic components with
reporting mechanisms when
counterfeits are found
Currently at revision A. Can be used to
satisfy AS9100 rev D electrical component
anti-counterfeit requirements. Next revision
is in process to align it better with DFAR
252.246.7007. Mandated by most USA
Prime Contractors.
SAE AS6174 General industry
but mainly used
by Avionics
OEMs
Similar to SAE AS5553 for
the procurement,
management and disposal of
electronic components but
modified for material and
mechanical components
Can be used to satisfy AS9100 rev D anti-
counterfeit requirements. Use rev A. It is
recognised this is a WIP as many
appendices are not yet complete. Please
join the committee if you have concerns
contact Robert Tipton,
robert.tipton@wyle.com
USA DFAR
252.246.7007
Military US
supply chain
OEMs
Set of 12 mandatory detailed
requirements for how to buy,
manage, and dispose of
electronic components with
reporting mechanisms when
counterfeits are found
Used in US Military contracts. Set of
mandatory rules for covering how to buy and
dispose of electronics components with
reporting rules when counterfeits are
suspected or found. Exceptions not allowed.
Can use SAE AS5553 and /or IEC/TS
62668-1 and IEC/TS 62668-2 to comply
8
GE Title or job number
9/29/2015
Anti-counterfeit standards summary
Standard Market
sector
Description Comments
UK Defence
Standard 05-
135
UK Military
supply chain
OEMs
General overall anti-counterfeit
requirements
Used in UK Military contracts. Part of the
UK Counterfeit Avoidance Maturity model
which is used to assess how ‘counterfeit
aware’ suppliers are. Can use SAE
AS5553 and /or IEC/TS 62668-1 and
IEC/TS 62668-2 to comply
IEC/TS 62668-1 Avionics OEMs Anti-counterfeit requirements for
the purchase and management
of electrical components,
management of the products IP
and control of spares and repairs
Allows the use of SAE AS5553 plans for
components coming into a business and
will allow the use of AS/EN/JISQ anti-
counterfeit plans. Considered to provide a
more ‘holistic’ approach to anti-counterfeit
and recycling component management .
Preferred by European Prime contractors
and suppliers who do not want to work to
SAE AS5553.
IEC/TS 62668-2 Avionics OEMs Risk assessment of electrical
components purchased from
non-franchised sources
Complements SAE AS5553 which has no
risk assessment process for non-
franchised purchases and IEC/TS 62668-
1.
9
GE Title or job number
9/29/2015
Anti-counterfeit standards summary
Standard Market
sector
Description Comments
SAE AS6496 Franchised
distributor for
high reliability,
Aerospace and
Defence market
Fraudulent/Counterfeit
Electronics parts: Avoidance,
Detection, Mitigation and
Disposition-
Authorised/Franchised
Distribution
Released 2014
SAE AS6171 Component Test
Houses for any
market
Test Methods Standards;
Counterfeit Electronic Parts
WIP- several individual test methods are
ready for release: Test method I – External
visual, Test method II- XRF .
Debate about risk mitigation method and
whether it should be part of SAE AS5553B.
AS6081 Non-franchised
distributors
Fraudulent/Counterfeit Electronics
parts: Avoidance, Detection,
Mitigation and Disposition-
Distributors; Counterfeit Electronic
Parts: Avoidance Protocol,
Distributors
Parts are offered by non-franchised distributors with
some basic testing which Avionics OEMs need to
review in their application risk assessment process.
Considered an input into SAE AS5553 or
IEC/TS 62668-2 risk assessment
ARP 6178 Non-franchised
distributors
Fraudulent/Counterfeit
Electronic Parts: Tool for Risk
Assessment of Distributors
Very useful Excel spread-sheet with macro
to remotely audit non-franchised distributors.
Considered an input into SAE AS5553 or
IEC/TS 62668-2 risk assessment
10
GE Title or job number
9/29/2015
Anti-counterfeit standards summary
Standard Market
sector
Description Comments
AS6462A Auditing
bodies and
OEMS
AS5553A Counterfeit
Electronic Parts:
Avoidance, Detection,
Mitigation and
Disposition Verification
Criteria
Audit checklist for SAE AS5553A for
use by OEMs and Third party auditing
bodies.
