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14 December 2018 UNCLASSIFIED of 93

Counterfeit Parts and Materials Prevention Program

Guidebook

Army Materiel Command


Preface.

In 2011, the Senate Armed Services Committee initiated an investigation into counterfeit electronic parts in the Department of Defense (DoD) supply chain. It produced findings of over 1 million potential suspect electronic parts alone. In 2016, the Government Accountability Office (GAO) released a congressional report stating that the DoD needs to improve reporting and oversight to reduce supply chain risk within the DoD. These findings both point to the challenges faced while trying to maintain supply availability within the DoD supply chain.

The long DoD procurement process coupled with a lengthy product sustainment phase creates an increase in both obsolescence and counterfeit risks. In recent years, manufacturers supplying products to Army Materiel Command (AMC) have either closed manufacturing capabilities or moved out of the DoD industrial base sector due to lack of sustainable production. These capability departures create gaps in materials and/or parts. This availability gap greatly increases AMC’s reliance on non-original component manufacturers and non-original equipment manufacturers, thereby increasing risk to sustainability. The availability gap also dramatically increases the probability of counterfeit material in the supply chain. It affects all classes of supply, therefore posing a significant threat to readiness and reliability of our weapon systems, potentially resulting in the inability to provide reliability, availability, and maintainability of our equipment.

In response to this risk, AMC G-3 has developed the AMC Counterfeit Parts and Materials Prevention (CPMP) Program Guidebook which is a tool to strengthen lifecycle protection policies and sustainment programs. This program awareness effort assists in ensuring that supply chains and associated systems are fielded and sustained in a way that reduces the likelihood and consequence of supply chain risks. This document’s design is based on an iterative knowledge management process to enable periodic updating of the information as the counterfeit risk environment evolves. It is imperative that all AMC activities implement a risk-based approach for identifying counterfeit parts and material risks. The communication and reporting of suspect-counterfeit parts and materials is critical to improving our ability to identify the magnitude of risk present, mitigate that risk, and sustain soldier safety and readiness.


Table of Contents

Chapter 1. Purpose, Scope, and Responsibilities ........................................................... 4

Chapter 2. Program Framework ............................................................................................ 7

Chapter 3. Risk Management - Best Practice .................................................................. 11

Chapter 4: Communication and Reporting ...................................................................... 22

Chapter 5. Physical Inspection and Testing .................................................................... 25

Chapter 6 Training .................................................................................................................. 33

Appendix A. Internet Resources and References .......................................................... 36

Appendix B. How to Access Army Materiel Command Standards and Specifications .......................................................................................................................... 44

Appendix C. Indicators of Counterfeit Electronic Parts ............................................... 45

Appendix D. Examples of Counterfeit Electronic Parts ............................................... 49

Appendix E. Indicators of Counterfeit Mechanical Parts and Materials .................. 56

Appendix F. Examples of Counterfeit Mechanical Parts and Materials .................... 59

Appendix G. Parts Management Plan Considerations ................................................. 64

Appendix H. Sample Statement of Work Language ...................................................... 66

Appendix I. Quality Assurance Checklist ......................................................................... 71

Appendix J. Policy on Use of In-House Engineering and Technical Resources ... 77

Appendix K. Source of Supply - Manufacturer and/or Supplier Risk ....................... 79

Appendix L. Risk Identification Methodologies .............................................................. 80

Appendix M. Acronyms ......................................................................................................... 81

Appendix N. Terms ................................................................................................................. 83


Chapter 1. Purpose, Scope, and Responsibilities 1. Purpose. a. Establish processes for identifying and resolving the risks associated with Army Materiel Command’s (AMC) Counterfeit Parts and Materials Prevention (CPMP) Program in accordance with (IAW) Department of Defense Instruction (DODI) Number 4140.67, dated April 26, 2013, Subject: DoD Counterfeit Prevention Policy. b. Document the AMC CPMP Program and assign oversight of the program to Headquarters, U.S. Army Materiel Command (HQ AMC) G-3. c. Define the AMC CPMP Program, identify best practices and procedures, establish objectives, and assign responsibilities for implementing and managing a comprehensive and coordinated program. 2. Scope. a. Headquarters AMC, Life Cycle Management Commands (LCMCs), Major Subordinate Commands (MSCs), and separate reporting activities that have the potential and/or actual risk of counterfeit material/parts entering supply chain operations. b. Any acquisition activity, repair activity, production activity, care of supplies in storage process, or inventory. c. Counterfeit risks encompass all raw materials, components, assemblies, end items, whether foreign or domestic sourced and/or new, refurbished, or reparable. 3. Responsibilities. a. The Commanding General (CG), U.S. Army Materiel Command (AMC) serves as the Army proponent for CPMP Program IAW Army Regulation (AR) 700-90. The CG, AMC designates the AMC G-3 to oversee the management of the Army CPMP Program. b. The AMC G-3 will:

(1) Serve as the Army proponent representative and maintain overall supervisory management of the CPMP Program.

(2) Monitor and support the CPMP program requirements as part of the Industrial Base mission IAW AR 700-90.

(3) Serve as the lead organization to implement and manage the CPMP Program:

(a) Provide guidance for establishing policies and procedures as required.

(b) Develop and provide training to the AMC Enterprise workforce.


(c) Promote a community of practice within the United States Services, DoD Activities, and Government and Non-Government activities for sharing of information in order to identify and share methodologies needed to improve the management, identification, testing, and mitigation of the associated risks of counterfeit parts and materials. Area of responsibilities include, but are not limited to, communications/reporting, prevention, risk management, and supply chain risk management.

(d) Assist in the resolution and resourcing of programmatic issues and counterfeit cases as requested through the AMC chain of command.

(e) Facilitate communication with relevant entities in Training and Doctrine Command (TRADOC), U.S. Army Forces Command (FORSCOM), and other Army elements.

(f) Assist the efforts of all AMC organizations in planning, developing, and executing risk prevention and mitigation solutions.

(g) Support Program/Product/Project Manager (PM) in addressing counterfeit prevention requirements.

(h) Establish a web portal for the provisioning of policy, processes, training, and community of practice. c. Life Cycle Management Commands (LCMC):

(1) Designate CPMP Program Subject Matter Expert/Liaison to implement and manage a CPMP Program IAW DoDI Number 4140.67, AR 70-77, AR 700-90, and Standardization Document (SD)-22.

(2) Develop a mechanism to address all areas of the CPMP Program and coordinate with the Criminal Investigation Command (CID), Program Executive Offices (PEO), PMs, and supporting Research, Development and Engineering Centers (RDEC).

(3) Provide alert notifications, interactions, information exchange, and cooperation within AMC, Army, DoD, other Government organizations, and the private sector as required.

(4) Utilize Product Data Reporting and Evaluation Program (PDREP) and the Government-Industry Data Exchange Program (GIDEP) as the AMC systems of record for all counterfeit actions.

(5) Provide standard operating procedures and training to supply activities, manufacturing arsenals, and repair facilities to ensure compliance with DoDI 4140.67, and this document.

(6) Evaluate program effectiveness to include performance metrics and reporting procedures.


(7) Provide CPMP training and information which promotes awareness and processes in support of an effective CPMP Program, through the utilization of the guidelines provided in Chapter 3.

(8) Create an approved suppliers list in coordination with their Engineering Support Activities and Defense Logistics Agency (DLA), providing a list of Original Equipment Manufacturer/Original Component Manufacturer (OEM/OCM), authorized/franchised distributors, and authorized aftermarket OEM/OCMs for all materials and parts at a high risk for counterfeit or critical to the safety and functionality of the system.

(9) In coordination with their Engineering Support Activities, develop written procedures for handling, segregation, disposal, and data retention of all suspect counterfeit parts and materials at all locations under LCMC jurisdiction. d. U.S. Army Research, Development and Engineering Command – Edgewood Chemical Biological Center – Industrial Base Team (RDCB-DES-I):

(1) Develop and maintain current counterfeit prevention policies, practices, and procedures.

(2) Establish the CPMP Program website.

(3) Develop and establish training requirements for the AMC Workforce.

(4) Serve as the AMC interagency interface for: AMC, DoD, and other Federal agencies on counterfeit prevention initiatives and guidelines. Additional contact information can be found on CPMP Program website. URL: https://ibwebportal.ria.army.mil/CPP.

(5) Promote collaboration and best practice usage of counterfeit prevention focus areas to drive incremental readiness improvements.


Chapter 2. Program Framework 1. Intent. This Guidebook provides guidance and best practices for implementing counterfeit prevention and detection measures throughout AMC. It is intended for use by all AMC organizations involved in designing, procuring, fielding, maintaining, and sustaining components and equipment. 2. Objective. To increase awareness through a structured approach to combat the counterfeit risk/threat which is prevalent in the modern global supply chain. The practices, processes, and procedures explained in this document are taken from various resources including: private industry, government, academia, and published standards and references. The guidebook is designed to provide a framework for preventing counterfeit parts and material from entering the AMC supply chain. 3. Regulatory Framework. DoDI 4140.67, DoD Counterfeit Prevention Policy Requirements. (Figure 1)

a. Establish policy and assign responsibilities necessary to prevent the introduction of

counterfeit material at any level of the DoD supply chain, including special requirements prescribed by Section 818 of Public Law 112-81 (Reference (b)) related to electronic parts.

b. Provide direction for anti-counterfeit measures for DoD weapon and information

systems acquisition and sustainment to prevent the introduction of counterfeit material. c. Assigns responsibilities for prevention, detection, remediation, investigation, and

restitution to defend the DoD against counterfeit material that poses a threat to personnel safety.

Figure 1 – Regulatory Framework


4. Counterfeit Definition. This guidebook uses the definition of counterfeit material found in DoDI 4140.67, which defines counterfeit material as “An item that is an unauthorized copy or substitute that has been identified, marked, or altered by a source other than the item's legally authorized source and has been misrepresented to be an authorized item of the legally authorized source.” This definition encompasses both used/refurbished items being sold as new and items being sold under an intentional misrepresentation of the item’s material and capability. It also includes items that have been modified to add malicious or other unapproved hardware/software, or modifications that would void the OEM/OCM warranty.

5. Readiness Risk. Counterfeit parts and materials may be inferior in quality, nonfunctional, or have the ability to sabotage systems potentially resulting in product failure. Used material, misrepresented as new, leaves the product with a lower mean time before failure than expected when purchasing a new part. Finally, some counterfeit material is a legitimate item, but has had a modification or/and been sabotaged to either cause premature failure or to gather information from the equipment when it is being used in the field. These issues can threaten the safety of the user and success of the mission.

6. Full Lifecycle Scope Risk Mitigation Measures. The counterfeit risk impacts a program’s lifecycle from the concept of design stage to end of useful life exit from the United States Army’s equipment inventory. It is imperative that an organization’s personnel awareness encompasses the entire spectrum of a product’s lifecycle. Figure 2 provides an overview of typical risk management measures which are required to protect a program’s readiness posture. This full lifecycle approach to counterfeit risk management is the foundation for the five overarching areas of best practices.

Figure 2 - Program’s Life Cycle Counterfeit Prevention Measures - Typical


7. Program Requirements. a. Create awareness to prevent procurement of counterfeit material. b. Employ a risk-based approach to reduce the frequency and impact of counterfeit material within DoD acquisition systems and DoD life-cycle sustainment processes by: (1) Applying prevention and early detection procedures to minimize the presence of counterfeit material within the DoD supply chain.

(2) Strengthening the oversight and surveillance procedures for critical material.

c. Document all occurrences of suspect and confirmed counterfeit material in the appropriate reporting systems. d. Make information about counterfeiting accessible at all levels of the AMC supply chain as a method to prevent further counterfeiting. e. Investigate, analyze, and assess all cases of suspected counterfeit material. f. Notify the United States Army criminal investigative organizations, or intelligence authorities, and those who use the suspect and confirmed counterfeit material, of incidents at the earliest opportunity. Seek restitution when cases are confirmed and obtain remedies prescribed by relevant authorities, including DoDI 7050.05 and part 46 of the Federal Acquisition Regulation. g. Align AMC anti-counterfeit processes to support the DoD supply chain goals for: (1) Weapon systems availability. (2) Weapon systems support effectiveness and efficiency. h. Provide AMC workforce with anti-counterfeit education and training. 8. Concept of Operations. a. The AMC CPMP Program is designed to operate in a collaborative work structure. This structural design enables the capture, socialization, and implementation of counterfeit prevention best practices across the AMC Enterprise. b. The AMC CPMP Program is tasked with developing a strategic program which incorporates continuous improvement to ensure the United States Army and AMC readiness objectives are not impacted by counterfeit materials or parts. The CPMP Program is designed to interface internally with LCMCs and RDECs while also interfacing externally with DoD organizations, Federal organizations, and commercial industry.


c. The AMC CPMP Program defines counterfeit awareness and prevention as everyone’s responsibility, since many people potentially come in contact with counterfeit material throughout the lifecycle process. The stakeholders, specifically the PEOs, PMs, LCMCs, and RDECs must ensure that the prevention and mitigation techniques are fully socialized and the knowledge base is refreshed in order to combat the counterfeit risk. It is each organization’s responsibility to ensure its processes, techniques, and practices include counterfeit prevention. d. CPMP Integrated Project Team (IPT) serves as the governing body for this program with the following objectives: (1) Develop new counterfeit prevention processes and techniques. (2) Research and evaluate counterfeit prevention practices, tools, and resources. (3) Conduct periodic learning roundtables with external organizations. (4) Maintain the AMC CPMP Program Guidebook. e. Program Foundation Blocks.

(1) Best Practices. The intent of the best practices is to implement, sustain, and continuously improve CPMP operations and processes.

(2) Knowledge Management. Capturing and mapping counterfeit prevention

knowledge assets and sources, then disseminating the information within the CPMP Program IPT to uncover important insights and ideas. The end state is the development of expertise: the ability to leverage knowledge strategically, mitigate risk, and make useful connections between seemingly unrelated assets or undeveloped counterfeit prevention sources to improve the CPMP Program.

(3) Communication and Reporting. Ensures communication of risk and provides

trend analysis of industrial sectors which are at risk. This block is both internal and external.

(4) Physical Testing. Verification of counterfeit components and methodologies

used to infiltrate the AMC supply chain.

(5) Training/Learning Organization. Three broad factors are applied to achieve organizational learning and adaptability in support of the AMC CPMP Program. These factors cover: A supportive learning environment; concrete learning processes and practices (Program of Instruction), and CPMP Program leadership behavior that provides reinforcement.


Chapter 3. Risk Management - Best Practice 1. Introduction. The purpose of this chapter is to provide direction for the traceability and detection of counterfeit material across the product acquisition lifecycle. The direction focuses on known processes and techniques to mitigate counterfeit risks based on the product’s lifecycle phase. This chapter also details the best practices for counterfeit mitigation. 2. Types of Counterfeit. Counterfeit material poses a significant risk to the supply chain, potentially resulting in loss of material, mission, or life. Counterfeit material refers to items that are unauthorized copies or substitutes that have been identified, marked, or altered by a source other than the items’ legally authorized manufacturer or have been misrepresented to be authorized items of the legally authorized manufacturer. Examples include but are not limited to:

a. Used material sold as new.

b. Material represented as having specific capability (e.g., speed, power, temperature, capacity) beyond the part specifications by the OEM/OCM.

c. Material construction (e.g., anodization, composition) other than the material’s

advertised construction. d. Material containing additional features or capabilities not intended by the

OEM/OCM (e.g., added malicious functions, modified firmware, etc.). 3. Risk Areas. All material is at risk to be counterfeited, yet research has shown that for DoD purposes, components which are experiencing Diminishing Manufacturing Sources and Material Shortages (DMSMS) risk exhibit a higher likelihood of being counterfeited. There are several factors that make an item a probable target of counterfeit: a. Obsolescence. Obsolete material is no longer available from trustworthy suppliers such as the original manufacturer or an authorized supplier. If the material is still in demand, the selling price may increase significantly, enough to justify counterfeiting. b. Difficult to Procure. Some material may present procurement challenges such as special waivers, rare materials, environmental concerns, etc. Falsified documentation may allow noncompliant material to be sold fraudulently.

c. Procurement Lead Time. Counterfeiters can often provide very short lead times for material, making the material a more attractive option when schedule is critical. d. Multiple Versions. Material with multiple compatible versions can be misrepresented for profit. An example might be a common bolt or washer that is available in several different plating or heat treatment versions, or an integrated circuit


with commercial, industrial, and military temperature ranges. In these cases, lower-quality or lesser parts can be sold for a higher price. e. Item Type. Certain categories of items are identified as counterfeit more often than others. A 2012 DLA assessment of counterfeit risk within DLA’s supply chain covered sixty-nine Federal Supply Groups (FSGs) managed by DLA. The five FSGs at the highest risk of counterfeit were:

(1) FSG 59 – Electrical and electronic equipment components, such as: integrated circuits, transistors, diodes, connectors, and electronic assemblies.

(2) FSG 29 – Engine accessories, such as: filters, valves, and pumps. (3) FSG 47 – Pipe, tubing, hose, and fittings.

(4) FSG 53 – Hardware and abrasives, such as: nuts, bolts, washers, screws, brackets, seals, o-rings, lubricants, and abrasives. (5) FSG 25 – Vehicular equipment components, such as brakes and springs.

f. Price and Volume. Counterfeiters are much more likely to deal in material where a significant profit can be gained, either through a high purchase price or through large volume sales. High sale price items are targeted and listed at a discount to lure customers seeking lower purchase costs. Counterfeiters will often target material that is available in multiple quality levels, procuring low cost commercial items that can be remarked and sold at a higher price as industrial, automotive, or military material. g. Common Commercial Material. Items commonly used in commercial applications are more likely to exist in high volume as electronic waste or e-waste. This is product that has been used in prior application, but has been reclaimed and refurbished. It may be resold as new product, although the material’s reliability has likely been affected. h. Malicious Intent and/or Strategic Value. Material that presents specific strategic opportunity to an adversary may make for an attractive counterfeit target. 4. Manufacturer and Supplier Assessment. See Appendices I and K for assessment checklist and manufacturer/supplier risk levels. 5. Supply Chains.

a. The global commercial supply chain. This is the source of most microelectronic components. It feeds the DoD acquisition and sustainment supply chains and is the most accessible for malicious insertion. As a result of the complex interactions between suppliers (and because defense is a small fraction of the total market), it is difficult to predict which specific parts of this supply chain will ultimately be placed into a weapons system. This lack of predictability makes it difficult to achieve precision effects on weapon systems through malicious insertions into the global commercial supply chain.


b. The DoD acquisition supply chain. This is the supply chain carefully designed by the prime contractor to support weapons-system development and production. It is difficult for an attacker to gain access to this supply chain for malicious insertion. However, if access can be attained, the attacker will acquire the understanding of the part’s placement in the weapon system, leading to a successful attack that can create precise and impactful effects. c. The DoD sustainment supply chain. This supply chain evolves during the weapon system’s lifecycle due to obsolescence issues. Often, later in the lifecycle, obsolescence issues will force the DoD to look outside of the original approved suppliers, to unapproved aftermarket suppliers who are often subject to less programmatic oversight. Microelectronic parts obsolescence is a major factor in driving toward new sources of supply for necessary parts to sustain the system. The continued discovery of counterfeit parts in the DoD supply system is proof that criminal activity (with less sophistication than a nation state adversary) can succeed in penetrating supply chains (GAO-16-236: Published: Feb 16, 2016). Parts originating in sustainment are harder to track than in acquisition, and there are opportunities for an attacker to gain access. Furthermore, if the attacker has an understanding of a part’s placement in a weapon system, a successful malicious insertion attack can create precise and impactful results. Therefore, the DoD sustainment supply chain is the most accessible target for sophisticated adversaries who desire to achieve both access and precision effects. d. Cyber Supply Chains. Insertion of a malicious microelectronic vulnerability via the supply chain can occur at any time during the production and fielding of a weapon system or during sustainment of the fielded system. When targeting the microelectronics supply chain for a weapon system, an attacker will consider: (1) Access. Can the attacker create opportunities, or leverage existing opportunities, to place malicious hardware or software into the weapons system? (2) Precision Effects. To what extent can the malicious insertion be relied upon to affect the weapon system’s performance, preferably in a predictable and controllable way? (3) Attacker Process. No matter where an attack occurs in the lifecycle of the system, an attacker seeking to exploit a maliciously inserted vulnerability must execute each step in the kill chain:

(a) Intelligence and planning. Gathering information on target system and suppliers to develop supply chain attack vector.

(b) Design and create. Developing malicious hardware and/or software or

vulnerability exploits for insertion into target supply chain. This may be done in an attacker-owned facility or by an insider in a legitimate facility.


(c) Insert. Incorporating malicious hardware or software into target system through its supply chain.

(d) Achieve effect. Actuating and operating malicious hardware or software

to achieve an effect. e. Cyber Supply Chain Risk Management (C-SCRM) is the process of identifying, assessing, and mitigating the risks associated with the distributed and interconnected nature of IT/OT (Information Technology/Operational Technology) product and service supply chains. It covers the entire life cycle of a system (including design, development, distribution, deployment, acquisition, maintenance, and destruction) as supply chain threats and vulnerabilities may intentionally or unintentionally compromise an IT/OT product or service at any stage. 6. Life Cycle Management Best Practices.

a. Pre-Milestone A. Material Solution Analysis Phase (Concept Development before milestone A).

(1) The potential industrial sectors of the technology should be evaluated to identify current risks trends and identify potential bad actors concerning sources of potential technology being considered for design into the material solution. The “Open Source” website - https://www.opensource.gov/, and other supply, risk management, intelligence, and historical databases can be utilized to identify potential risk factors. The initial risk assessment is broad in scope to determine areas of risks for potential technology, industrial, and material sectors and associated supply chains. The assessment must incorporate operational security, supply chain risk management, cause and effect of risks, and any critical technology that is incorporated into the program of record. For example: there should be an overall system technology counterfeit risk assessment performed on all critical technology/components which have a high probability of being sourced from nations which have displayed counterfeit trends and/or identified as a source of counterfeit. The system technology counterfeit risk assessment should determine the probability of the proposed technology being counterfeited as well as the potential impact this would have on the overall system by incorporating assessment of:

(a) Current shortfalls in the trusted industry sectors

(b) Percent of first time sources of supply

(c) Dependence on sources which could experience a shift in social economic posture

(d) Sources in countries which are labeled less than favored nation status

https://www.opensource.gov/


b. Milestone A: Technology Maturation and Risk Reduction. (1) Risks. The risks of counterfeiting need to be considered during the activities of the Preliminary Design Review before Milestone B. The design should be evaluated to determine the associated risks of every component based on material and function. This roadmap of components should be recorded as part of the Parts Management Plan. (2) Protection Plan. Program Protection Plan Evaluation Criteria, Version 1.1, Section 5 Threats, Vulnerabilities, and Countermeasures sections contain a description of the plan (or references Counterfeit Prevention Plan) to prevent microelectronic counterfeits (of any kind) in critical components when items are not obtained from the original equipment manufacturer, original component manufacturer or from an authorized distributor. (3) Material. When determining the best material to be used, the long term availability of the material needs to be considered. This includes both the finished material and any intermediate inputs. The long term availability is determined by the stability of the supply chain for internal and external forces. The stability of the region where material is produced should be considered as more volatile regions could face extra challenges in the delivery of material. Insufficient access to intermediate inputs to the process such as lack of qualified personnel in the region can also affect the supply chain. The financial health of the manufacturer can be a factor; a manufacturer will not continue to produce the material without continued demand or if more financially lucrative products can be produced instead. This becomes crucial to parts that contain sole sourced materials. (4) Part Criticality. The function of the part is tied into the criticality. If a part is more critical to the process any unexpected failure could have catastrophic consequences to the success of the mission. Parts that have a critical role in the function should be carefully examined for any potential sources of counterfeit. If a high possibility of counterfeit is suspected, the part should be reviewed for potential redesign opportunities when practical. (5) Likelihood. Although any part that can be counterfeited may be counterfeit, there are certain factors that increase the likelihood of a part to be counterfeited:

(a) Obsolescence. If the part is no longer profitable for the manufacturer to produce, they may eliminate the supply chain

(b) Large Orders. Parts sold in large supply are a target for unauthorized

suppliers with cheap goods. These may be components that have been recycled, inferior, or misrepresented.

(c) Type of Component. Counterfeit is common in electronic components that

are often recycled from electronic waste. It is also regularly seen in engine accessories, pipe and tubing, and hardware and abrasives, but is possible in any component.


(6) Consequences. The likelihood of counterfeiting occurring should be considered closely with the impact of the occurrence. Parts with more risk factors are at a higher likelihood of being counterfeit, but all parts have the potential to be counterfeit. All parts should be evaluated to determine what the likelihood of counterfeit would be and the potential consequence. Counterfeit parts are unlikely to be caught in initial material testing and often fail unexpectedly before the predicted time of failure. Parts that fail before expected can result in the failure of critical mission functions or endanger the health of personnel.

c. Milestone B. Engineering and Manufacturing Development. (1) The primary contractor or OEM/OCM directly supplying any parts or materials to the United States Government should have a demonstrated system of quality that includes a documented plan to reduce the potential for counterfeit entering into their supply chain. The contractor should have a system of traceability for all components that pass through from suppliers and secondary contractors. Secondary contractors and suppliers should also maintain quality systems and documentation for all parts and a list of approved suppliers should be maintained by the contractors. Additionally they should have an inventory management system and a set measure of quality for all parts based on an explicit checklist of specifications provided by the acquisition personnel. Documentation for all processes and parts is critical for both the primary contractors and any secondary contractors. The manufacturer’s personnel should have training to spot counterfeit within the supply chain and have documented procedures for reporting suspected items.

d. Milestone C. Production, Deployment, and Sustainment.

(1) Obsolescence. The system PM should oversee the development of a comprehensive Diminishing Manufacturing Sources and Material Shortages (DMSMS) plan to help counter the effects of obsolescence in the supply chain. This plan should include where parts are intended to be purchased from as the part becomes obsolete. (2) Authorized Suppliers. Parts should be purchased from the OEM/OCM to all extent possible. In cases where this is not possible, parts should be purchased from an authorized supply chain. Authorized aftermarket suppliers have agreements with the OEM/OCM and have the rights from the OEM/OCM to sell the parts. All elements in an authorized supply chain receive parts only from the OEM/OCM or an authorized supplier. This reduces the risk of counterfeit by ensuring authentic parts are used. (3) Unauthorized Suppliers. Purchasing through authorized supply chains becomes more difficult as the part becomes obsolete. The OEM/OCM and any authorized suppliers may have left the market, with parts only available through unauthorized suppliers. Before a part is acquired from the unauthorized supplier, the part should be evaluated for the potential of replacing the obsolete material with new material from an authorized supplier, or redesigning the part to remove the obsolete material altogether. If this is not possible, then the intended unauthorized supplier should be evaluated rigorously for compliance with standards and risk of counterfeit


material. Unauthorized suppliers should be inspected on site for counterfeit risk mitigation procedures. The unauthorized supplier should have documentation of their approved suppliers and justification concerning why their suppliers are a low risk. All parts from the unauthorized supplier should be inspected upon delivery. After initial visual inspection, parts should be tested and may be sent to an independent testing lab for further investigation. See chapter 5, “Physical Inspection and Testing”, for more information and recommended SAE documents to apply when testing parts and materials. A part that is non-conforming is not necessarily suspect counterfeit without further evaluation. The non-conforming or suspect shipment should be removed entirely from the supply chain and placed in a secure area. Suspect parts should not be sent back to the supplier to avoid the parts re-entering the supply chain or being sold to another customer. The suspect parts should be communicated to supervisors and recorded in GIDEP/PDREP. (4) Procurement Planning for Lead-time. The procurement planning process must address long lead times that are common for many part commodities, and especially for many electronic part classes that can approach 52 weeks for commercial off-the-shelf parts. Proper planning can assure availability through authorized suppliers.

e. End of Service Life. When a part or component has been used to the end of its useful life, its service life is reached and it is critical that proper component disposal occurs. Parts need to be taken to the proper disposal authorities and damaged beyond all function. This is to ensure the parts are not recycled back into the supply chain. Any specialized equipment for creation of parts should also be properly disposed. 7. Best Practices Categorized.

a. Acquisition Contracting Requirements.

(1) Utilize DFARS 246.870, 252.246-7007, 252.246-7008 and DoDI 4140.67, to provide acquisition contract requirements pertaining to counterfeit prevention. (2) Require the prime contractor to flow down DMSMS management requirements to include Engineering Bill of Materials (BOMs)/parts lists to their subcontractors to minimize obsolescence issues throughout the contract period.

(3) Include Contract Data Requirement List (CDRL) and Data Item Description (DID) as required to mitigate counterfeit risk while ensuring compliance with all applicable Defense Federal Acquisition Regulation Supplement (DFARS) provisions, DoD, ARs, and DMSMS requirements pertaining to the risk of acquiring counterfeit parts. A counterfeit prevention plan that addresses the requirements of SAE AS5553 and SAE AS6174 should be required with Government approval.

(4) Life Cycle Sustainment Plan (LCSP) Outline Version 2.0. Obsolescence and counterfeit risk management process, and controls should be incorporated into a program’s LCSP 2.0, Chapter 3 Product Support Strategy.


(5) Perform periodic obsolescence/counterfeit risk management review on current programs of record and sustainment programs in order to proactively implement obsolescence risk mitigation best practices and reduce counterfeit risk.

(6) Require AMC organizations, when possible, to procure from OEM/OCM, authorized/franchised distributors, or from aftermarket manufacturers authorized by the OEM/OCM. (7) In scenarios where a part is not available from the OEM/OCM, authorized/franchised distributors, or an authorized aftermarket manufacturer, require that purchase be made from a supplier on the LCMC-controlled approved supplier list or manufactured at a United States Army or Services Arsenal/Facility.

(8) Prior to placing a purchase order with a non-authorized supplier, the buyer should check both the GIDEP and PDREP databases to confirm that the proposed supplier has not previously supplied counterfeit parts.

(9) For higher risk components and items critical to the safety of the user that are available only from unapproved/unproven sources, perform risk assessments and develop a testing plan that mitigates the likelihood of acquiring counterfeit items and the resulting likely impact on Army readiness. Additional specific inspection and testing practices are provided in SAE Standards AS 5553, AS 6081, AS 6171/1, AS 6171A, and AS 6174, and IDEA-STD-1010. (See Appendix A). (10) Review and evaluate alternative procurement options such as:

(a) Long-term buy (b) Lifetime buy possibilities (c) Bridge buy (d) Organic industrial base design and manufacturing (e) Reverse Engineering for key components at risk of

obsolescence/counterfeiting

b. Supply Chain Accountability. (1) Traceability. Any unauthorized supplier of parts, components, and materials, not previously approved by the Government, should provide with the parts a Certificate of Conformance showing traceability to all the supply chain intermediaries, from the actual manufacturer to the ultimate supplier.


(2) Ordering Procedures. (a) Whenever possible, all material and parts should be ordered through approved government systems to reduce the risk for counterfeit. In example: Logistics Modernization Program (LMP), General Services Administration, or Government contracting mechanism. The use of credit card purchases from an unproven source adds considerable risk to United States Army supply chain, therefore will be used as a last resort. (b) Long lead time items can cause delays in system readiness, and often cause DoD supply chain members to look to non-authorized suppliers who can provide a shorter lead time. This significantly increases the risk of counterfeit entering the supply chain. Therefore, material and parts should be proactively managed and ordered using supply chain best practices to minimize unexpected delays due to long lead times.

(3) Counterfeit Electronic and Non-Electronics Parts Control Plan. All AMC organizations should develop and implement a counterfeit parts control plan that documents processes used for counterfeit prevention, risk mitigation, disposition, and reporting of suspect counterfeit parts and confirmed counterfeit parts. A Parts Management Development Guide that provides general guidance and considerations can be found in MIL-STD 3018 Appendix B. Guidance for developing an Electronic Components Management Plan is available in SAE EIA-STD-4899. (4) Material Control. All suspect counterfeit parts should be strictly controlled and not disposed of until provided guidance by United States Army Legal authority. (5) Inspection.

(a) All purchased parts and materials should be inspected upon receipt for any visual indications of possible counterfeit issues. Suppliers in the supply chain of suspected counterfeit parts are to be reported in GIDEP and PDREP. The reports should include inspection and/or test results substantiating the determination of suspect counterfeit.

(b) Inspect and test any other parts received from the suspected supplier,

and any parts within the same lot of material received from any other suppliers. Dispose of quarantined, suspected counterfeit parts as directed by the Legal or Contracting organizations with proper disposition codes per DoDM 4160.28.

c. Knowledge Management.

(1) Guidance. Establish counterfeit prevention guidance in AMC policies, regulations, standing operating procedures (SOPs), and work instructions. (2) Web Portal. Establish the Counterfeit Prevention Web Portal, https://ibwebportal.ria.army.mil/CPP.


(3) Subject Matter Experts. Identify CPMP Program subject matter experts (SMEs) in each of the acquisition, supply chain management, receiving, inspection, testing, and sustainment functions. Establish Subject Matter Expertise at the program offices and in each LCMC and RDEC. (4) Roundtables. Collaboratively execute semi-annual Commercial Industry – Science and Technology – Government Roundtables to continuously improve counterfeit risk prevention methodologies and strengthen AMC’s Counterfeit Risk Management posture. Roundtables should focus on processes, market trends, testing methodologies, training methods, and communications. (5) Guidance. Provide assistance and guidance to AMC, United States Services, Defense Logistics Agency, and Federal Agencies concerning counterfeit risk management, and planning to prevent and mitigate counterfeit issues. (6) Training. Provide periodic counterfeit risk management training to support AMC enterprise readiness. Counterfeit awareness and prevention training will be available in person and computer based. Train CPMP Program Point of Contacts to be trained in program procedures and tools for identifying and reporting counterfeit material review.

d. Testing.

(1) Test Plans. Develop and establish a test plan for material procured from unauthorized suppliers and for all High-Risk and Critical-Safety material. (2) Material Segregation. All AMC Facilities will document with written instructions on how suspect material will be segregated and stored during inspection and testing, as well as how test results will be recorded. A template provided on the AMC Counterfeit webpage lists the documentation and contents necessary for the segregated storage and testing. The template can be accessed and downloaded from the CPMP website: https://ibwebportal.ria.army.mil/CPP. (3) Testing Facilities. Use Government test facilities first for authentication testing, and commercial testing facilities second. Additional information on testing centers and prototype integration facilities can be found on the CPMP Program website. All testing facilities must meet the following criteria:

(a) ISO certified or recognized independent certification

(b) Employs best laboratory practices and processes

(c) Validated test plan and methodology for parts to be tested

(d) Proven and positive performance history

(e) Evidence of calibrated test equipment

(f) Defense Land and Maritime Lab Suitability Listing or facility validation


(4) Quarantine Material. Quarantined by the organization in accordance with established policies and procedures and notification of GIDEP, where appropriate. (5) Authenticity Validation. If the parts pass initial inspection, they are then tested to validate their authenticity. Testing should include, as appropriate, electrical, software, and mechanical attributes in order to establish the authenticity of the part. (6) Documentation. Documented with records to include identity of the manufacturer, all suppliers in the supply chain, and inspection and testing results.

e. Communications and Reporting. (1) Utilize Counterfeit Prevention Web Portal.

(a) Serve as the AMC CPMP Program information hub for all counterfeit

prevention concerns

(b) Capture lessons learned

(c) Serve as a repository for processes, techniques, and best practice guidance

(d) Provide a centralized location for standardized guidance and criteria

(e) Develop and implement continuous improvement initiatives through the AMC Counterfeit Working Group, and external agencies

(2) Utilization of GIDEP and PDREP. Additional detail for GIDEP and PDREP can be found in Chapter 4, as well as on the Counterfeit Prevention Web Portal.

(3) Notify the AMC Chain of Command and General Counsel’s Office of the suspected counterfeit part acquisition, for their investigation and possible criminal prosecution for fraud.