AS6301 Auditing
bodies and
OEMS
AS6081
Fraudulent/Counterfeit
Electronics parts:
Avoidance, Detection,
Mitigation and
Disposition- Distributors
Verification criteria
Issued in 2014
AIR6273 For everyone
using other
SAE anti-
counterfeit
standards
Terms and Definitions-
Fraudulent/Counterfeit
Electronic parts
Draft – still WIP
11
GE Title or job number
9/29/2015
2015 anti-counterfeit supply chain
12
GE Title or job number
9/29/2015
• Personal liability for employees of companies under the new charge of trafficking
in counterfeit military goods:
 Fines and imprisoned (up to 20 years if claim ‘not guilty’ and later found guilty).
 Impacts countries with weak extradition laws to the USA, e.g. the UK.
• Potential DFAR implementation issues:
 ‘Traceability back to the original component manufacturer’ clause : Prime
contractors i.e. air-framers are finding this clause a massive challenge and are
seeking to limit this to just the traceability to the first assembly of a LRU. This has
been agreed.
 A revision to SAE AS5553 rev A was started last year to incorporate any many
DFAR requirements as possible. The draft was also streamlined significantly.
However this failed an SAE ballot in November. Further discussions with the DoD
have been held with a way forward. The G19 committee has just started up again
working to create SAE AS5553 rev B with an optimistic target publication date of
December 2014.
• DFAR definition of counterfeit (same in SAE AS5553A), also includes fraudulent
components in addition to fraudulent recycled components and is unique to the
USA.
USA Military DFAR rule 252.246.7007 includes:
13
GE Title or job number
9/29/2015
USA prosecutions in 2014
• Vision Tech in Florida in 2010, discussed last year
• June 2014 Massachusetts-based distributor Peter Picone of Epic
International Electronics Inc., pleaded guilty to trafficking in falsified ICs that
had been resurfaced to change the date code and to affixing counterfeit marks
destined for military equipment. The counterfeit parts bore the trademarks of
legitimate companies such as Xilinx, National Semiconductor and Motorola. He
faces 46 months in jail after pleading guilty.
This is the second prosecution on the new charge of trafficking in
counterfeit military goods, see
http://www.law.cornell.edu/uscode/text/18/2320
 The court has taken the unprecedented step of publishing all the
components Mr. Picone ever sold to the US Navy and it implicates
nearly all the non-franchised distributors in the USA.
• The DFAR resulted from the 2012 Section 818 National Defence
Authorization Act (NDAA) signed by President Obama on Dec 31st 2011.
 Some parts of this legislation are still outstanding
14
GE Title or job number
9/29/2015
NDAA section 818 DFARS For US Military Programs
 The latest open DFAR Cases register is located at
http://www.acq.osd.mil/dpap/dars/opencases/dfarscasenum/dfars.pdf which contains
several impending DFAR cases related to section 818 legislation approved by
President Obama
 As of June 0th 2015 the following are pending:
 2015-D020 , DoD use of Trusted Suppliers for Electronic parts. Status report
due data extended to 6/24/2015
 2014-D005, ‘Detection and Avoidance of Counterfeit Electronic Parts-Further
Implementation’, requiring that electronic parts be obtained from ‘trusted
suppliers’: The Case manager has forwarded a draft final DFARS rule to the
processing manager.
 2014-D021, Item Unique Identification (IUID) Prescription Correction, to
modify DFAR 252.211-7003, as some wording was lost. Report due extended
to 6/3/2015.
 Audit activities are part of the Purchasing Systems evaluation see DFAR
252.244.7001 where it is thought that DCMA may develop a new counterfeit
detection and detection systems checklist
15
GE Title or job number
9/29/2015
UK Defence Standard 05-135 – Avoidance of
counterfeit material, published July 2014
• High level language requiring a clear requirement to manage the risk in supply
chains depending on the criticality of the material in relation to performance
and safety where the supplier is aware of the final use of the materiel.
• The supplier shall be able to demonstrate the materiel meets the original
qualification requirements and the safety and performance of the deliverable
materiel and ensure it is not degraded.