(4) Notify the Contracting Officer, Contracting Officer Representative, or Purchasing Department, as applicable, of the suspected counterfeit part acquisition.

(5) Notify the Program Executive Office (Life Cycle Manager) and/or other acquisition organization of the suspected counterfeit part acquisition. (6) Notify the United States Army Criminal Investigation Command (CID) of the suspected counterfeit part acquisition. To report allegations of contract fraud including false claims, bribery, corruption, kickbacks, and false statements, call 1-844-ARMY-CID (844-276-9243) or email CID at [email protected] to reach the U.S. Army Criminal Investigation Command's Major Procurement Fraud Unit. In Southwest Asia you can call CID toll free at 877 363-3348 or via DSN 664-1151.


Chapter 4: Communication and Reporting 1. Purpose. Provides direction on the proper methods of communication and reporting of suspect counterfeit parts and material. To provide a standardized methodology and process that can be used across the AMC Enterprise for reporting both suspected counterfeit, and confirmed counterfeit material. 2. Scope. This chapter provides direction on both preventative and alerting communications, as well as how the CPMP Program website can be used jointly across AMC, and eventually the entire Army and DoD, as a supplemental tool to assist with counterfeit prevention and mitigation. 3. Communication Systems. a. System of Record. PDREP is the AMC Reporting System of Record. This Department of the Navy program supports requirements regarding the reporting, collection, and use of supplier performance information. PDREP is a best practice DoD data repository for supplier data which promotes continuous process improvement for increased material readiness and decreased deficiency issues, providing an overall cost savings to DoD. b. Interface System. GIDEP is the current information management system used across the entire DoD to communicate and document counterfeit activity. GIDEP is a cooperative activity between government and industry participants seeking to share essential technical information during the research, design, development, production, and operational life cycle phases of material. The system enables the CPMP Program Community to reduce risk through:

(1) Research of historical records.

(2) Recording on non-conformance data.

(3) Recording of suspect counterfeit reports which are cataloged in non-conformances under the Failure Experience Data (FED).

(4) Interface with commercial industry and government partners. c. Counterfeit Prevention Portal. https://ibwebportal.ria.army.mil/CPP (1) Counterfeit infiltration capabilities will continue to evolve, therefore requiring iterative and improved solutions to prevent counterfeit parts from entering the AMC supply chain. In order to confront this change, a counterfeit prevention website has been created to consolidate counterfeit prevention guidance, training, alerts, reporting, subject matter experts, and mitigation resources. The website is available to all CAC-enabled DoD members. Non-CAC users may use the “Contact Us” feature on the homepage of the website to request specific information and provide recommendations.


(2) The website includes policy and guidance documents, online training, suspect counterfeit notices from GIDEP and PDREP, contact information for subject matter experts across the DoD, and links to additional counterfeit prevention and mitigation resources. 4. Potential Commercial Data Tools. There are numerous commercial tools for research, predictive analysis, logistics, bill of materials analysis, and configuration management. The CPMP Program does not recommend a specific commercial tool due to the tool’s limitations and available Government owned information systems. 5. Process Map. The process for identifying and reporting suspect counterfeit material is shown in Figure 3. This process map is for a part or material that is received by an AMC Arsenal or Depot, but the process can be followed at any AMC location receiving material.

Accepted Inventory

Non-Conforming

Suspect Counterfeit

Is Item Potentially

Counterfeit?

Add to Inventory

Contract Officer to Return to SenderNo

Inspect/Test Item for Counterfeit

Tests Confirm Item is Suspect

Counterfeit?No Was Item Non-

Conforming?

Yes

NoYes

Receiving/Inspection and Required initial

Testing

Complete and Submit PDREP form A5S and GIDEP Alert

Yes

Figure 3 - Process for Identifying and Reporting Suspect Counterfeit Material


6. Communication Information System Access – Additional Government Tools.

a. DFARS 246.870 Requires Contractors to Report Counterfeit Electronic Part Detection.

(1) Becomes aware of the counterfeit electronic parts or suspect counterfeit electronic parts through inspection, testing, and authentication efforts of the contractor or its subcontractors; through a GIDEP alert; or by other means.

(2) Provides timely (i.e., within 60 days after the contractor becomes aware) written notice to the cognizant contracting officer(s); and GIDEP (unless the contractor is a foreign corporation or partnership that does not have an office, place of business, or fiscal paying agent in the United States; or the counterfeit electronic part or suspect counterfeit electronic part is the subject of an on-going criminal investigation). b. Aviation Missile Research Development Engineering Center (AMRDEC) Multifunctional Obsolescence Resolution Environment (MORE). MORE is an engineering analytical tool, owned and developed by AMRDEC. It is documented as the AMC obsolescence management environment of record for electronics. The information system provides the ability to remain independent of commercial obsolescence management tools. It has increased product availability accuracy through supplemental human research by comparison of multiple tool information and has unique features not found in the commercial tool market. MORE contains over 10 years of past Army product availability research, and is used to manage electronic parts availability data, analysis results, discontinuance alerts, problem cases and critical thinking results in a single enterprise. c. System for Award Management. The review of unauthorized sources should include information from government System for Award Management (SAM) (http://www.sam.gov) to assess procurement risk and eligibility status.

d. Defense Microelectronics Activity (DMEA) Trusted Foundry Program – Accredited Suppliers. DMEA is the program manager for the DoD Trusted Foundry program. The program provides a cost-effective means to assure the integrity and confidentiality of integrated circuits during design and manufacturing while providing the US Government with access to leading edge microelectronics technologies for both Trusted and non-sensitive applications. The accredited suppliers list can and will change over time. For the most current accredited list, only the online DMEA list is valid. https://www.dmea.osd.mil/otherdocs/AccreditedSuppliers.pdf

http://www.sam.gov/

https://www.dmea.osd.mil/otherdocs/AccreditedSuppliers.pdf


Chapter 5. Physical Inspection and Testing 1. Purpose. Provide an overview of physical inspection processes which are first line of risk management in the prevention of counterfeit parts and materials. 2. Scope. This chapter focuses on electrical parts, mechanical parts, and raw materials. 3. Objective. To provide awareness in the acceptance direction on when to conduct testing for suspect counterfeit material, what types of testing to conduct, and how to contain the suspect material. 4. Constraint. Counterfeit detection techniques cannot guarantee material authenticity. The SAE standards AS5553, AS6081, and AS6171 provide a suite of tests which can be used to detect counterfeit electronic parts. These tests were developed for a fairly wide range of detectability. In cases of highly critical electronic parts or parts at higher risk of malicious counterfeiting, additional tests may be warranted, such as functional electrical test or comparative analysis of basic electrical responses. During the inspection process, it is not uncommon for minor counterfeit indicators to be identified. The distinction between ‘counterfeit’ and ‘authentic’ is sometimes not obvious, as minor indicators, such as documentation errors or scratches and other marks, can be present in authentic material. Typically, item obsolescence results in the injection of high-risk suppliers, therefore the material is more likely to have been stored for a longer period than material still in production, and may have changed hands several times. These handling and storage processes increase the likelihood the material is no longer in OEM/OCM condition. 5. Critical safety items. All catastrophic, critical risk, and critical safety items should be thoroughly inspected and tested, regardless of supply source. See SAE AS 6171/1 (Tables 14 and 15), SAE AS 6171A (Tables 2 and 3) and SAE AS 9017 for additional inspection information on these three item categories. 6. Checkpoints

a. Documentation inspection.

b. Material visual inspection.

c. Testing. 7. Documentation Inspection. The initial checkpoint in the identification of counterfeit material is the inspection of all paperwork (including packaging and part labels) that accompanies the shipment. With counterfeit parts and materials, the documentation is often forged, and should be examined upon arrival for inconsistency between the purchase order and provided documentation. Depending on the material, the documentation should provide:


a. Certificate of conformance.

b. Shipment origin location.

c. Special testing or screening certification.

d. Manufacturer or Supplier performed testing – assurance.

e. Supply chain management/Inventory data such as: date codes, lot codes, quantity, etc.

f. Inspection focuses on missing or suspicious items such as: misspelled words, inaccurate logos, inaccurate bar codes, poor grammar, etc.

g. Typical identification of risk types. (1) Altered documents.

(2) Excessively faded or unclear or missing data.

(3) Uneven/inconsistent type style, size or pitch change.

(4) Data on a single line is located at different heights.

(5) Cut and paste appearance of paperwork.

(6) Mixed content such as typed and hand written.

(7) Corrections are not properly lined-out, initialed and dated.

(8) Document data is not legible, mismatched, or/and missing.

h. Certification.

(1) Technical data is inconsistent.

(2) Certification/test results which are identical, some variation should be

expected.

(3) Certificate of conformance and testing is not delivered as required.

(4) No item traceability. 8. Item/Material Inspection. Some indicators provide a high level of confidence that the material may be counterfeit (e.g., mixed internal designs in the same package, non-magnetic materials attracted to a magnet), while other indicators (smudged markings,


chips and scratches) might be a result of processing, handling, or other processes which can be, but are not always, counterfeit indicators. 9. Counterfeit Material Detection. The testing required to detect counterfeit mechanical parts and materials is dependent on the critical properties of the part or material. Standards and engineering drawings should be referenced to determine applicable tests for a given material. 10. Detection Methods for Assemblies. Entire electronic assembles and commercial items can also be susceptible to counterfeiting. Many overall visual inspection indicators (documentation, labeling, markings, etc.) apply to assemblies. “Gold Model” (known good assembly) comparison or input from the OEM/OCM is very beneficial. All equipment/items should contain marking such as serial numbers that can be verified by the OEM/OCM. Another technique is to disassemble the item into its subcomponents and apply standard counterfeit inspection tests on the individual components of the assembly.

a. Verification, if possible, that the manufacturing dates of the subcomponents were prior to the manufacturing date of the assembly.

b. Firmware that may be part of an assembly should be verified to ensure that the correct version is installed on the assembly. 11. Joint Federated Assurance Center. Software and Hardware Assurance JFAC is a federation of Department of Defense (DoD) organizations that promotes and enables software (SwA) and hardware (HwA) assurance. JFAC member organizations and their technical service providers interact with program offices and other interested parties to provide SwA/HwA expertise and support, to include vulnerability assessment, detection, analysis, and remediation services, information about emerging threats and capabilities, software and hardware assessment tools and services, and best practices. The initiatives objectives are:

a. Support program offices by identifying and facilitating access to DoD SwA and HwA expertise and capabilities to reduce vulnerabilities in fielded DoD systems.

b. Assess capability gaps over time and recommend plans to close gaps.

c. Develop recommendations for initiatives in support of the DoD R&D strategy to innovate vulnerability analysis, testing, and protection tools for SwA and HwA.

d. Serve as the DoD point of contact for SwA and HwA interdepartmental and interagency efforts.

e. Develop and sustain a Department inventory of SwA and HwA resources, including tool licenses.


f. JFAC SwA and HwA providers along with other resources can be accessed at https://jfac.navy.mil/JFAC. 12. Electronic Parts Detection. The most counterfeited electronic parts are active (semiconductor) parts. This includes all memory-related components. The most often counterfeited electronic parts are integrated circuit chips. Functional testing is a valid method for counterfeit testing, but should not be the only testing conducted. While functional testing will show if an item will operate, it does not detect whether that item is new or used. Most counterfeit electronic parts will have the same electronics design and functionality as authentic parts, but the expected life cycle may be vastly different. DFARS 246.870 directs the use of industry standards in the inspection and test of electronic parts that were purchased from unauthorized suppliers. See SAE AS5553, AS6174, and AS6171 as additional sources of information for potential inspections and tests to assess parts from unauthorized sources.

13. Defense Logistics Agency (DLA). a. Electronic Parts. The DLA authenticates certain high-risk parts. This part population encompasses Federal Stock Class (FSC) category 5962 (Electronic Microcircuits). DLA’s process provides marking of all parts with a deoxyribonucleic acid (DNA)-based ink which fluoresces under examination by ultraviolet light. This marking signifies the parts were bought from an authorized supplier, or adequate authentication analysis has been performed. All electronic microcircuit parts purchased from DLA should be checked to ensure the DLA ink marking is present. DLA recommends inspecting to package requirements, and completing a 100% visual inspection, per SAE AS6081. Failure to detect this ink might be an indicator the parts were procured by DLA before enactment of this marking, and that these parts should be authenticated if DLA purchased them from outside the authorized supply chain.

b. DLA maintains a Qualified Suppliers List for Distributors (QSLD). This listing, which includes authorized and unauthorized suppliers, verifies distributors have a Quality Management System (QMS) in place to minimize counterfeit risk for electronic parts in FSC 5961 (semiconductor devices and associated hardware) and 5962 (microcircuits, electronic). DLA has QSLD listings for other material as well, including mechanical parts.

c. DLA also maintains a Qualified Testing Suppliers List (QTSL) which establishes QMS and inspection/test requirements for FSC 5961 and 5962 electronic parts. The authentication requirements are based on SAE AS6081. The QSLD and QTSL listings form a core part of DLA’s counterfeit mitigation efforts. 14. Inventory Management. A considerable risk is present for material which was purchased before there was significant awareness of counterfeit risk. There is the potential that some of this material was purchased from unauthorized suppliers, and placed into the stockroom with no authentication performed. It is important to maintain stock control/traceability in stocks in order to attempt to identify and authenticate older material and items.

https://jfac.navy.mil/JFAC


a. Focus on critical safety items to determine the criticality of this material to the end

use application.

b. High risk commodities such as electronics.

c. Identify which of the purchased material is at high risk for being counterfeited.

d. Develop an authentication plan, or method for the authentication of high-risk critical material procured from high-risk suppliers. For examples, see SAE ARP 6328, p. 11, para. 3.2.1.2.1(i); p 17, para. 3.4.3.1; and SAE AS 6081, p. 16, para. 4.2.6. 15. Suspect Counterfeit Determination. a. Since there are numerous variables in identifying counterfeit parts, care should be taken to perform enough authentication work to determine authenticity with a reasonable level of confidence. Two initial steps that should occur when reviewing for authenticity are identifying multiple suspect counterfeit indicators and obtaining information from the OEM/OCM to support the suspicion that the part is counterfeit.

(1) Appendices C and E list many of these indicators, along with a minor, moderate, or major significance:

(a) Minor indicator - Sign of processing, quality, or handling which might not be related to counterfeiting

(b) Moderate indicator - Definite cause of suspicion for the part’s authenticity

(c) Major indicator - strong risk that the part has been modified and qualifies as counterfeit

b. Using the above as indicators for determination, a threshold for reporting material to PDREP and GIDEP as suspect counterfeit would occur if any one of the following conditions is present:

(1) One major indicator and one moderate indicator.

(2) Three or more moderate indicators.

(3) Two or more moderate indicators and two or more minor indicators.

(4) If during the authentication, the indicator values add up to suspicion of counterfeit, the material can be classified as suspect counterfeit, and ideally the material should be inspected or tested further in order to increase confidence in the ruling.


16. Testing

a. Government laboratory test facilities should be used to conduct testing, unless the testing requirements are not available in the AMC Infrastructure. If no government testing capabilities exist, then certified commercial laboratory testing facilities will be utilized. Regardless of the source of testing, the following criteria are to be used when selecting a test laboratory:

(1) ISO certified Organization. Quality assurance program, certified personnel,

and proof of responsibilities. (2) Examples of best laboratory practices - validated test plans; methodologies

for the particular parts and/or materials requiring testing; proof of calibrated test equipment.

(3) Standardized and documented procedures to support testing, storage, data

compiling process and archival - storage of records and reports.

17. Critical and High-Risk Material. High risk material requires the most frequent and stringent tests. These items can be critical function components, critical safety items (CSIs), or material that is at a high risk of counterfeiting, such as electronics, software, embedded memory, and/or communications technology equipment. A counterfeit detection test should be carried out on all such items prior to integrating them into higher level assemblies. 18. Suspected Counterfeit Parts and Materials. a. Initial Containment. At all times suspected counterfeit materials and parts will be segregated in a controlled access area to ensure the parts/materials do not re-enter the inventory.

(1) Segregation. When the product is being tested, the entire lot must be segregated from all other similar material. This will ensure that no product is mistakenly recorded as a different item, or sent to approved stock as acceptable inventory prior to completion of testing. Facilities conducting the testing need written instructions on how suspect material will be segregated and controlled.

(2) Data Record. The source of testing will be required to provide a report of testing performed to include appropriate pictures of product prior to and after testing. The report must include the tests conducted, the sample size tested, results obtained, and determination of findings regarding the item’s authenticity. This data should be stored in a standardized format and retrievable for future reference. b. Final Containment, Disposition, and Notification.

(1) Suspect counterfeit material should be impounded, along with all other items from the same lot and date code. This includes uninstalled (stock and production floor)


material, material installed into hardware, and may include in-process or finished assemblies, including product that has already been shipped to the customer for further processing or final installation.

(2) The containment process must determine the possibility of additional counterfeit material by investigating prior purchases of:

(a) Any material from that supplier, or authorized distributors

(b) Purchases of the same lot and date code from other suppliers

(c) All potential hardware items with the suspect material should be identified,

and the users notified

(3) Destroy/Transfer. Once an item is identified as being suspect counterfeit, it is to be quarantined, along with all other items from the supplier in a location where it cannot be unintentionally used or installed on a higher-level assembly. Secure the material and mark external packaging to denote it is suspect counterfeit to prevent it from re-entering the inventory. The items are not to be returned to the supplier. The items are also not to be destroyed or recycled until approval is given by the contracting officer, or the attorney in the General Counsel’s Office who is assigned to the case. If approval is given to scrap the material, it must be destroyed in a way that would make it impossible to be resold. It shall not be put in the recycling stream unless it is first rendered completely inoperable for any use.

(4) Suspected Counterfeit Parts and Materials Communication. The organization identifying the suspect counterfeit part or material will be in active communication with the AMC CPMP Office, Program Executive Office, National Inventory Control Point, and Counterfeit Prevention Point of Contact at LCMC/RDEC.

(a) Notify the contracting officer, and Criminal Investigation Command (CID) immediately when suspect counterfeit material is identified.

(b) Under no circumstances should suspect counterfeit material be returned

to the supplier, even if this refusal results in lost reimbursement costs. Do not contact the supplier about the suspect counterfeit material.

(i) Requests for analysis should be referred to the OEM/OCM (ii) When a suspect counterfeit determination has been made, the

Engineering Support Activity needs to contact the legal department with supporting technical information, and possibly will be involved for further investigation

(c) Document the suspected counterfeit occurrence (5AS) in PDREP, and

GIDEP.


(d) Communication should be provided also to organizations responsible for any fielded equipment that may contain material from the same lot of suspect material, alerting them of the suspect material and its potential impact. (5) Upon completion of the suspect material investigation, the AMC Counterfeit office and all impacted organizations must be notified of the investigation results. Additionally, if the item was confirmed as counterfeit after investigation, PDREP and GIDEP notifications are to be updated accordingly.


Chapter 6 Training 1. Purpose. To establish a community of learning which provides counterfeit prevention awareness training and identification of additional training resources. 2. Mission. Provide training resources to the AMC workforce so that they can proactively prevent suspect counterfeit parts from entering the supply chain and weapon systems. The focus of the training is to increase the abilities of the AMC workforce to properly identify suspect counterfeit parts. 3. Requirement. a. AMC CPMP Program Staff will be trained in their roles and responsibilities in support of the program. The training is not designed to create subject matter experts, however training criteria will be based on roles and responsibilities to ensure the development of skills, knowledge, and abilities. b. Each LCMC and RDEC will have a trained instructor. c. Each maintenance and/or supply depot will have a trained instructor. d. Each manufacturing arsenal will have a trained instructor. 4. Methodology. a. The AMC CPMP Office will provide regional training to the LCMC’s and RDEC’s. b. The AMC CPMP Office provided training has two primary focuses: 1) Provide the baseline training to the site’s workforce, and 2) Establish a qualified site trainer to ensure sustainment of skill levels. c. Online training resources will available on the AMC Counterfeit Prevention Portal. https://ibwebportal.ria.army.mil/CPP/training.cfm 5. Program of Instruction.

a. AMC CPMP Training.

(1) Counterfeit Awareness Overview.

(2) Protecting the Supply Chain from Counterfeit.

(3) Inspection and Testing of Suspect Counterfeit Parts and Materials.

(4) Reporting and Communication of Suspect Counterfeit.

https://ibwebportal.ria.army.mil/CPP/training.cfm


(5) Disposal of Counterfeit Parts and Materials.

b. Level 1 Foundation.

(1) Professional Reading. (a) DoDI 4140.67, DoD Counterfeit Prevention Policy

(b) DFARS 252.246-7000-7008

(c) DLAD (Defense Logistics Agency Directive) PART 46.490 Oversight of

DoD supply chain integrity

(d) SAE 5553

(e) SAE 6081

(f) SAE 6174

(g) GIDEP/PDREP Introduction Training

(2) Defense Acquisition University Courses Acquisition Management (ACQ) Continuous Learning Contracting (CLC) Continuous Learning Engineering (CLE) Continuous Learning Logistics (CLL) Continuous Learning Module (CLM) Logistics (LOG)

(a) CLL 032 – Preventing Counterfeit Electronic Parts from Entering the DoD Supply Chain

(b) CLL 062 – Counterfeit Prevention Awareness

(c) CLL 201 – DMSMS Fundamentals

(d) CLL 202 – DMSMS Fundamentals: Executive Summary

(e) CLL 203 – DLA DMSMS Essentials

c. Level 2 Recommended Functional Training.

(1) CLL 015 – Business Case Analysis

(2) CLL 019 – Technology Refresh Planning


(3) CLL 020 – Independent Logistics Assessments

(4) CLE 301 – Reliability and Maintainability

(5) CLC 011 – Contracting for the Rest of Us

(6) CLL 206 – Introduction to Parts Management

(7) CLE 003 – Technical Reviews

(8) CLM 017 – Risk Management

(9) ACQ 101 – Acquisition Fundamentals

(10) LOG 235 – Performance Based Logistics 6. Knowledge, Skills, and Abilities Thresholds.

a. Understanding of DoD and Army policies, regulations, and procedures as applied to counterfeit prevention, maintenance planning, and the acquisition and sustainment of a program of record.

b. In-depth knowledge of the capabilities of government mandated case-tracking

systems GIDEP and PDREP. c. Working knowledge of supply chain risk management tools and principles. d. Life Cycle Sustainment Plan 2.0 obsolescence and counterfeit risk management

requirements.


Appendix A. Internet Resources and References Internet Resources AAQ (Academy of Aerospace Quality). http://aaq.eng.auburn.edu/drupal7/, The AAQ (Academy of Aerospace Quality) is an online platform for quality assurance training for academics, students, and commercial space service providers involved in aerospace research, technology development, and payload design and development. The AAQ curriculum includes training modules for all aspects of quality assurance necessary to ensure project success. The AAQ website provides a virtual community for networking and sharing of lessons-learned among like-minded scholars Aerospace Industries Association (AIA) https://www.aia-aerospace.org/, The Aerospace Industries Association is the voice of American aerospace and defense. We advocate for policies and responsible budgets that keep our country strong, bolster our capacity to innovate, and spur our economic growth. AMC Obsolescence Tools and Process Working Group, https://login.milsuite.mil/?goto=https%3A%2F%2Fwww.milsuite.mil%3A443%2Fbook%2Fgroups%2Fobsolescence-tool-working-group-otwg. Army Equipping Enterprise System (AE2S). https://afm.us.army.mil/sso/banner/?back=https%3a%2f%2fafm.us.army.mil%2fsuite%2fAclReg%2flogin.jsp Army Materiel Command Standards and Specifications Procurement Program. https://www.us.army.mil/suite/page/468324, Logging on and Searching IHS Standards Products (See Appendix B) Army Research and Technology Protection (RTP) Program. http://www.dami.army.pentagon.mil/site/ARTPC/, The Army Research and Technology Protection (RTP) Program was established to provide tailored, life cycle comprehensive RTP to DOD acquisitions programs with Critical Program Information (CPI), and to Research, Development, Testing and Evaluation Centers where critical research is conducted CPMP Program Website, https://ibwebportal.ria.army.mil/CPP/ Center for Advanced Life Cycle Engineering (CALCE). https://www.calce.umd.edu/, CALCE is recognized as a founder and driving force behind the development and implementation of physics-of-failure (PoF) approaches to reliability, as well as a world leader in accelerated testing, electronic parts selection and management, and supply-chain management

http://aaq.eng.auburn.edu/drupal7/

https://www.aia-aerospace.org/

https://login.milsuite.mil/?goto=https%3A%2F%2Fwww.milsuite.mil%3A443%2Fbook%2Fgroups%2Fobsolescence-tool-working-group-otwg

https://login.milsuite.mil/?goto=https%3A%2F%2Fwww.milsuite.mil%3A443%2Fbook%2Fgroups%2Fobsolescence-tool-working-group-otwg

https://afm.us.army.mil/sso/banner/?back=https%3a%2f%2fafm.us.army.mil%2fsuite%2fAclReg%2flogin.jsp

https://afm.us.army.mil/sso/banner/?back=https%3a%2f%2fafm.us.army.mil%2fsuite%2fAclReg%2flogin.jsp

https://www.us.army.mil/suite/page/468324

http://www.dami.army.pentagon.mil/site/ARTPC/

https://www.calce.umd.edu/


Center for Development of Security Excellence (CDSE). https://www.cdse.edu/index.html, CDSE is a nationally accredited, award-winning directorate within the Defense Security Service (DSS) located in Linthicum, MD. CDSE provides security education, training, and certification products and services to a broad audience supporting the protection of National Security and professionalization of the DoD security enterprise Defense Acquisition Guidebook 2017. https://www.dau.mil/tools/dag DoD Issuances. http://www.esd.whs.mil/Directives/issuances/dodi/ Department of Defense Medical Materiel Quality Control Messages (MMQC)/Medical Materiel Information Messages. To develop, tailor, deliver, and sustain medical material capabilities and data in support of readiness and healthcare operations globally http://www.usamma.amedd.army.mil/assets/apps/nala_qaweb/nala_query_type.cfm DoD Microelectronics Activity, https://www.dmea.osd.mil/home.html Department of Defense, Research and Engineering Gateway (DoD Techipedia) https://www.dodtechipedia.mil Defense Logistics Agency Land and Maritime, Counterfeit Parts & Risk Mitigation Subcommittee http://www.dla.mil/LandandMaritime/Offers/Services/TechnicalSupport/DocStandDiv/PartsMgmtPgrm/PartsStdMgmtComm/PSMCSubComm/CounterfeitSub.aspx Defense Logistics Agency, Qualified Testing Suppliers List (QTSL) Home Page http://www.landandmaritime.dla.mil/offices/sourcing_and_qualification/offices.aspx?Section=QTSL Defense Microelectronics Activity (DMEA). DMEA was established and continuously evolved by the Office of the Secretary of Defense (OSD) to jointly act as the DOD Center for microelectronics technology, acquisition, transformation, and support. https://www.dmea.osd.mil/ Defense Pricing/Defense Procurement and Acquisition Policy https://www.acq.osd.mil/dpap/index.html Diminishing Manufacturing Sources and Material Shortages (DMSMS) Knowledge Sharing Portal (DKSP). DMSMS Knowledge Sharing Portal (DKSP) is focused on being a non-biased one-stop provider of DMSMS related information, resources and material to empower the DoD community, both Organic and Industrial, to implement best practices for monitoring, tracking, resolving, and performing analytical logistic and engineering analysis related to obsolescence impacts. Utilization of the DKSP as a resource facilitates optimal resolution, test, parts management, design, upgrade and

https://www.cdse.edu/index.html

https://www.dau.mil/tools/dag

http://www.esd.whs.mil/Directives/issuances/dodi/

http://www.usamma.amedd.army.mil/assets/apps/nala_qaweb/nala_query_type.cfm

https://www.dmea.osd.mil/home.html

https://www.dodtechipedia.mil/

http://www.dla.mil/LandandMaritime/Offers/Services/TechnicalSupport/DocStandDiv/PartsMgmtPgrm/PartsStdMgmtComm/PSMCSubComm/CounterfeitSub.aspx

http://www.dla.mil/LandandMaritime/Offers/Services/TechnicalSupport/DocStandDiv/PartsMgmtPgrm/PartsStdMgmtComm/PSMCSubComm/CounterfeitSub.aspx

http://www.landandmaritime.dla.mil/offices/sourcing_and_qualification/offices.aspx?Section=QTSL

http://www.landandmaritime.dla.mil/offices/sourcing_and_qualification/offices.aspx?Section=QTSL

https://www.dmea.osd.mil/

https://www.acq.osd.mil/dpap/index.html


redesign methodologies, thereby minimizing detrimental weapons systems readiness resulting from DMSMS and obsolescence impacts https://www.dau.mil/cop/dmsms/Pages/Default.aspx DoD Integrated Product Support Roadmap. https://www.dau.mil/dodpsroadmap/Pages/Default.aspx, Product Support Management is the planning, management and funding of the package of support functions required to field and maintain the readiness and operational capability of major weapon systems, subsystems, and components Federal Aviation Administration. Aviation Counterfeit Notices, https://www.faasafety.gov/ Federally Funded Research and Development Centers (FFRDCs) https://www.nsf-urveys.net/FedFunds/(S(jny2rxzi2wyncyk4du1qr5kt))/HelpNonDOD/ffrdc.aspx Global Combat Support System – Joint. https://gcss61.csd.disa.mil/gcssportal Government Electronics & Information Technology Association (Tech America), http://www.geia.org/ Havocscope. Havocscope calculates the worldwide losses to counterfeiting based upon 26 different counterfeit products and the economic impact of counterfeit goods and piracy in 88 countries. To see the estimated losses by counterfeit products and the losses by country https://www.havocscope.com/category/counterfeit-goods/ Joint Electron Device Engineering Council (JEDEC), Global Standards for the Microelectronics Industry, https://www.jedec.org/ Joint Federated Assurance Center (JFAC). A federation of DoD organizations that promotes and enables software and hardware assurance by providing expertise and support to defense acquisition programs and supporting activities https://jfac.navy.mil/ Joint Technology Exchange Group (JTEG). The Joint Group on Depot Maintenance (JG-DM) hereby charters the JTEG to improve coordination in the introduction of new or improved technology, new processes, or new equipment into DoD depot maintenance activities https://jteg.ncms.org/ Joint Deficiency Reporting System (JDRS). This web site allows submission and complete processing of various Deficiency Reports for US Army, Air Force, Coast Guard, and Navy/Marines users https://jdrs.mil/ Logistics Support Activity (LOGSA) https://www.logsa.army.mil/

https://www.dau.mil/cop/dmsms/Pages/Default.aspx

https://www.dau.mil/dodpsroadmap/Pages/Default.aspx

https://www.faasafety.gov/

https://www.nsf-urveys.net/FedFunds/(S(jny2rxzi2wyncyk4du1qr5kt))/HelpNonDOD/ffrdc.aspx

https://www.nsf-urveys.net/FedFunds/(S(jny2rxzi2wyncyk4du1qr5kt))/HelpNonDOD/ffrdc.aspx

https://gcss61.csd.disa.mil/gcssportal

http://www.geia.org/

https://www.havocscope.com/category/counterfeit-goods/

https://www.jedec.org/

https://jfac.navy.mil/

https://jteg.ncms.org/

https://jdrs.mil/

https://www.logsa.army.mil/


Life Cycle Sustainment Plan Outline Version 2.0, Office of the Assistant Secretary of Defense, Logistics and Materiel Readiness https://www.dau.mil/tools/Lists/DAUTools/Attachments/12/LCSP%20Plan%20Outline%20Version%202.0%20-%2019%20Jan%202017.pdf Life Cycle Sustainment Plan (LCSP) Outline, Defense Acquisition University https://www.dau.mil/tools/t/Life-Cycle-Sustainment-Plan-(LCSP)-Outline Materiel Enterprise Capabilities Database (MEC-D). The Materiel Enterprise Capabilities Database (MEC-D) is a tool used to simplify initial market research for manufacturing and repair capabilities within the Army Organic Industrial Base. Primary users of the MEC-D have US Army Acquisition and Sustainment requirements, but also include other DoD and USG requirements. Additional information includes: facilities, services, and skills https://mecd.ria.army.mil/default.cfm Mergent Online. Offers a wealth of textual detail - the hallmark of all Mergent Products - on company financials, descriptions, history, property, subsidiaries officers and directors. Powerful intuitive search capabilities combined with an easy to use interface, access to risk ratings, credit information and recommendations under one platform http://www.mergentonline.com/login.php, National Intellectual Property Rights Coordination Center. IPR Center partners employ a strategic approach to combat IP Theft. That approach includes:

• Investigation. Identifying, disrupting, prosecuting and dismantling criminal organizations involved in the manufacture and distribution of counterfeit products.

• Outreach and Training. Providing training for domestic and international law enforcement to build stronger enforcement capabilities worldwide

• https://www.iprcenter.gov/ National Council for Advanced Manufacturing (NACFAM). The National Council for Advanced Manufacturing (NACFAM) is the non-partisan voice of advanced manufacturing in Washington, DC, advocating manufacturing-related policy and program solutions to help revitalize the U.S. manufacturing sector in four key areas: Technological Innovation/Supply Chain Integration/Sustainable Manufacturing/Talent Development http://www.nacfam.org/ Office of the Deputy Assistant Secretary of Defense (ODASD) - Systems Engineering https://www.acq.osd.mil/se/initiatives/init_pp-sse.html Open Source Enterprise https://www.opensource.gov/public/content/login/login.fccIntelligence National Institute of Standards and Technology (NIST), Department of Commerce https://www.nist.gov/ Product Data Reporting and Evaluation Program. The Product Data Reporting and Evaluation Program (PDREP) is the Department of the Navy program that supports requirements regarding the reporting, collection and use of supplier performance

https://www.dau.mil/tools/Lists/DAUTools/Attachments/12/LCSP%20Plan%20Outline%20Version%202.0%20-%2019%20Jan%202017.pdf

https://www.dau.mil/tools/Lists/DAUTools/Attachments/12/LCSP%20Plan%20Outline%20Version%202.0%20-%2019%20Jan%202017.pdf

https://www.dau.mil/tools/t/Life-Cycle-Sustainment-Plan-(LCSP)-Outline

https://mecd.ria.army.mil/default.cfm

http://www.mergentonline.com/login.php

https://www.iprcenter.gov/

http://www.nacfam.org/

https://www.acq.osd.mil/se/initiatives/init_pp-sse.html

https://www.opensource.gov/public/content/login/login.fccIntelligence

https://www.nist.gov/


information identified in the Code of Federal Regulations (CFR), Federal Acquisition Regulation (FAR), Defense Federal Acquisition Regulation Supplement (DFARS) and Navy regulations. PDREP supports Navy management of the supply chain ensuring first time quality and on-time delivery of materials for both critical and non-critical applications. PDREP promotes continuous process improvement for increased material readiness and decreased deficiency issues, providing an overall cost savings to DoD and the Navy https://www.pdrep.csd.disa.mil/ Research and Engineering Gateway. Integrated "Billboard" which provides a DoD source for scientific and technical (S&T) information https://dtic-stinet.dtic.mil/ TACOM DMSMS/Obsolescence/Counterfeit Resource Center https://tacom.aep.army.mil/sites/mso/DOC/Pages/TACOMDMSMSOBSOLCOUNT.aspx?FollowSite=1&SiteName=TACOM%20DMSMS%2FObsolescence%2FCounterfeit%20Resource%20center Tech America (GEIA) https://www.techamerica.org/ Trusted Access Program Office https://www.dmea.osd.mil/tapo.html United States Army Criminal Investigation Division Command, 701st Military Police Group (CID), Major Procurement Fraud Unit (MPFU) http://www.cid.army.mil/701st.html#sec4 Reference Documents Aerospace Standards – Use Army Knowledge Online to access standards (See Appendix B for log-in instructions) SAE AS5553 - Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition SAE ARP6328 - Guideline for Development of Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition Systems SAE AS6081- Fraudulent/Counterfeit Electronic Parts: Avoidance, Detection, Mitigation, and Disposition - Distributors SAE AS6462 - Fraudulent/Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition Verification Criteria SAE AS6496 - Fraudulent/Counterfeit Electronic Parts: Avoidance, Detection, Mitigation, and Disposition - Authorized/Franchised Distribution SAE AS6174 - Mechanical Parts and Materials Counterfeit Avoidance

https://www.pdrep.csd.disa.mil/

https://dtic-stinet.dtic.mil/

https://tacom.aep.army.mil/sites/mso/DOC/Pages/TACOMDMSMSOBSOLCOUNT.aspx?FollowSite=1&SiteName=TACOM%20DMSMS%2FObsolescence%2FCounterfeit%20Resource%20center



https://www.techamerica.org/

https://www.dmea.osd.mil/tapo.html

http://www.cid.army.mil/701st.html#sec4


SAE AS6171/1 - Suspect/Counterfeit Test Evaluation Method SAE AS6171A - Test Methods Standard; General Requirements, Suspect/Counterfeit, Electrical, Electronic, and Electromechanical Parts SAE AS9017 - Control of Aviation Critical Safety Items SAE EIA-STD-4899C - Requirements for an Electronic Components Management Plan Non-SAE Standards and Department of Defense Documents Army Regulation 70–77, Research, Development, and Acquisition, Program Protection Army Regulation 700–90, Logistics, Army Industrial Base Process Army Regulation 700–127, Logistics, Integrated Product Support Army Regulation 702–7–1, Product Assurance, Reporting of Product Quality Deficiencies Within the U.S. Army DCMA-INST 1205, Department of Defense, Defense Contract Management Agency, Instruction Counterfeit Mitigation. Multifunctional Instruction Defense Federal Acquisition Regulation Supplement – DFARS Defense Science Board Task Force on Cyber Supply Chain Report, February 2017