 An anti-counterfeit policy
 Flow-down to suppliers
 Appointment of a management representative
 Training
 Purchasing controls
 Test and verification
 Control of non-conforming product
 Reporting
16
GE Title or job number
9/29/2015
IEC committee TC107 WG3 Counterfeit electronic parts
• see http://www.iec.ch/dyn/www/f?p=103:14:0::::FSP_ORG_ID,FSP_LANG_ID:5736,25
• Published a revision in 2014, explaining when recycled components become fraudulent
recycled components for the Chinese National Committee.
 IEC/TS 62668-1, ‘PROCESS MANAGEMENT FOR AVIONICS – COUNTERFEIT
PREVENTION – Part 1: Avoiding the use of counterfeit, fraudulent and recycled electronic
components
 Allows the use of SAE AS5553A plans for components coming into the business.
 Enables OEMs to have one overall plan for SAE AS5553A and IEC/TS 62668-1
 Discusses when recycled components become fraudulent components and why the
Avionics industry cannot use them.
 A revision is on-going in 2015 to add in references to the DFAR, Defence Standard,
AS9100 rev D and remove the Chinese RECS scheme which is not being maintained.
 Refers to the now published IEC/TS 62668-2 ‘PROCESS MANAGEMENT FOR AVIONICS –
COUNTERFEIT PREVENTION – Part 2: Managing electronic components from non-
franchised sources.
 Used as the IEC/TS 62668-1 non franchised distributor risk assessment process.
 Can also be used as a risk assessment process for the following:
o SAE AS5553A,
o DFAR rule 252.246.7007
o DEF STANDARD 05-135
17
GE Title or job number
9/29/2015
SAE International Anti-counterfeit
Specifications• SAE AS5553A for Electronic components
• See http://www.sae.org/
• G-19 committee has active membership mainly from the USA and UK
• SAE AS5553A was published in January 2013 superseding SAE AS5553 which
has misleading definitions.
• Manages components coming into a business only.
• Targeted at general industry and AS9100 requirement is not mandatory.
• Revision B was started to incorporate DFAR 252.246.7007 to the extent that
general industry will allow, but recent ballot of Nov 2014 failed. Further meetings
are planned with the DOD in Washington DC in March.
• The SAE has no Third Party auditing activities and is only publishing standards and
auditing checklists.
• Was endorsed for use by the DoD for USA Military supply chains in 2013 but there is
dispute about whether the new revision B will be adequate.
• The audit checklist for SAE AS5553A is published as SAE AS6462A.
• IECQ WG06 has started to create the administration documents for SAE AS5553 auditing
18
GE Title or job number
9/29/2015
How one
anti-counterfeit
plan can address:
DEF STD 05-135
DFAR 252.246.7007
SAE AS5553A
IEC/TS 62668-1
using the non-
franchised risk
assessment process
from:
IEC/TS 62668-2
19
GE Title or job number
9/29/2015
Key elements for an anti-counterfeit plan
 Publish a plan addressing each requirement of the external standard and/or provide a cross
reference matrix . This protects your business in legal court cases.
 Establish company standard Purchase Order notes which state unambiguously that ‘ no counterfeits
or recycled components are allowed’.
 Orders shall be placed for traceable components from OCMs or franchised distributors or
franchised aftermarket distributors.
 Traceability can be demonstrated by the C of C’s , packing slips, shipping label information, part
marking information ( lot date codes etc.) and are required for each part of the supply chain back
to the original manufacturer.
 Accurate part numbers on the PO to the internal component database information or BOM to that
on the received C of C or Packing slip are required to prove traceability. Each part of the supply
chain has to provide this level of traceability back to the original component manufacturer.
Distributors who automatically default to their internal part number and ship against this, loose
supply chain traceability and cannot be used.
 Accurate, clear Shipment labelling, C of Cs, packing slip details are required from the Distributors.
 Transcription errors, truncated part numbers, bad handwriting, unexplained quantities or
quantities that do not add up after a stock split will results in parts being identified as ‘suspect’
when they are possibly just badly labelled.
 Supply chain anti-counterfeit audits have started.
 Non-franchised distributors require a risk assessment and every order placed may need anti-
counterfeit testing for example to IEC/TS 62668-2 or SAE AS7171 or SAE AS6081 . Special test
specifications will be required. Approval from customers may be required.
20
GE Title or job number
9/29/2015
Overview
21
GE Title or job number
9/29/2015
Anti-counterfeit summary 2012
Contact information:
Jo Vann, TC107 WG3 Anti-counterfeit convenor,
CEO- Component Technology ,
GE Aviation Systems Ltd.,
T +44 (0)1242 632927
F +44 (0)1242 661151
E jo.vann@ge.com
www.ge.com/aviation

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External Anti-counterfeit standards July 14th 2015

  • 1. 1 GE Title or job number 9/29/2015 Anti-counterfeit standards summary July 2015 Prepared by: Jo Vann IEC TC107 WG3 ‘Counterfeit electronic parts; avoidance, detection, mitigation, and disposition in avionics applications’ convener , see http://www.iec.ch/dyn/www/f?p=103:14:0::::FSP_ORG_ID,FSP _LANG_ID:5736,25 Member of SAE: G19A, G19AD, G19C, G19CI, AMPC, IAQG
  • 2. 2 GE Title or job number 9/29/2015 2 The Avionics Supply Chain 1. Parts & Materials Suppliers 2. Board Assemblers 3. Avionics OEMs, Logistics, Maintenance and Repair 4. Platform Integrators 5. Operators & Regulators Parts Boards Contract Mfg. Suppliers CustomersSolder etc. Suppliers Customers 15 - 40 yr Lifecycle 3 - 6 yr Lifecycle IEC/TS 62668-1/SAE AS5553A Anti- counterfeit and IEC/TS 62239-1 ECMP Most life cycle costs are incurred here and managed by ECMP Global Supply Chain SAE AS5553A counterfeit avoidance Requirements flow-down vs. products flow-up process is disrupted here Aerospace Captive To build products that must meet mil-aero requirements (what we must control) Using COTS components targeted for other markets (what we cannot control) Aerospace Electronics • Depends on materials and components developed for other industries • Vastly different lifecycle applications
  • 3. 3 GE Title or job number 9/29/2015 What is the problem? • In 2010/2011 the USA DoD identified upwards of a million counterfeit components in their Military supply chain.  This resulted in the 2012 NDAA section 818 anti-counterfeit clause which was published May 2014 as DFAR 252.247.7007 • Researcher IHS analysed electronics industry data in 2013 concerning counterfeit parts that were reported from 2001 until early 2012:  More than 12 million counterfeit parts have been reported over the last five years to 2013  57% of counterfeit part reports involved obsolete or end of life parts.  Nearly 37% of counterfeit parts involve components still being produced by manufacturers.  A single incident of a counterfeit part can cause up to 64 weeks of production line downtime and cost up to $2.1 million to resolve.  Counterfeit parts are mostly sold on the open market.
  • 4. 4 GE Title or job number 9/29/2015 Recycling - typically occurs in China
  • 5. 5 GE Title or job number 9/29/2015 International anti-counterfeit standards SA E IEC IEC/TC 107 WG3 G-14 AAQS C IEC/TS6 2668-2 G19A IEC/TS6 2668-1 G19A D G19C AS6171 Test Methods AS6496 Franchise d distributor AS6301 ,AS646 2 audit checklist s G19CI AS5553 electronic component s G21 AS617 4 materiels AS9100 Rev D for publicatio n 2016/17
  • 6. 6 GE Title or job number 9/29/2015 Military Supply Chains and contract flow-down USA Military UK Military DFARS in contracts DEF STAN 05-135 anti- counterfeit DFAR 252.246.70 07 electrical anti- counterfei t OEM SAE AS5553 flow- down to suppliers OEM suppliers SAE AS6496 Franchised distributors ARP 6178 non- franchised distributor SAE AS6171 Materials
  • 7. 7 GE Title or job number 9/29/2015 Anti-counterfeit standards summary Standard Market sector Description Comments AS/EN/JISQ9100 Avionics OEMS General Quality Management System All Avionics OEMs are expected to operate to this standard which is currently at rev C. Next revision (rev D) for publication in 2016/2017 will include anti-counterfeit management requirements for material, mechanical and electrical components SAE AS5553 General industry but mainly used by Avionics OEMs Set of 11 mandatory detailed requirements for how to buy, manage, and dispose of electronic components with reporting mechanisms when counterfeits are found Currently at revision A. Can be used to satisfy AS9100 rev D electrical component anti-counterfeit requirements. Next revision is in process to align it better with DFAR 252.246.7007. Mandated by most USA Prime Contractors. SAE AS6174 General industry but mainly used by Avionics OEMs Similar to SAE AS5553 for the