Department of Defense Instruction 4140.01, DoD Supply Chain Materiel Management Policy Department of Defense Instruction 4140.67, DoD Counterfeit Prevention Policy of 26 April 2013, Incorporating Change 1, 25 October, 2017 Department of Defense Instruction 5000.02, Operation of the Defense Acquisition System Department of Defense Instruction 5200.44, Protection of Mission Critical Functions to Achieve Trusted Systems and Networks Department of Defense Instruction 7050.05 Coordination of Remedies for Fraud and Corruption Related to Procurement Department of Defense Instruction 8510.01, Subject: Risk Management Framework (RMF) for DoD Information Technology (IT). Department of Defense Manual (DODM) 4140.01, DOD Supply Chain Materiel Management Procedures, Volume 11


Department of Defense, Office of the Deputy Assistant Secretary of Defense for Systems Engineering, Risk, Issue, and Opportunity Management Guide for Defense Acquisition Programs, 2015 Department of the Navy, Counterfeit Materiel Process Guidebook, Guidelines for Mitigating the Risk of Counterfeit Materiel in the Supply Chain, Office of the Assistant Secretary of the Navy, (Research, Development & Acquisition) Acquisition and Business Management, June 2017 Deputy Assistant Secretary of Defense for Systems Engineering (DASD(SE)). 2011. Program Protection Plan Outline and Guidance, Version 1.0. http://www.acq.osd.mil/se/docs/PPP-Outline-and-Guidance-v1-July2011.pdf Deputy Assistant Secretary of Defense, Systems Engineering, Program Protection Plan Evaluation Criteria, Version 1.1, dtd February 2014 Department of the Army, Office of the Assistant Secretary of the Army. Acquisition Logistics and Technology, SAAL-ZT, Memorandum For See Distribution, Subject: Policy on Use of In-House Engineering and Technical Resources Government Industry Data Exchange Program (GIDEP) Operations Manual Independent Distributors of Electronics Association Standard (IDEA-STD) -1010: Acceptability of Electronic Components Distributed in the Open Market IPC-1782, Standard for Manufacturing and Supply Chain Traceability of Electronic Products JEDEC Standard. JESD243 Counterfeit Electronic Parts: Non-Proliferation for Manufacturers MIL-HDBK-896A, Department of Defense, Handbook, Manufacturing Management Program Guide MIL-STD-3018, Parts Management MIL-STD-11991A, Department of Defense Standard Practice, General Standard for Parts, Materials, and Processes SECNAVINST 4140.2, AFI 20-106, DA Pam 95-9, DLA I3200.4, DCMA INST CSI (AV) 25, Management of Aviation Critical Safety Items Standardization Document-19 (SD-19), Parts Management Guide Standardization Document (SD-22), Diminishing Manufacturing Sources and Material Shortages. A Guidebook of Best Practices for Implementing a Robust DMSMS Management Program

http://www.acq.osd.mil/se/docs/PPP-Outline-and-Guidance-v1-July2011.pdf


SECNAVINST 4855.3, Product Data Reporting and Evaluation Program (PDREP) United States Government Accountability Office (GAO), Counterfeit Parts: DOD Needs to Improve Reporting and Oversight to Reduce Supply Chain Risk Report to Congressional Committees GAO-16-236 United States GAO, Defense Supplier Base, DOD Should Leverage Ongoing Initiatives in Developing Its Program to Mitigate Risk of Counterfeit Parts, GAO-10-339 United States GAO, Military Readiness, DOD’s Readiness Rebuilding Efforts May Be at Risk without a Comprehensive Plan, GAO-16-841 USD(AT&L) Memorandum, Document Streamlining – Program Protection Plan (PPP), July 18, 2011, https://www.acq.osd.mil/se/docs/PDUSD-ATLMemo-Expected-Bus-Practice-PPP-18Jul11.pdf

https://www.acq.osd.mil/se/docs/PDUSD-ATLMemo-Expected-Bus-Practice-PPP-18Jul11.pdf

https://www.acq.osd.mil/se/docs/PDUSD-ATLMemo-Expected-Bus-Practice-PPP-18Jul11.pdf


Appendix B. How to Access Army Materiel Command Standards and Specifications


Appendix C. Indicators of Counterfeit Electronic Parts1 1. The following table is a guide, not an exhaustive list, which contains possible indicators that may point to a part being suspect counterfeit. While many of these indicators apply only to electronic parts, some would apply equally to all material (package inspection, documentation inspection, marking inspection, physical dimensions). No one indicator may be sufficient for classifying a part as suspect counterfeit, therefore it is best practice to look for multiple indicators. It is best to consider both the quantity and strength of indicators found to make a determination. Input from the original component manufacturer should weigh heavily in this determination if their input is available. Counterfeit Indicator Guide

Test Type Counterfeit Indicator Strength of Indicator

External Package Inspection

Shipping damage to external packaging Minor Misspelled wording on external packaging Minor Wrong part number on external packaging Moderate Erroneous OM Logo on external packaging Major

Internal Package Inspection

Shipping damage to box/tube/tray/reel Minor Misspelled wording on box/tube/tray/reel Minor Wrong part number on box/tube/tray/reel Moderate Wrong quantity notes on box/tube/tray/reel Minor Bar code mismatch (scan vs human) on box/tube/tray/reel Major Erroneous OM Logo on box/tube/tray/reel Major Not in original manufacturer's packaging Minor Use of non-ESD protected material Moderate Not in a sealed moisture barrier bag Minor Humidity indicator card (HIC does not change with humidity) Major

Wrong/inconsistent orientation in tube/tray/reel Moderate Inconsistent design of tubes/trays/reels Moderate Incorrect size for tube/tray Moderate

Documentation Inspection

Misspelled wording in documentation Minor Mismatch in part number or lot/DC in documentation Moderate Mismatch in part quantity in documentation Minor Erroneous OM Logo on documents Major Evidence of tampering in documentation Moderate

1 Appendix C copied with Approval From Navy Counterfeit Materiel Process Guidebook NAVSO P-7000



Part Marking / ID Inspection

Three or more date codes or lots in the same box/tube/tray/reel Moderate

Marking on part does not match documentation or packaging Moderate Lot/DC on part does not match documentation or packaging Moderate Impossible lot/DC on part or packaging (obsolete) Major Inconsistent part indentation (pin 1, etc.), top or bottom Major Inconsistent country of origin information Major Incorrect/erroneous manufacturer logo Major Texture within part indentations Minor Misaligned markings on parts Minor

Inconsistent laser etch depth/width Minor Part markings are poor quality Minor

Physical Dimensions Package dimensions fail specifications Major Pin count is incorrect Major

Part Surface Inspection

Superficial scratches or chips on part Minor Major mechanical damage (chips, scratches, etc.) Moderate Heat stress (bulges or blisters) on part Major "Ghosted" markings visible on part surface Major Sanding visible across part surface Major Inconsistent texture or color on parts in same lot/DC Moderate Suspicious texture or color on part Minor Suspicious laser markings Minor Internal die or wirebonds exposed to surface of part Major Evidence of microblasting Major Evidence of flat lapping Major Chemical residue or other contamination on part Minor

Lead / Solder Ball Inspection

Bent leads on part Minor Replated part leads (no tooling marks) Major Deformed leads/balls Minor Wrong solder ball size Moderate No exposed copper on end of leads Minor Oxidized/corroded leads/balls Minor Excessive scratches or scrapes on leads Moderate Missing leads/balls Moderate Solder splash on leads/balls Moderate Evidence of microblasting Moderate Reattached leads on part Major Lead design varies on parts in same lot/DC Moderate



Marking Permanency

Ink marking is removed by MS/alcohol Moderate Surface coating is removed by MS/alcohol Major Hidden "ghosted" markings uncovered by MS/alcohol Major Internal die or wirebonds exposed by MS/alcohol Major Sanding underneath surface uncovered by MS/alcohol Major

Surface Scrape Surface coating is removed by a razor knife Major Sanding underneath surface exposed by razor knife Major

Surface Finish Permanency

Ink marking is removed by acetone Minor Surface coating is removed by acetone Major Hidden "ghosted" markings uncovered by acetone Major Internal die or wirebonds exposed by acetone Major Sanding underneath surface uncovered by acetone Major

Surface coating is removed by aggressive solvents Major Hidden "ghosted" markings uncovered by aggressive solvents Major Internal die or wirebonds exposed by aggressive solvents Major Sanding underneath surface uncovered by aggressive solvents Major

X-Ray Fluorescence Inconsistent lead plating composition Minor

Incorrect lead plating composition Moderate

Radiological (X- Ray)

Inconsistent die size or design on parts in same lot/DC Major

Misaligned die Minor

Cracked or damaged die Major Inconsistent lead frame size or design on parts in same lot/DC Major Damaged or deformed lead frame Major

Inconsistent wire bond thickness on parts in same lot/DC Minor

Inconsistent wire bond placement on parts in same lot/DC Major

Incorrect wire bond material Major

Missing wire bonds Major

Double ball bonds Major

Inconsistent die/lead frame thickness on parts in same lot/DC Minor

Scanning Acoustic Microscopy

Hidden "ghosted" markings visible by shallow scan Major

Die delamination visible with CSAM scan Minor

Inconsistent die size or design on parts in same lot/DC Major Inconsistent lead frame size or design on parts in same lot/DC Major



Decapsulation

Inconsistent die size or design on parts in same lot/DC Major

Misaligned die Minor

Cracked or damaged die Major Poor quality (e.g., traces, spacing, contamination, etc.) Minor

Wrong OM or logo Major

Mismatched part number Minor

Incorrect wire bond material Major

Inconsistent OM or logo on parts in same lot/DC Major

Inconsistent part number on parts in same lot/DC Major

Inconsistent die design on parts in same lot/DC Major

Inconsistent lead frame design on parts in same lot/DC Major

Impossible date code (die year after part DC) Major

Part is more difficult to decap compared to known good Minor

Electrical Test

One-time programmable parts can't be programmed Major

Code/programming left over in parts Major

25% or higher electrical failure rate Moderate 10% or higher electrical failure rate Minor

5% or higher electrical failure rate Minor

Electrical failures are gross (wrong/damaged) Major Electrical failures are marginal (stress) Minor

Non-traditional electrical test variation Minor

Known Good Part Comparison

Unmatched pin 1 indicator Moderate Unmatched dimple placement Moderate Unmatched font or lot format Moderate Unmatched lead design Moderate Unmatched lead frame Minor Unmatched die markings Minor

OM Support Component manufacturer states parts are likely counterfeit Major Component manufacturer states parts are possibly counterfeit Moderate


Appendix D. Examples of Counterfeit Electronic Parts2

• Visual inspection revealed incorrect and misspelled logo. The phrase ‘NRTL’ denotes Nationally Recognized Test Laboratories, a listing of labs certified to certain test standards. The presence of a misspelling (NRLT) is a strong indicator that the label is counterfeit.

• Visual inspection revealed font inconsistencies.

• Visual inspection reveals variation in substrate design. This is highly unusual for parts from the same lot and date code.

2 Appendix D copied with Approval From Navy Counterfeit Materiel Process Guidebook NAVSO P-7000


• Visual inspection revealed blacktopping material along the edge of the part.

• Visual inspection revealed blacktopping in the part indent.

• Visual inspection found no exposed copper on the ends of leads.

• Visual inspection found contamination and scratches on leads


• Visual inspection found different fonts for the country of origin. This is highly unusual for parts from the same lot and date code.

• Visual inspection found different Pin 1 indicators. This is highly unusual for parts from the same lot and date code.

• Visual inspection found bent leads and major chip outs from part


• Acetone swab removing top coating. Sanding marks revealed underneath coating.

• DynaSolve 750 Solvents removed top coating.

• Visual inspection found suspicious laser markings. Acoustic microscopy found ghosted markings confirming the parts had been remarked


• Acoustic microscopy showed horizontal scratches indicative of sanding as well as ghosted markings.

• Acoustic microscopy revealed ghosted markings. The devices were remarked as different speeds or different temperature ranges.

• Acoustic microscopy identified the center of the part contained a different material that was otherwise undetectable upon visual inspection.


• Visual and X-Ray inspection revealed part with leads that were reattached.

• X-Ray inspection found three different lead frame designs and two different die sizes. This is highly unusual for parts from the same lot and date code.

• X-Ray inspection found two different lead frame designs. This is highly unusual for parts from the same lot and date code.


• Decapsulation revealed different die sizes as well as die markings. This is highly unusual for parts from the same lot and date code.

• Decapsulation revealed different die markings. This is highly unusual for parts from the same lot and date code.

No Markings Markings


Appendix E. Indicators of Counterfeit Mechanical Parts and Materials3

Test/Material Type Counterfeit Indicator

Strength of

Indicator Packaging Indicators

Inconsistent vendor name on the item and on the shipping container, or no name on the container Moderate

Shipping boxes contain mixed batch numbers, expiration dates, and UPC codes Minor

Unusual packaging and boxing of items Moderate Inconsistent with the manufacturer’s normal packaging or documentation requirements Major

Questionable or meaningless numbers on the item(s) or packaging Moderate

Obviously changed labeling (crossed out or erased) Moderate Erroneous OM Logo on external packaging Major

Nameplate Indicators

Appear to have been altered, photocopied, or painted over Major Have incomplete or missing data Moderate Preprinted labels that show typed entries Moderate Attached in a different location than normal or with inconsistent fasteners (screws instead of rivets, or a combination of rivets

Moderate

Missing manufacturer’s standard markings, stamps, or logos, and with irregular stamping or inconsistent font Multiple logos and seals

Major

Warning labels with grammatical errors or that conflict with information found elsewhere on the packaging Major

Obviously changed labeling (crossed out or erased) Major Documentation Indicators

Excessively faded or unclear or missing data Moderate Use of correction fluid or correction tape Major Type style, size, or pitch change is evident Moderate Data on a single line is located at different heights Moderate Lines on forms are bent, broken, or interrupted indicating data has been deleted or exchanged by “cut and paste” Major

Handwritten entries are on the same document where there is typed or preprinted data Moderate

Text on page ends abruptly and the number of pages conflicts with the transmittal Moderate

Corrections are not properly lined-out, initialed and dated Moderate Document is not signed or initialed when required Moderate The name of the document approver, or title, cannot be determined Moderate

Document has missing or illegible signature, initials Moderate The name of the document approver, or title, cannot be determined Major

Approvers name and signature do not match Major

3 Appendix E copied with Approval From Navy Counterfeit Materiel Process Guidebook NAVSO P-7000


Test/ Material Type Counterfeit Indicator Strength of

Indicator

Documentation Indicators

Technical data is inconsistent with code or standard requirements Major Certification/test results are identical between all tested item, expect normal variations Moderate

Documentation Certificate of Conformance and Testing is not delivered as required on the purchase order, or is in an unusual format

Moderate

Document is not traceable to the items procured Major

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Pitting or corrosion Moderate External weld or heat indications Major Questionable or meaningless numbers Major Typed labels Moderate Evidence of hand-made parts Major Painted stainless steel Moderate Ferrous metals that are clean and bright Moderate Excess wire brushing or painting Minor Ground off casting marks or logos Major Weld repairs Major Threads showing evidence of wear or dressing Moderate Inconsistency between labels Moderate Old or worn nameplates Moderate Missing manufacturer’s standard markings and logos Major Overlapping stamps Moderate Different colors of the same part Moderate Traces of Prussian Blue or other lapping compound Moderate Used component appearance Moderate Wrench marks Moderate Scratches on component outer surface Minor Missing markings Moderate Missing ratings Moderate Evidence of re-stamping Major Wrong material Major Deficient welds Major Outside of dimensional specifications Major Wrong country of origin Major Wrong fasteners for nameplates Moderate

Valves

Poor fit between assembled valve parts Major Scratched or marred fasteners or packing glands Minor Gate valve: Gate off-center when viewed through open end Major Fresh sand-blasted appearance of valve bodies, eyebolts, fittings and stems Minor

Loose or missing fasteners Moderate Different design on valves of the same manufacturer Moderate


Test/Material Type Counterfeit Indicator

Strength of

Indicator

Some parts (e.g., hand wheels) look newer than the rest of the valve Minor

Excessive or missing markings (e.g. UL, FM, CGA, AGA) Moderate Valves will not open or close, even when wrench applied Major Valves Substandard valves mixed in with standard valves (substitution) Major Indications of prior use Major Wrong/insufficient logo, , pressure rating, heat treat conditions, etc. Major Altered markings on identification tags Major

Small Hardware

Poor thread form, evidence of wear, or dressing Moderate No markings for nuts or washers manufactured to a code or MIL-SPEC which requires marking Major Headmarkings are marred, missing, or appear to have been altered Major

Headmarkings are inconsistent with heat/lot Major Double stamping (Metric and SAE) Major Headmarks with raised marks and depressed marks on same bolt Major

Roller Bearings

Missing markings Major Markings in wrong location Moderate Evidence of re-stamping Major Wrong material Major Dimensional specifications out of tolerance Major Incorrect packaging Moderate


Appendix F. Examples of Counterfeit Mechanical Parts and Materials4

• Counterfeit precision bearings had different packaging, dimensions, and lot/date code markings.

• Counterfeit valve, handle marked Watts Regulator FBV-1 but Watts doesn’t manufacture a FBV-1 series valve. Further, Taiwan is stamped on the handle and Watts doesn’t have a facility in Taiwan. It is important to know the common markings specific to each Valve manufacturer.

4 Appendix F copied with Approval From Navy Counterfeit Materiel Process Guidebook NAVSO P-7000


• Counterfeit valve was sold as “new” but was dirty, scratched, had clamp marks, had groove in

bolt hole and had different rivet sizes on tag.

• Grade 8 bolts are the most commonly counterfeited fastener. No manufacturer’s mark or grade mark (unless certified to a specification not requiring marking) are visual indicators the part may be counterfeit. See Appendix III to ANSI B18.2.1 for information on bolt head markings based on the grade of the fastener.

• Counterfeit refrigerant gas had many print errors on the container. Counterfeit refrigerant (R-

40 instead of R-134a) can cause cancer, kidney/liver damage, and corrosion to aluminum causing potentially a violent explosion.


• Counterfeit circuit breakers had different markings than genuine parts.

• Counterfeit pipe plugs were required to be 316 stainless steel and failed magnetic permeability testing. Full metallurgical analysis showed material is carbon steel. Further, manufacturer’s marking did not match any in MIL-HDBK-57.

• Counterfeit bronze pipe tee’s - material was found to be highly magnetic and rusted. Full metallurgical analysis found material is actually carbon steel painted a bronze color.


• Counterfeit hook – Crosby Group, Inc. has the patent trademark registration for the color Red in the United States. This hook was received from a Crosby distributor and represented as a Crosby hook. However, it was marked as “ELD” not “CG” or “Crosby”

• Counterfeit washers/spacers were received in the same box together. The counterfeit part had no marking and unknown manufacturer.

• Counterfeit stainless steel “T” weldlet had grind marks where information was removed and new information was stamped on.


Appendix G. Parts Management Plan Considerations 1. The following considerations and elements are the parts management construction elements that are recommended for consideration. a. Typical plan considerations.

• Component application • Component qualification • Component quality assurance • Component dependability • Component compatibility with the equipment manufacturing process.

b. Elements. 1) Part selection baseline. Parts selection list gives visibility to designers and subcontractors of the parts preferred for use. 2) Part selection and authorization. The management and organizational structure for standardization functions. 3) Obsolescence management. The plan must include procedures for obsolescence management, such as proactive obsolescence forecasting and mitigation for application part types. 4) Parts list or bill of materials. The plan must detail how and when the contractor submits initial and updated parts lists or bills of materials to the government, as required by contract. 5) Subcontractor management. The plan must describe contractor procedures for establishing and maintaining subcontractor participation to the extent necessary to ensure satisfaction of the parts management objectives. 6) Part and supplier quality. The plan must describe provisions for assessing part suppliers and part quality, such as statistical process control data, audits, and past performances. 7) Part-level documentation procedures. The documentation procedures must be detailed and consistent with the program’s configuration management, logistics strategies, and total life-cycle requirements. 8) Substitute and alternate part procedure. The process for the management, definition, and documentation of substitute and alternate parts. 9) Replacement process. The contractor must ensure that the program is consistent with the intent and application of systems engineering disciplines (configuration management, quality, logistics, etc.). 10) Customer-contractor teaming. The parts management plan must address customer teaming to allow for continued insight into processes for program verification.


11) Counterfeit parts. Address the detection, mitigation, and disposition of counterfeit parts, including electronic, electrical, and mechanical parts. SAE International’s AS6081 should be used as guidance for electronic parts. AS6174 should be used as guidance for mechanical parts. 12) Lead-free electronic parts. The parts management plan must address the process to manage the risk associated with using lead-free parts. Tech-America GEIA-STD-0005-1 may be used as guidance for lead-free electronic parts. 13) Additional elements. The process for addressing those additional elements, as identified by contract, must be defined.


Appendix H. Sample Statement of Work Language 1. The following provides information that can be considered for inclusion into the Statements of Work (SOW) for solicitations or contracts where counterfeit material is identified as a risk. a. Counterfeit Risk Management Plan. The Contractor shall prepare, or update existing, Counterfeit Risk Management Plan for submittal and Government approval in accordance with DI-MISC-81832, CDRL XXXX. The Plan shall meet the requirements of SAE AS5553 for electronic items and SAE AS6174 for non-electronic items. The Contractor shall procure parts from original manufacturers or the original manufacturers’ franchised distributors. Contractors shall report counterfeits and suspected counterfeits to the Government and in the Government Industry Data Exchange Program (GIDEP), in accordance with the GIDEP Operations Manual, SO300-BT-PRO-010. 2. In addition to the Statement of Work language listed above, the following sample statements are only examples and can be used together or separately. They should be modified or otherwise tailored to meet program requirements: a. Counterfeit Parts and Materials Planning. The contractor planning shall document procedures and processes to minimize the risk of procuring and/or using counterfeit parts and materials, and their process for detecting counterfeit material in the event it is procured. This requirement applies to both new/modified and existing mission and safety critical hardware. SAE AS5553, SAE AS6174, and SAE AS6081 contain information regarding the detection, avoidance, and mitigation of counterfeit electronic components, and may be used as a reference document for the development of the plan. b. Counterfeit Parts and Materials System. The Contractor’s counterfeit electronic part avoidance and detection process shall implement policies and procedures that address:

• The training of personnel • The inspection and testing of electronic parts • Processes to abolish counterfeit parts proliferation • Mechanisms to enable traceability of parts to suppliers • Use and qualification of low risk suppliers • The reporting and quarantining of counterfeit electronic parts and suspect counterfeit

electronic parts • Methodologies to identify suspect counterfeit parts and to rapidly determine if a suspect

counterfeit part is, in fact, counterfeit • The design, operation, and maintenance of systems to detect and avoid counterfeit

electronic parts and suspect counterfeit electronic parts • The flow down of counterfeit avoidance and detection requirements to subcontractors • Process for keeping continually informed of current counterfeiting information and trends,

including detection and avoidance techniques • Process for screening GIDEP reports and other credible sources of counterfeiting

information • Control of obsolete electronic parts to maximize availability and use of authentic,

qualified electronic parts throughout product life cycle


c. Purchases from Unauthorized Suppliers. Parts and materials shall not be purchased from unauthorized suppliers (e.g. independent distributor or broker) unless there is no other means for procurement. In isolated cases when an unauthorized supplier is the only possible choice for procurement, an unauthorized supplier purchase report shall be provided to the program office. The report shall contain the following information:

• Reason why an authorized supplier or OM could not provide the part or material • Product certificate of conformance with full supply chain traceability to the OM, if

available • Verification and authenticity data results (e.g., visual inspection, marking/surface finish

permanency, DPA, Scanning Acoustic Microscopy, Energy Dispersive X-Ray • Spectroscopy, Fourier Transform Infrared (FTIR) Spectroscopy, Rockwell Hardness

Test, etc.) • Parts and materials that are part of commercial assemblies should also be procured only

from OMs or authorized suppliers. For true commercial assemblies, built and provided unmodified to multiple customers, it may not be possible to enforce these requirements as strictly.

d. Preventing Counterfeit Parts and Materials. The contractor shall take steps as defined below to minimize the risk of receiving counterfeit parts and materials.

• Maximize availability of authentic, originally designed and/or qualified parts throughout the product’s life cycle, including management of parts obsolescence

• Assess potential suppliers to minimize the risk of receiving counterfeit parts or materials

• Maintain a listing of approved suppliers with documented criteria for approval and removal of suppliers from the list

• Have purchasing procedures which require the selection of parts and materials from OM or authorized suppliers whenever possible

• Require a certificate of compliance and supply chain traceability for all electronic part purchases, and provide to the Government upon request

• Use Government or industry services such as GIDEP and other commercially available services to identify part or supplier quality or authenticity problems

• Define minimum inspection and test requirements for parts being procured from unauthorized suppliers, and shall ensure that in-house, third-party, and/or distributor inspection and test procedures and facilities comply with these requirements

• Incorporate procurement clauses which plainly identify quality requirements and liability to all approved suppliers

• Flow the requirements above to affected subcontractors • Parts and materials shall not be purchased from unauthorized sources (e.g. independent

distributor or broker) unless there is no other means for procurement. • Properly destroy or mutilate counterfeit material in accordance with DoDI 4160.21 to

ensure it will not re-enter the supply chain

e. Purchase Report (CDRL XX) shall be provided to the contracting officer/ program office. • The report shall contain the following information:

o Reason why an authorized supplier or original component manufacturer (OCM) could not provide the part or material.

o Product certificate of conformance with traceability to the OM, if available.


o Verification and authenticity data results (e.g., visual inspection, marking/surface, finish permanency, DPA, Scanning Acoustic Microscopy, Energy Dispersive X-Ray Spectroscopy, Fourier Transform Infrared (FTIR) Spectroscopy, Rockwell Hardness.

o SAE AS5553 contains information regarding the detection, avoidance, and mitigation of counterfeit electronic components, and may be used as a reference document for meeting the above steps.

f. Counterfeit Parts and Materials. The Contractor shall provide a Counterfeit Prevention Plan (CDRL XXX) that documents procedures to minimize the risk of procuring and/or using counterfeit parts and materials. This plan shall be in accordance with DFARS 252.246-7007 Contractor Counterfeit Electronic Part Detention and Avoidance and for approval by the appropriate United Stated Government contact. Solicitations and subcontracts for all suppliers shall contain a requirement for procedures to minimize the risk of procuring and/or using counterfeit parts and materials. g. Preventing Counterfeit Parts and Materials. The Contractor shall implement steps as defined in DFARS 252.246-7007 to minimize the risk of receiving counterfeit parts and materials. Parts and materials shall not be purchased from unauthorized suppliers (e.g. independent distributor or broker) unless there is no other means for procurement. In isolated cases when an unauthorized supplier is the only possible choice for procurement, a Technical Report – Study/Services, Unauthorized Supplier Purchase Report (CDRL XXXX) shall be provided to the contracting officer and the program office. h. Containing Counterfeit Parts and Materials. Suspect counterfeit parts and materials shall be impounded with all other items from the same lot. All Government users holding that part are to be located and identified so that any hardware items with the suspect part or material may be contained, pending confirmation of the part or material’s authenticity. The OM may be involved at this point in order to verify authenticity of the item in question. Confirmed counterfeit material shall be contained and provided to investigative agencies for ongoing investigation or prosecution. The counterfeit product shall not be scrapped or otherwise disposed of without approval from investigative authorities or the program office. i. Confirmed counterfeit product shall not be returned or handled in a way which would allow its resale or reuse. j. Reporting Counterfeit Parts and Materials. The primary inventory control activity (PICA) and program office shall be notified of the occurrence of a suspect or confirmed counterfeit part or material, and the actions taken to identify, contain, and impound all product from the lot. The PICA shall also contact the OM, and supplier if applicable. The PICA shall initiate and submit an Alert to the Government-Industry Data Exchange Program (GIDEP) within 60 days of knowledge of the counterfeit part or material. The PICA shall notify the appropriate parties, including investigation services, to document the case for legal action if required (e.g., contracting officer, DOD Office of Inspector General). k. Nonconforming Material and Parts. Electrical components which fail during production or acceptance testing shall be assessed to determine if the supplier of the part was an authorized supplier for the manufacturer. Analysis of these failures shall include assessment of part authenticity (potential of being counterfeit or fraudulent).


l. Seller warrants the goods delivered pursuant to this Contract, unless specifically stated otherwise in this Contract, shall (i) be new (ii) be free from defects in workmanship, materials, and design and (iii) be in accordance with all the requirements of this Contract. Seller further warrants that the performance of work and services shall conform with the requirements of this Contract and to high professional standards. All warranties in this Contract shall survive inspection, test, final acceptance and payment of goods and services.

m. Seller warrants without limitation as to time that any hardware, software and firmware goods delivered under this Contract: (i) shall not contain any viruses, malicious code, Trojan horse, worm, time bomb, self-help code, back door, or other software code or routine designed to: (a) damage, destroy or alter any software or hardware; (b) reveal, damage, destroy, or alter any data. n. Counterfeit Mitigation. Seller warrants that the goods delivered pursuant to this Contract shall (i) be and only contain materials obtained directly from the OM or an authorized OM reseller or distributor; (ii) not be or contain Counterfeit Items, as defined below; and (iii) contain only authentic, unaltered OM labels and other markings. Seller shall obtain and retain all documentation required to fully trace the distribution and sale of the goods delivered hereunder back to the relevant OM, and, on request of Buyer, shall provide such authenticating documentation. o. Seller warrants that any hardware, software and firmware goods delivered under this Contract: (i) shall not contain any viruses, malicious code, Trojan horse, worm, time bomb, self-help code, back door, or other software code or routine designed to: (a) damage, destroy or alter any software or hardware; (b) reveal, damage, destroy, or alter any data; (c) disable any computer program automatically; or (d) permit unauthorized access to any software or hardware; (ii) shall not contain any third party software (including software that may be considered free software or open source software) that (a) may require any software to be published, accessed or otherwise made available without the consent of Buyer, or (b) may require distribution, copying or modification of any software free of charge; and (iii) shall not infringe any patent, copyright, trademark, or other proprietary right of any third party or misappropriate any trade secret of any third party. p. New Materials; Anti-Counterfeit Mitigation. For Subcontractors, Contract Manufacturers, and Authorized Distributors - Only new and authentic material are to be used in products delivered to Buyer. No counterfeit or suspect counterfeit material is to be contained within the delivered product. Material shall be purchased directly from the OMs, or through the OMs Authorized Distributor. Documentation must be available that authenticates traceability to the applicable OM. Independent Distributors (Brokers) shall not be used without written consent from Buyer. q. Independent Distributors - Independent Distributor's procedures shall meet the intent of the requirements of IDEA-STD-1010 & SAE AS6081 and have a Quality Management System certified to AS9100 and/or AS9120. When available, the OM’s Certificate of Conformance and all traceability documentation shall be included with each shipment of parts. It shall include the manufacturer's name, part number, date codes, lot codes, serializations, and / or any other batch identifications. Inspections and tests required are as noted in the Subcontract. Recorded evidence of all testing performed shall be included with each shipment. If suspect/counterfeit parts are furnished under this Subcontract and are found in any of the Goods delivered hereunder, such items will be impounded by Buyer. Upon approval from the Government’s legal representative, in coordination with the proper Criminal Investigation Division representative, the Seller shall be


contacted to promptly replace such suspect/counterfeit parts with parts acceptable to the Buyer and the Seller shall be liable for all costs relating to the removal and replacement of said parts as specified in the Subcontract requirements or Distributor's insurance policies. Buyer reserves all contractual rights and remedies to address grievances and detrimental impacts caused by suspect/counterfeit parts. 2. Sample GIDEP Contract Clauses. In each contract executed for the design, development, testing, production and/or support of mission related material that exceeds $500,000 in total estimated value, and when GIDEP participation is determined to be justified, a clause similar to the following, tailored if need be to meet specific requirements, shall be included: a. The contractor shall participate in the GIDEP under the latest revision of GIDEP Requirements Guide, NAVSEA S0300-BU-GYD-010. GIDEP is an invaluable tool in the government’s war against inefficiency, and is limited to participating activities. GIDEP will retain and provide data and/or reports provided in compliance with this contract on a privileged basis. Compliance with the provisions of this clause shall not relieve the contractor from complying with other provisions of the contract. b. The contractor agrees to insert paragraph A. of this clause in any subcontract hereunder exceeding $500,000. When so inserted, the word "Contractor" shall be changed to "Subcontractor." 3. GIDEP Data Item Descriptions. The following Data Item Descriptions (DID) are active and may be used for including GIDEP in contracts. a. GIDEP Annual Progress Report: DID: DI-QCIC-80127A, Dated: 5 May 2003 “The Government Industry Data Exchange Program (GIDEP) utilization report provides participant’s reduction or elimination of unplanned expenditure from the use of information. b. Alert/Safe-Alert: DID: DI-QCIC-80125B, Dated: 5 May 2003. “The Alert/Safe Alert Report provides the government with information concerning nonconforming items, supplies, and services or safety problems which have adversely impacted, or has potential to adversely impact a Government-funded program(s). This interchange of information will help eliminate instances where individual agencies or their contractors acquire supplies and services previously identified as nonconforming by other agencies. c. Response to an Alert/Safe -Alert: DID: DI-QCIC-80126B, Dated: 5 May 2003 “The Response to the GIDEP alert/safe-alert provides information on the applicability and impact of the nonconforming supplies and services regarding the effect of the failure on systems/equipment function, mission, or safety condition.


Appendix I. Quality Assurance Checklist 1. Instructions for completing the following two Quality Assurance Checklists for prevention and detection of counterfeit material in the supply chain: Checklist 1: Assessment of Contractor Reliability to Determine Counterfeit Risk

1. Complete each question in the context of “Does the contractor have documented policies and procedures in place that address a minimum of________?” The applicable answers are Yes, No, or N/A.