procurement, management and disposal of electronic components but modified for material and mechanical components Can be used to satisfy AS9100 rev D anti- counterfeit requirements. Use rev A. It is recognised this is a WIP as many appendices are not yet complete. Please join the committee if you have concerns contact Robert Tipton, robert.tipton@wyle.com USA DFAR 252.246.7007 Military US supply chain OEMs Set of 12 mandatory detailed requirements for how to buy, manage, and dispose of electronic components with reporting mechanisms when counterfeits are found Used in US Military contracts. Set of mandatory rules for covering how to buy and dispose of electronics components with reporting rules when counterfeits are suspected or found. Exceptions not allowed. Can use SAE AS5553 and /or IEC/TS 62668-1 and IEC/TS 62668-2 to comply
  • 8. 8 GE Title or job number 9/29/2015 Anti-counterfeit standards summary Standard Market sector Description Comments UK Defence Standard 05- 135 UK Military supply chain OEMs General overall anti-counterfeit requirements Used in UK Military contracts. Part of the UK Counterfeit Avoidance Maturity model which is used to assess how ‘counterfeit aware’ suppliers are. Can use SAE AS5553 and /or IEC/TS 62668-1 and IEC/TS 62668-2 to comply IEC/TS 62668-1 Avionics OEMs Anti-counterfeit requirements for the purchase and management of electrical components, management of the products IP and control of spares and repairs Allows the use of SAE AS5553 plans for components coming into a business and will allow the use of AS/EN/JISQ anti- counterfeit plans. Considered to provide a more ‘holistic’ approach to anti-counterfeit and recycling component management . Preferred by European Prime contractors and suppliers who do not want to work to SAE AS5553. IEC/TS 62668-2 Avionics OEMs Risk assessment of electrical components purchased from non-franchised sources Complements SAE AS5553 which has no risk assessment process for non- franchised purchases and IEC/TS 62668- 1.
  • 9. 9 GE Title or job number 9/29/2015 Anti-counterfeit standards summary Standard Market sector Description Comments SAE AS6496 Franchised distributor for high reliability, Aerospace and Defence market Fraudulent/Counterfeit Electronics parts: Avoidance, Detection, Mitigation and Disposition- Authorised/Franchised Distribution Released 2014 SAE AS6171 Component Test Houses for any market Test Methods Standards; Counterfeit Electronic Parts WIP- several individual test methods are ready for release: Test method I – External visual, Test method II- XRF . Debate about risk mitigation method and whether it should be part of SAE AS5553B. AS6081 Non-franchised distributors Fraudulent/Counterfeit Electronics parts: Avoidance, Detection, Mitigation and Disposition- Distributors; Counterfeit Electronic Parts: Avoidance Protocol, Distributors Parts are offered by non-franchised distributors with some basic testing which Avionics OEMs need to review in their application risk assessment process. Considered an input into SAE AS5553 or IEC/TS 62668-2 risk assessment ARP 6178 Non-franchised distributors Fraudulent/Counterfeit Electronic Parts: Tool for Risk Assessment of Distributors Very useful Excel spread-sheet with macro to remotely audit non-franchised distributors. Considered an input into SAE AS5553 or IEC/TS 62668-2 risk assessment
  • 10. 10 GE Title or job number 9/29/2015 Anti-counterfeit standards summary Standard Market sector Description Comments AS6462A Auditing bodies and OEMS AS5553A Counterfeit Electronic Parts: Avoidance, Detection, Mitigation and Disposition Verification Criteria Audit checklist for SAE AS5553A for use by OEMs and Third party auditing bodies. AS6301 Auditing bodies and OEMS AS6081 Fraudulent/Counterfeit Electronics parts: Avoidance, Detection, Mitigation and Disposition- Distributors Verification criteria Issued in 2014 AIR6273 For everyone using other SAE anti- counterfeit standards Terms and Definitions- Fraudulent/Counterfeit Electronic parts Draft – still WIP
  • 11. 11 GE Title or job number 9/29/2015 2015 anti-counterfeit supply chain