2. Any answer of “No” in Checklist 1 is a risk indicator. Justify any answer of N/A in the “Evidence and Notes Section” by stating how it does not apply to the contract.

3. Evidence includes contractual requirements, industry standards, or internal (contractor specific) guidance documents.

Checklist 2: Detection of Counterfeit or Suspect Counterfeit Parts upon Receipt of Material Each lot, batch, or date code should be authenticated as a separate authentication lot. An authentication lot is defined as one shipment of a specific lot, date code, batch number, or other group identification.

1. Section 1 is to be completed for all ALL incoming Material.

a. Inspection of Documentation – Mark Yes, No, N/A for each piece of information. i. Answers of “Yes” for any line items under 1.g, 1.h, and 1.i are risk indicators

b. Visual Inspection: i. Answers of “Yes” for line items 2. and 3. are risk indicators.

2. Section 2 is to be completed for Material that is NOT purchased from OM or Authorized Supplier,

AND is Critical Material or Material known to be susceptible to counterfeiting. a. Electronic Parts:

i. Functional testing does not guarantee authenticity for electronic parts. The preferred standard for inspection and testing for electronic parts is SAE AS6081.

b. Mechanical Parts

i. There is no core set of inspections and tests that are applicable for all Mechanical Parts and Materials. The standard of avoiding and detecting counterfeit mechanical parts and materials is SAE AS6174.

ii. Sections 5.b, 5.c, and 5.d list potential tests and equipment that can be used in counterfeit detection.

3. Section 3 is to be completed for material that is suspect counterfeit.


Assessment of Contractor Reliability to Determine Counterfeit Risk

Checklist 1: Assessment of Contractor Reliability to Determine Counterfeit Risk Does the contractor have documented policies and procedures in place that address a minimum of:

Yes, No, or N/A Evidence and Notes

1 Anti-Counterfeit Personnel Training?

2 Inspection and testing of parts, with set acceptance and rejection criteria?

3 Quarantining and reporting counterfeit parts and suspect counterfeit parts?

4 Abolishing counterfeit parts proliferation and preventing their return to the supply chain?

5 Risk based tracking of part traceability from original manufacturer to product acceptance by the government?

5.a For discrete parts? 5.b For parts contained in assemblies?

5.c

If traceability from the original manufacturer cannot be established, is the contractor responsible for inspection, testing, and authentication IAW applicable industry standards?

6 Does the contractor maintain documentation of:

6.a Traceability from original manufacturer to product acceptance by government?

6.b Inspection, testing, and authentication when traceability cannot be established?

6.c Does the contractor provide this documentation to the government upon request?

7 Contractor Source of Supply: 7.a Original Manufacturer?

7.b Authorized aftermarket manufacturer? 7.c "Contractor Approved Supplier"?

7.c.1

Does the contractor ensure that "Contractor Approved Suppliers" utilize established counterfeit prevention industry standards?

7.d "Other than Contractor Approved Supplier" 7.d.1 Does the contractor notify the CO in

writing?

7.d.2 Does the contractor utilize established counterfeit prevention industry standards to obtain the part?


Checklist 1: Assessment of Contractor Reliability to Determine Counterfeit Risk Does the contractor have documented policies and procedures in place that address a minimum of:

Yes, No, or N/A Evidence and Notes

8 Identification of suspect parts?

8.a Methodologies to rapidly verify if suspect part is counterfeit?

9 Systems are designed, operated, and maintained to detect and avoid suspect and counterfeit parts?

10 Require flow down of counterfeit detection and avoidance policies to all subcontractors in the supply chain?

10.a Those responsible for buying or selling parts or assemblies?

10.b Those responsible for performing authentication testing?

11 Stay informed of current counterfeit information and trends?

11.a

Screens GIDEP reports and other credible sources of counterfeit information to avoid the purchase and/or use of suspect and counterfeit parts?

12

Maintain control of obsolete parts to maximize availability and use of authentic, originally designed, and qualified parts throughout the product's lifecycle?

13

Effective management of lead-time in procurement planning to preclude need for using unauthorized sources, and maximize procurements through authorized sources?


Checklist 2: Detection of Counterfeit or Suspect Counterfeit Parts upon Receipt of Material

Checklist 2: Detection of Counterfeit or Suspect Counterfeit Parts upon Receipt of Material Section 1: For ALL incoming material:

Initial Documentation Inspection: Yes, No, or N/A Evidence and Notes

1

Inspect all paperwork, including packaging and part labels, which accompanies the shipment. Missing or suspicious information can be based on previously received documentation for the same material.

Documentation should provide: 1.a Origin of the shipment 1.b Certification of any special testing and/or screening 1.c Any supplier performed authentication 1.d Date Codes 1.e Lot Codes

1.f Quantity Categories of counterfeit documentation include: 1.g Altered Documents :

a. Excessively faded, unclear, or missing data b. Use of correction fluid or tape c. Type size, style, or pitch change is evident d. Data on a single line is located at different heights

e. Lines on forms are bent, broken, or interrupted (indicates data has been deleted or "cut and paste")

f. Handwritten entries on a document with typed or preprinted data

g. Text on page ends abruptly h. Number of pages conflicts with the transmittal i. Other

1.h Signatures and Initials:

a. Corrections not properly lined out, initialed, and dated b. Document is not signed or initialed where required

c. The name or title of the document approver cannot be determined

d. Approver's name and signature do not match f. Document has missing or illegible signature or initials g. Other



Section 1: For ALL incoming material:

Material Authenticity Inspection/Test

Test Performed? (Yes, No, N/A)

Notes

1.i Certification :

a. Technical data is inconsistent with code or standard requirements

b. Certification/test results are identical between all tested items (normal variation should be expected)

c. Documented Certificate of Conformance and Testing is not delivered as required on the purchase order, or is in an unusual format

d. Document is not traceable to the items procured

e. Other Visual Inspection:

2 Packaging

a. Mixed internal designs in same packaging, incorrect labels, etc.

3 Markings a. Smudged Markings, Chips, Scratches, etc. Section 2: If Critical Material or Material known to be susceptible to counterfeiting, NOT purchased from OM or Authorized Supplier

Material Authenticity Inspection/Test Test

Performed? (Yes, No, N/A)

Notes

4 Electronic Parts

4.a SAE AS6081, Fraudulent/Counterfeit Electronic Parts: Avoidance, Detection, Mitigation, and Disposition - Distributors

5 Mechanical Parts and Materials (There is no core set of techniques across the board, below are examples of equipment and test methods that are useful)

5.a SAE AS6174, Counterfeit Material; Assuring Acquisition of Authentic and Conforming Material

5.b Material Visualization and Measurement

a. Stereo Microscope

b. Optical Microscope

c. Digital Microscope System

d. Scanning Electron Microscopy

e. Non-contact Measurement system

f. Contact Coordinate Measuring Machine

g. Profilometer



Section 2: If Critical Material or Material known to be susceptible to counterfeiting, NOT purchased from OM or Authorized Supplier

Material Authenticity Inspection/Test

Test Performed? (Yes, No, N/A)

Notes

5.c Alloy/Material Identification

a. Scanning Electron Microscope-Energy Dispersive Spectroscopy (SEM-EDS)

b. X-Ray Fluorescence Spectroscopy (XRF)

c. Induction Coupled Plasma Atomic Emission Spectroscopy (ICP-AES)

d. Fourier Transform Infrared Spectroscopy (FTIR) e. X-Ray Photoelectron Spectroscopy (XPS)

5.d Heat-Treatment/Finish Identification

a. Mechanical cross-section grinding and polishing b. Chemical and thermal etching of microstructure

c. Rockwell Hardness, scales A, B, C, D, and superficial

d. Micro Hardness, Knoop and Vickers Section 3: If Material is suspect:

Methods to confirm counterfeit:

Action Taken?

(Yes, No, N/A)

Notes

6 Quarantine material 7 Document multiple indicators that the material is counterfeit

8 Obtain the OM's analysis and response that the material is likely counterfeit

9 Report to Program Office, PDREP, GIDEP, etc.


Appendix J. Policy on Use of In-House Engineering and Technical Resources

DEPARTMENT OF THE ARMY OFFICE OF THE ASSISTANT SECRETARY OF THE ARMY

ACQUISITION LOGISTICS AND TECHNOLOGY 103 ARMY PENTAGON

WASHINGTON DC 20310-010

SAAL-ZT MEMORANDUM FOR SEE DISTRIBUTION SUBJECT: Policy on Use of In-House Engineering and Technical Resources

1. References:

a. Department of Defense Strategic Guidance, “Sustaining U.S. Global Leadership: Priorities for 21st Century Defense,” 5 January 2012.

b. Memorandum, Assistant Secretary of the Army (Acquisition, Logistics and

Technology) (ASA(ALT)), 9 February 2017, subject: Policy on Transition Agreements for Army Science and Technology Projects.

2. Reference 1a established the overarching strategic direction for the Department of Defense (DoD) including the imperative to sustain innovation and investment at an appropriate level, especially in a constrained fiscal environment. This strategic imperative requires focused stewardship of the DoD intellectual capital for acquiring the complex systems required by the warfighter.

a. The DoD must always have the ability to (1) understand military problems in

technical terms, (2) know who has the potential to solve those problems, and (3) when offered, technically verify a correct solution. The Department of the Army has historically made deliberate and measured investments to ensure that ability remains within the organic workforce to perform these inherently governmental functions. The Army must be a good steward of its resources and must maximize its investments. The Army must affirm that the need to establish and maintain an in-house technical capability essential to understanding the technical-cost trade space of acquisition remains relevant today.

b. During this time of strategic and budget reforms, the DoD must maximize its return

on investment of in-house technical capabilities and facilities. Consequently, this policy directs the Program Executive Officers (PEO) and their program managers (PM) to leverage the Army’s organic in-house engineering and technical resources to the fullest extent possible. It is especially important that Department of the Army scientists and engineers perform or participate significantly in the early stages of Analysis of Alternatives (AoA), in-house prototyping, experimentation, scale-model testing, and reducing risk via subsystem development and test. These tasks serve to emphasize hands-on work rather than administrative or oversight functions.


3. Policy:

a. The PMs will collaborate with organic in-house engineering and technical resources to ensure utilization of organic Army Science & Technology (S&T) and Research & Development (R&D) efforts prior to outsourcing R&D efforts to industry. Effective 30 days after the date of this memorandum, PMs are restricted from outsourcing new R&D projects unless the Army organic in-house engineering and technical resources cannot fulfill the PM’s developmental objective. The Army defines organic in-house engineering and technical resources as work performed by on-hand Government employees in government facilities at the time of the decision. It does not include out-sourced work, maintained by organic in-house engineering and technical resources. These tasks serve to emphasize hands-on work rather than administrative or oversight functions.

b. Outsourcing will require a written waiver signed by the appropriate PEO and co- signed

by the two-star S&T command (Medical Research Materiel Command, Space and Missile Defense Command Technology Center, Engineer Research Development Center or the Research, Development and Engineering Command). This signature authority cannot be further delegated. A copy of the waiver will be provided to the ASA(ALT). Waivers not agreed upon by these parties will be raised to the ASA(ALT) for adjudication and signature. The adjudication authority may be delegated.

c. Effective 30 days after the date of this memorandum, transition agreements (TAs) are

required for 6.3 S&T programs and 6.4 R&D in-house programs and can be used to document the expectations for the PM. The TAs will stipulate tangible S&T and R&D deliverables such as a developmental prototype, technical data package, specification resulting from a technology demonstration, or a transition to a Program of Record. The Deputy Assistant Secretary of the Army (Research and Technology) (DASA(R&T)) is the proponent for the TA policy, reference 1b.

d. By 90 days after the date of this memorandum, the DASA(R&T) and the Deputy for

Acquisition and Systems Management will submit a joint report on compliance with this directive to the Office of the ASA(ALT) with a by-program list for 6.3 and 6.4 efforts that includes expected expenditures and planned date of transition. Thereafter, DASA(R&T) will monitor execution of TAs.

4. The point of contact is Dr. Thomas P. Russell, 703-571-2608, DSN 671-2608 or [email protected].

mailto:[email protected]


Appendix K. Source of Supply - Manufacturer and/or Supplier Risk 1. Intent. To minimize counterfeit risk, material should always be purchased from the OEM, OCM, or an authorized supplier when available. If an unauthorized supplier is the only source, the supplier should be assessed prior to being considered an acceptable source of supply. Acquisition procedures allow the technical authority for each purchase to determine supplier suitability. Engineering and Logistics activities should maintain procurement procedures for high risk material such as an Approved Suppliers List (ASL) that is periodically updated, but at least annually to mitigate risk. 2. Risk Scale

• Original Equipment Manufacturer (OEM)/Original Component Manufacturer (OCM)

• Aftermarket Manufacturer/Supplier approved by OEM/OCM

• OEM/OCM Authorized Supplier

• Franchised Distributor

• Unauthorized Approved (Investigated/Traceability) Supplier

• Contractor verified supplier

• Independent Distributor (Unauthorized)

• Grey Market Vendors (Unauthorized)

• Distributors of excess materials (Unauthorized)


Appendix L. Risk Identification Methodologies 1. The commercial research and development and manufacturing sectors and DoD deploy a broad spectrum of risk identification approaches. These approaches can be sectioned into top-level (e.g., assessment or review of key processes and documents) or lower-level methods (e.g., brainstorming, Delphi method, diagramming methods). A more systematic method using a top-level approach combined with a variety of lower-level methods is recommended. Program and sustainment personnel should have a clear understanding of the program’s requirements, goals, plans, and supporting analysis. 2. An understanding of the following program-related documents helps program personnel identify sources of potential risk:

Acquisition and Sustainment Program Documents Analysis of Alternatives (AoA) Acquisition Program Baseline (APB) Acquisition Strategy Systems Engineering Plan (SEP) Test and Evaluation Management Plan (TEMP)

Systems Engineering Management Plan (SEMP)

Technology Readiness Assessment (TRA) Program Protection Plan (PPP) Life-Cycle Sustainment Plan (LCSP) 2.0 Life-Cycle Mission Data Plan (LMDP) Integrated Master Plan (IMP) Integrated Master Schedule (IMS) Joint Capabilities Integration and Development System (JCIDS)

Government technical requirements and specifications documents

Contract structure and provisions 3. Early and recurring communication between the user and acquisition communities involved in the development of JCIDS documents helps requirements leaders and acquisition leaders identify high risk requirements and inform potential technical risk-based trades. 4. The following lower-level approaches should be considered to help identify technical, programmatic, and business risks by government and/or contractor program teams.

• Subject Matter Expert (SME) brainstorming activities, affinity method for grouping results and other inputs, and diagramming methods (e.g., cause/effect, influence diagrams, process flow charts).

• Interviews with program team leads, SMEs, sustainment leaders and/or program stakeholders, review of lessons learned, including risks or issues on predecessor or similar programs

• Examination of new contract activity and proposals, e.g., the Integrated Baseline Review 5. Systems engineering activities.

• Systems Engineering Technical Reviews and design reviews, to include the identification of problematic requirements, immature technologies, and design shortfalls.

• Technology sources. Maturity of critical technologies and progress to technology maturation plans.

• Checklists and trigger questions focused on key processes associated with development, production, and/or support activities.

• Evaluation of results from integration and test activities. • Design changes, such as Class I Engineering Change Proposals as well as the rate of

Class I and II design changes. • Failure mode and effects analysis, fault tree analysis, and additional reliability analyses.


Appendix M. Acronyms Acronym Definition AMC Army Materiel Command AMRDEC Aviation Missile Research Development Engineering Center AR Army Regulation BOM Bill of Materials CDRL Contract Data Requirements List CG Commanding General CID Criminal Investigation Command CLL Continuous Learning Logistics CPMP Counterfeit Parts and Materials Prevention C-SCRM Cyber Supply Chain Risk Management CSI Critical Safety Item DFARS Defense Federal Acquisition Regulation Supplement DID Data Item Description DLA Defense Logistics Agency DLAD Defense Logistics Agency Directive DMEA Defense Microelectronics Activity DMSMS Diminishing Manufacturing Sources and Material Shortages DoD Department of Defense DODI Department of Defense Instruction FED Failure Experience Data FORSCOM U.S. Army Forces Command FSC Federal Supply Class or Federal Supply Classification FSG Federal Supply Group GIDEP Government-Industry Data Exchange Program HQ AMC Headquarters U.S. Army Materiel Command IAW In Accordance With IPT Integrated Product Team IT/OT Information technology/Operational Technology JFAC Joint Federated Assurance Center LCMC Life Cycle Management Commands LCSP Life Cycle Sustainment Plan LMP Logistics Modernization Program MORE Multifunctional Obsolescence Resolution Environment MSC Major Subordinate Command OEM/OCM Original Equipment Manufacturer/Original Component Manufacturer OM Original Manufacturer PDREP Product Data Reporting and Evaluation Program PEO Program Executive Office PM Program/Product/Project Manager PQDR Product Quality Deficiency Report


Acronym Definition QMS Quality Management System QSLD Qualified Suppliers List for Distributors QTSL Qualified Testing Suppliers List RDECOM Research, Development and Engineering Command RDEC Research, Development and Engineering Centers SAM System of Award Management SD Standardization Document SME Subject Matter Expert SOP Standard Operating Procedure TRADOC Training and Doctrine Command USACIDC United States Army Criminal Investigation Division Command