  • 12. 12 GE Title or job number 9/29/2015 • Personal liability for employees of companies under the new charge of trafficking in counterfeit military goods:  Fines and imprisoned (up to 20 years if claim ‘not guilty’ and later found guilty).  Impacts countries with weak extradition laws to the USA, e.g. the UK. • Potential DFAR implementation issues:  ‘Traceability back to the original component manufacturer’ clause : Prime contractors i.e. air-framers are finding this clause a massive challenge and are seeking to limit this to just the traceability to the first assembly of a LRU. This has been agreed.  A revision to SAE AS5553 rev A was started last year to incorporate any many DFAR requirements as possible. The draft was also streamlined significantly. However this failed an SAE ballot in November. Further discussions with the DoD have been held with a way forward. The G19 committee has just started up again working to create SAE AS5553 rev B with an optimistic target publication date of December 2014. • DFAR definition of counterfeit (same in SAE AS5553A), also includes fraudulent components in addition to fraudulent recycled components and is unique to the USA. USA Military DFAR rule 252.246.7007 includes:
  • 13. 13 GE Title or job number 9/29/2015 USA prosecutions in 2014 • Vision Tech in Florida in 2010, discussed last year • June 2014 Massachusetts-based distributor Peter Picone of Epic International Electronics Inc., pleaded guilty to trafficking in falsified ICs that had been resurfaced to change the date code and to affixing counterfeit marks destined for military equipment. The counterfeit parts bore the trademarks of legitimate companies such as Xilinx, National Semiconductor and Motorola. He faces 46 months in jail after pleading guilty. This is the second prosecution on the new charge of trafficking in counterfeit military goods, see http://www.law.cornell.edu/uscode/text/18/2320  The court has taken the unprecedented step of publishing all the components Mr. Picone ever sold to the US Navy and it implicates nearly all the non-franchised distributors in the USA. • The DFAR resulted from the 2012 Section 818 National Defence Authorization Act (NDAA) signed by President Obama on Dec 31st 2011.  Some parts of this legislation are still outstanding
  • 14. 14 GE Title or job number 9/29/2015 NDAA section 818 DFARS For US Military Programs  The latest open DFAR Cases register is located at http://www.acq.osd.mil/dpap/dars/opencases/dfarscasenum/dfars.pdf which contains several impending DFAR cases related to section 818 legislation approved by President Obama  As of June 0th 2015 the following are pending:  2015-D020 , DoD use of Trusted Suppliers for Electronic parts. Status report due data extended to 6/24/2015  2014-D005, ‘Detection and Avoidance of Counterfeit Electronic Parts-Further Implementation’, requiring that electronic parts be obtained from ‘trusted suppliers’: The Case manager has forwarded a draft final DFARS rule to the processing manager.  2014-D021, Item Unique Identification (IUID) Prescription Correction, to modify DFAR 252.211-7003, as some wording was lost. Report due extended to 6/3/2015.  Audit activities are part of the Purchasing Systems evaluation see DFAR 252.244.7001 where it is thought that DCMA may develop a new counterfeit detection and detection systems checklist
  • 15. 15 GE Title or job number 9/29/2015 UK Defence Standard 05-135 – Avoidance of counterfeit material, published July 2014 • High level language requiring a clear requirement to manage the risk in supply chains depending on the criticality of the material in relation to performance and safety where the supplier is aware of the final use of the materiel. • The supplier shall be able to demonstrate the materiel meets the original qualification requirements and the safety and performance of the deliverable materiel and ensure it is not degraded.  An anti-counterfeit policy  Flow-down to suppliers  Appointment of a management representative  Training  Purchasing controls  Test and verification  Control of non-conforming product  Reporting
  • 16. 16 GE Title or job number 9/29/2015 IEC committee TC107 WG3 Counterfeit electronic parts • see http://www.iec.ch/dyn/www/f?p=103:14:0::::FSP_ORG_ID,FSP_LANG_ID:5736,25 • Published a revision in 2014, explaining when recycled components become fraudulent recycled components for the Chinese National Committee.  IEC/TS 62668-1, ‘PROCESS MANAGEMENT FOR AVIONICS – COUNTERFEIT PREVENTION – Part 1: Avoiding the use of counterfeit, fraudulent and recycled electronic components  Allows the use of SAE AS5553A plans for components coming into the business.  Enables OEMs to have one overall plan for SAE AS5553A and IEC/TS 62668-1  Discusses when recycled components become fraudulent components and why the Avionics industry cannot use them.  A revision is on-going in 2015 to add in references to the DFAR, Defence Standard, AS9100 rev D and remove the Chinese RECS scheme which is not being maintained.  Refers to the now published IEC/TS 62668-2 ‘PROCESS MANAGEMENT FOR AVIONICS – COUNTERFEIT PREVENTION – Part 2: Managing electronic components from non- franchised sources.  Used as the IEC/TS 62668-1 non franchised distributor risk assessment process.  Can also be used as a risk assessment process for the following: o SAE AS5553A, o DFAR rule 252.246.7007 o DEF STANDARD 05-135
  • 17. 17 GE Title or job number 9/29/2015 SAE International Anti-counterfeit Specifications• SAE AS5553A for Electronic components • See http://www.sae.org/ • G-19 committee has active membership mainly from the USA and UK • SAE AS5553A was published in January 2013 superseding SAE AS5553 which has misleading definitions. • Manages components coming into a business only. • Targeted at general industry and AS9100 requirement is not mandatory. • Revision B was started to incorporate DFAR 252.246.7007 to the extent that general industry will allow, but recent ballot of Nov 2014 failed. Further meetings are planned with the DOD in Washington DC in March. • The SAE has no Third Party auditing activities and is only publishing standards and auditing checklists. • Was endorsed for use by the DoD for USA Military supply chains in 2013 but there is dispute about whether the new revision B will be adequate. • The audit checklist for SAE AS5553A is published as SAE AS6462A. • IECQ WG06 has started to create the administration documents for SAE AS5553 auditing
  • 18. 18 GE Title or job number 9/29/2015 How one anti-counterfeit plan can address: DEF STD 05-135 DFAR 252.246.7007 SAE AS5553A IEC/TS 62668-1 using the non- franchised risk assessment process from: IEC/TS 62668-2
  • 19. 19 GE Title or job number 9/29/2015 Key elements for an anti-counterfeit plan  Publish a plan addressing each requirement of the external standard and/or provide a cross reference matrix . This protects your business in legal court cases.  Establish company standard Purchase Order notes which state unambiguously that ‘ no counterfeits or recycled components are allowed’.  Orders shall be placed for traceable components from OCMs or franchised distributors or franchised aftermarket distributors.  Traceability can be demonstrated by the C of C’s , packing slips, shipping label information, part marking information ( lot date codes etc.) and are required for each part of the supply chain back to the original manufacturer.  Accurate part numbers on the PO to the internal component database information or BOM to that on the received C of C or Packing slip are required to prove traceability. Each part of the supply chain has to provide this level of traceability back to the original component manufacturer. Distributors who automatically default to their internal part number and ship against this, loose supply chain traceability and cannot be used.  Accurate, clear Shipment labelling, C of Cs, packing slip details are required from the Distributors.  Transcription errors, truncated part numbers, bad handwriting, unexplained quantities or quantities that do not add up after a stock split will results in parts being identified as ‘suspect’ when they are possibly just badly labelled.  Supply chain anti-counterfeit audits have started.  Non-franchised distributors require a risk assessment and every order placed may need anti- counterfeit testing for example to IEC/TS 62668-2 or SAE AS7171 or SAE AS6081 . Special test specifications will be required. Approval from customers may be required.
  • 20. 20 GE Title or job number 9/29/2015 Overview
  • 21. 21 GE Title or job number 9/29/2015 Anti-counterfeit summary 2012 Contact information: Jo Vann, TC107 WG3 Anti-counterfeit convenor, CEO- Component Technology , GE Aviation Systems Ltd., T +44 (0)1242 632927 F +44 (0)1242 661151 E jo.vann@ge.com www.ge.com/aviation