Appendix N. Terms Acceptable Counterfeit Electronic Part Detection and Avoidance System. The Contractor shall establish and maintain an acceptable counterfeit electronic part detection and avoidance system. Failure to maintain an acceptable counterfeit electronic part detection and avoidance system, as defined in this clause, may result in disapproval of the purchasing system by the Contracting Officer and/or withholding of payments and affect the allow-ability of costs of counterfeit electronic parts or suspect counterfeit electronic parts and the cost of rework or corrective action that may be required to remedy the use or inclusion of such parts (see DFARS 231.205-71)., DFARS 252.246-7007 August 2, 2016 Acquiring Activity. The element of the agency/command that identifies and initiates a contract requirement or may have been tasked by another agency/command to be responsible for developing the contract requirement and monitoring the acquisitions. This can either be a Government or contractor flow-down to their suppliers, MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Acquisition Activity (AA). The Government office or agency that is responsible for acquisition or modification of the military system or equipment. MIL-STD-3018 DoD Standard Practice Parts Management Aftermarket Manufacturer. A manufacturer that meets one or more of the following criteria: 1. The manufacturer is authorized by the OCM to produce and sell replacement parts, usually due to an OCM decision to discontinue production of a part. Parts supplied are produced from materials that have been a. Transferred from the OCM to the Aftermarket Manufacturer, or b. Produced by the Aftermarket Manufacturer using OCM tooling and intellectual property 2. The manufacturer produces parts using semiconductor dice or wafers, manufactured by and traceable to an OCM, that have been properly stored until use and are subsequently assembled, tested, and qualified using processes that meet technical specifications without violating the OCM’s intellectual property rights (IPR) 3. The manufacturer produces parts through emulation, reverse-engineering, or redesign, that match the OCM's specifications and satisfy customer needs without violating the OCM's IPR. In any case, the Aftermarket Manufacturer must label or otherwise identify its parts to ensure that the “as shipped "aftermarket manufactured part should not be mistaken for the part made by the OCM. AS6081 Altered Item. An item whose drawing delineates the physical alteration of the existing item under the control of another design activity or defined by a nationally recognized standard. The drawing type permits the required alteration to be performed by any competent manufacturer including the original manufacturer, the altering design activity, or a third party. It establishes a new item identification for the altered item. (In accordance with (IAW) ASME Y14.24), MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Approved Supplier. Suppliers that are assessed and determined to provide acceptable fraudulent/counterfeit parts risk mitigation process. AS6081


Authentic Material. Made from the proper materials using the proper processes with required testing. Department of Defense Instruction DODI 4140.67 DoD Counterfeit Prevention Policy Authenticity Process. The process of using inspections, tests, or other methods to determine whether a part or material has been knowingly misrepresented by a supplier and is therefore considered a counterfeit part or material. Parts or materials which pass the authenticity process are considered likely to be authentic valid versions of the item intended to have been purchased. PMAP (MDA-QS-003) Rev B Authorized Aftermarket Manufacturer. An organization that fabricates a part under a contract with, or with the express written authority of, the original component manufacturer based on the original component manufacturer’s designs, formulas, and/or specifications. DFARS 252.246-7007 August 2, 2016 Authorized Supplier. A supplier, distributor, or an aftermarket manufacturer with a contractual arrangement with, or the express written authority of, the original manufacturer or current design activity to buy, stock, repackage, sell, or distribute the part. DFARS 252.246-7007 August 2, 2016 DFARS 246.870-1 CONTRACTOR LIABILITY FOR LOSS OF OR DAMAGE TO PROPERTY OF THE GOVERNMENT (Revised August 2, 2016) Batch Number. An identifying number assigned by the enterprise to a designated group of items referred to as a batch. A batch may be a division of a lot. MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Bill of Material (BOM). A listing of parts and required quantities; electronic, electrical, mechanical, and materials used to identify repair parts or parts need to fabricate (produce) a system or assembly (see SD-22), MIL-STD-3018 DoD Standard Practice Parts Management Broker. In the independent distribution market, Brokers are professionally referred to as Independent Distributors. See definitions for “Broker Distributor” and “Independent Distributor.”. AS6081 Broker Distributor. A type of Independent Distributor that works in a “Just in Time” (JIT) environment. Customers contact the Broker Distributor with requirements identifying the part number, quantity, target price, and date required. The Broker Distributor searches the industry and locates parts that meet the target price and other Customer requirements. Broker distributors do not have contractual agreements or obligations with OCMs. (For reference only). AS6081 Certificate of Conformance and Supply Chain Traceability (CoCT). A Certificate of Conformance required by certain military specifications which requires documented supply chain traceability from the Qualified Parts List/Qualified Manufacturers List (QPL/QML) manufacturer through delivery to a government agency if the material is not procured directly from the approved manufacturer. SAE AS6081 Commercial off-the-shelf Item (COTS). A product, material, component, sub-system, or system sold or traded to the general public in the course of normal business operations at prices based on established catalog or market prices. MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property


Contract Administration Office. Also means a contract management office of the Defense Contract Management Agency, DFARS 202 subpart 202.1 Definitions August 2, 2016 Contracting Activity. For DoD also means elements designated by the director of a defense agency which has been delegated contracting authority through its agency charter. DoD contracting activities are listed at PGI 202.101. DFARS 202 subpart 202.1 Definitions August 2, 2016 Contract-Approved Supplier. A supplier that does not have a contractual agreement with the original component manufacturer for a transaction, but has been identified as trustworthy by a contractor or subcontractor. DFARS 252.246-7007 August 2, 2016 Contracting Officer's Representative. An individual designated and authorized in writing by the contracting officer to perform specific technical or administrative functions. DFARS 202 subpart 202.1 Definitions August 2, 2016 Contract Manufacturer. A company that produces goods under contract for another company under the label or brand name of that company. DFARS 252.246-7007 August 2, 2016 Corporate Baseline. A listing of parts approved by a corporation for use in equipment design application. The contractor creates and maintains this listing. MIL-STD-3018 DoD Standard Practice Parts Management Counterfeit Electronic Part. An unlawful or unauthorized reproduction, substitution, or alteration that has been knowingly mismarked, misidentified, or otherwise misrepresented to be an authentic, unmodified electronic part from the original manufacturer, or a source with the express written authority of the original manufacturer or current design activity, including an authorized aftermarket manufacturer. Unlawful or unauthorized substitution includes used electronic parts represented as new, or the false identification of grade, serial number, lot number, date code, or performance characteristics. DFARS 252.246-7007, August 2, 2016 Counterfeit Mark. The term ‘counterfeit mark’ means - ‘‘(A) a spurious mark - ‘‘(i) that is used in connection with trafficking in any goods, services, labels, patches, stickers, wrappers, badges, emblems, medallions, charms, boxes, containers, cans, cases, hangtags, documentation, or packaging of any type or nature; ‘‘(ii) that is identical with, or substantially indistinguishable from, a mark registered on the principal register in the United States Patent and Trademark Office and in use, whether or not the defendant knew such mark was so registered;‘‘(iii) that is applied to or used in connection with the goods or services for which the mark is registered with the United States Patent and Trademark Office, or is applied to or consists of a label, patch, sticker, wrapper, badge, emblem, medallion, charm, box, container, can, case, hangtag, documentation, or packaging of any type or nature that is designed, marketed, or otherwise intended to be used on or in connection with the goods or services for which the mark is registered in the United States Patent and Trademark Office; and‘‘(iv) the use of which is likely to cause confusion, to cause mistake, or to deceive; or ‘‘(B) a spurious designation that is identical with, or substantially indistinguishable from, a designation as to which the remedies of the Lanham Act are made available by reason of section 220506 of title 36; but such term does not include any mark or designation used in connection with goods or services, or a mark or designation applied to labels, patches, stickers, wrappers, badges, emblems, medallions, charms, boxes, containers, cans,

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cases, hangtags, documentation, or packaging of any type or nature used in connection with such goods or services, of which the manufacturer or producer was, at the time of the manufacture or production in question, authorized to use the mark or designation for the type of goods or services so manufactured or produced, by the holder of the right to use such mark or designation. NDAA 2012 Public Law 112-81 Counterfeit Material. An item that is an unauthorized copy or substitute that has been identified, marked, or altered by a source other than the item's legally authorized source and has been misrepresented to be an authorized item of the legally authorized source. Department of Defense Instruction DODI 4140.67 DoD Counterfeit Prevention Policy Counterfeit Part. A fraudulent part that has been confirmed to be a copy, imitation, or substitute that has been represented, identified, or marked as genuine, and/or altered by a source without legal right with intent to mislead, deceive, or defraud. NOTE: A suspect part may be determined to be, fraudulent or counterfeit through further evaluation and testing. All counterfeit parts are fraudulent, but not all fraudulent parts are counterfeit. SAE AS6081 Credible Information. Information that, considering its source and the surrounding circumstances, supports a reasonable belief that an event has occurred or will occur. DFARS 252.246-7003 Notification of Potential Safety Issues (JUN 2013) Critical Component. A component which is or contains information and communications technology (ICT), including hardware, software, and firmware, whether custom, commercial, or otherwise developed, and which delivers or protects mission critical functionality of a system or which, because of the system’s design, may introduce vulnerability to the mission critical functions of an applicable system. Department of Defense Instruction Number 5200.44 - Subject: Protection of Mission Critical Functions to Achieve Trusted Systems and Networks (TSN) Critical Material. Includes critical components as described in Reference (v), CII as described in Reference (g), CAI as described in Reference (w), critical safety items (CSI) as described in Reference (u), and other material identified by the cognizant Service engineering support activity prior to initial supportability analysis during the initial provisioning and cataloging or approval of a design change notice, and documented by the cognizant Service logistics organization. Department of Defense Instruction DODI 4140.67 DoD Counterfeit Prevention Policy Critical Safety Item. A part, subassembly, assembly, subsystem, installation equipment, or support equipment for a system that contains a characteristic, any failure, malfunction, or absence of which could have a safety impact. DFARS 252.246-7003 Notification of Potential Safety Issues (JUN 2013) Cyber Supply Chain Risk Management (C-SCRM). The process of identifying, assessing, and mitigating the risks associated with the distributed and interconnected nature of IT/OT product and service supply chains. It covers the entire life cycle of a system (including design, development, distribution, deployment, acquisition, maintenance, and destruction) as supply chain threats and vulnerabilities may intentionally or unintentionally compromise an IT/OT product or service at any stage


Defective Product. A product or the component of a product that fails to function or operate in accordance with the terms of a contract, its specifications or drawings, or with applicable Federal or military specifications. Department of Defense Instruction DODI 7050.05 Coordination of Remedies for Fraud and Corruption Related to Procurement Department of Defense (DoD) Commonly Available Parts. Parts available in the Federal Logistics Information System with current usage in one or more applications. Current usage is indicated by a steady or upward trend with expectations that it will continue to be available for the foreseeable future. Usage information may be either from the Government or manufacturer (s) of the part. Technical data describing the salient characteristics of the part is to be available to the public. Parts constructed to proprietary use documents (i.e., source control drawings, selected item drawings, altered item drawings) are not within the scope of this definition. MIL-STD-3018 DoD Standard Practice Parts Management Diminishing Manufacturing Sources and Material Shortages (DMSMS). The loss or impending loss of the last known manufacturer or supplier of raw materials, production parts, or repair parts. MIL-STD-3018 DoD Standard Practice Parts Management Direct Part Marking. Markings applied directly to an item's surface using intrusive or non-intrusive identification techniques. MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Electrical, Electronic, and Electro-mechanical (EEE) Part. Electrical, electronic, and electromechanical parts are components designed and built to perform specific functions, and are not subject to disassembly without destruction or impairment of design use. Examples of electrical parts include resistors, capacitors, inductors, transformers, and connectors. Electronic parts include active devices, such as monolithic microcircuits, hybrid microcircuits, diodes, and transistors. Electromechanical parts are devices that have electrical inputs with mechanical outputs, or mechanical inputs with electrical outputs, or combinations of each. Examples of electromechanical parts are motors, synchros, servos, and some relays. SAE AS6081 Electronic Part. An integrated circuit, a discrete electronic component (including, but not limited to, a transistor, capacitor, resistor, or diode), or a circuit assembly (section 818(f)(2) of Pub. L. 112-81). DFARS 252.246-7007 August 2, 2016 Engineering Support Activity. The Military Department organization assigned responsibility and authority to perform and approve engineering and quality assurance actions necessary to evolve detail design disclosures for systems, subsystems, equipment, and components exhibiting attributes essential for products to meet specific military requirements. During the operational phase, it includes any engineering activity, the results of which would add to or alter the design of equipment in such a manner, or to such an extent, as to change its operational capabilities or its design attributes of performance, reliability, maintainability and parts interchangeability, or to render it capable of alternative or additional use. Department of Defense Instruction DODI 4140.67 DoD Counterfeit Prevention Policy Franchised and Authorized Distributor. Transactions conducted by an OCM-Authorized Distributor distributing product within the terms of an OCM contractual agreement. Contractual Agreement terms include, but are not limited to, distribution region, distribution products or lines,


and warranty flow down from the OCM. Under this distribution, the distributor would be known as an Authorized Distributor. For the purposes in this Standard, Franchised Distribution is considered synonymous with Authorized Distribution. SAE AS6081 Fraudulent Part. Any suspect part misrepresented to the Customer as meeting the Customer’s requirements. SAE AS 6081 Government-Industry Data Exchange Program (GIDEP). A cooperative activity between government and industry participants seeking to reduce or eliminate expenditures of resources by sharing technical information essential during research, design, development, production and operational phases of the life-cycle of systems, facilities, and equipment. Department of Defense Instruction DODI 4140.67 DoD Counterfeit Prevention Policy. High Risk. Material that has previously been counterfeited or is susceptible to counterfeiting and has an end use or application where the success or security of the mission, or safety of the warfighter, depends on the continued reliable function of the material. Material often at high risk of counterfeiting includes: Integrated circuits, Discrete semiconductors (e.g., transistors, diodes, optocouplers), High voltage, high value, or specialty (e.g., low ESR, high Q, trimmer) capacitors, Mechanical roller bearings, Specialty fasteners, Lubricants, Adhesives, Batteries, Other materiel identified in Government-Industry Data Exchange Program(GIDEP) or Product Data Reporting and Evaluation Program (PDREP) reports as susceptible to being counterfeited. NAVSO P-7000 Independent Distributor. A distributor that purchases parts with the intention to sell and redistribute them back into the market. Purchased parts may be obtained from OEMs or Contract Manufacturers (typically from excess inventories), or from other Distributors (Franchised, Authorized, or Independent). Resale of the purchased parts (redistribution) may be to OEMs, Contract Manufacturers, or other Distributors. Independent Distributors do not normally have contractual agreements or obligations with OCMs. SAE AS6081 Intensive Item Management. A system that establishes varying levels of item management facilitated by the use of a UII ranging from the use of existing receipt and acceptance regulations to providing a detailed chain of custody involving strict accountability and tracking, by UII, of these items while in receipt, physical inventory, and issue. Department of Defense Instruction DODI 4140.67 DoD Counterfeit Prevention Policy Interdiction. Using focused targeting and inspections to keep counterfeit and pirated goods out of U.S. supply chains, markets and streets. Item. A single hardware article or a single unit formed by a grouping of subassemblies, components, or constituent parts. (IAW DFARS 252.211-7003), MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Life Cycle. The life of an acquisition program consists of phases, each preceded by a milestone or decision point, during which a system goes through research, development, test, and evaluation (RDT&E); production; fielding or deployment; sustainment; and disposal. Currently, the five phases are: 1. Material Solution Analysis (MSA); 2. Technology Maturation and Risk Reduction (TMRR); 3. Engineering and Manufacturing Development (EMD); 4. Production and Deployment (P&D); 5. Operations and Support (O&S)


Manufacturer (MFR). An individual, company, corporation, firm, or Government activity who controls the production of an item; or produces an item from crude or fabricated materials; or assembles materials or components or parts, with or without modification, into a more complex item. MFR may be used in this document as an abbreviation of the term manufacturer. MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Material. Includes material as defined in Reference (g), system components, sub-components, software, information and communications technology as described in Reference (v), support equipment and systems purchased, procured or contracted or incorporated into the DoD supply chain for weapon and information systems, DoD business processes and DoD operational support. Department of Defense Instruction (DODI) 4140.67 DoD Counterfeit Prevention Policy Non-Conforming Product. A product or the component of a product that has not been manufactured, assembled, tested, or inspected in accordance with the terms of a contract, its specifications, or drawings, including military specifications. Department of Defense Instruction (DODI) 7050.05 Coordination of Remedies for Fraud and Corruption Related to Procurement Activities Non-Developmental Item (NDI). System or equipment available from a wide variety of sources with little or no development effort required by the Government (see FAR 2.101). MIL-STD-3018 DoD Standard Practice Parts Management Obsolete Electronic Part. An electronic part that is no longer available from the original manufacturer or an authorized aftermarket manufacturer. DFARS 252.246-7007 Original Component Manufacturer (OCM). An organization that designs and /or engineers a part and is entitled to any intellectual property rights to that part. DFARS 252.246-7007 Original Design Activity (ODA). The design activity originally responsible for the design and identification of an item whose drawing number and activity identification is shown in the title block of the drawings and associated documents. (IAW ASME Y14.100), MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Original Equipment Manufacturer (OEM). A company that manufactures products that it has designed from purchased components and sells those products under the company’s brand name. DFARS 252.246-7007, SAE AS6081 Original Manufacturer. The original component manufacturer, the original equipment manufacturer, or the contract manufacturer. DFARS 252.246-7007 Part. One or more pieces joined together, which are not normally subject to disassembly without destruction or impairment of intended design use. SAE AS6081 Parts List. A listing of all parts used in design or construction of the military system or equipment. Initially, it contains those items designed into the system. Upon production, it contains those items that are incorporated into the actual unit(s) produced. MIL-STD-3018 DoD Standard Practice Parts Management


Parts Management. The practice of considering the application, standardization, technology (new and aging), system reliability, maintainability, supportability, and cost in selecting parts and addressing availability, logistics support, DMSMS, and legacy issues in supporting them throughout the life of the systems. MIL-STD-3018 DoD Standard Practice Parts Management Product Data Reporting and Evaluation Program (PDREP). The Department of the Navy program that supports requirements regarding the reporting, collection and use of supplier performance information identified in the Code of Federal Regulations (CFR), Federal Acquisition Regulations (FAR), Defense Federal Acquisition Regulation Supplement (DFARS) and Navy regulations. PDREP supports Navy management of the supply chain ensuring first time quality and on-time delivery of materials for both critical and non-critical applications. SECNAV Instruction 4855.3 Product Quality Deficiency Report (PQDR). Product Quality Deficiency Reports (PQDR) are used to determine the cause of discrepancies, effect corrective action and prevent recurrences as required by the Product Quality Deficiency Report Program, DLAR 4155.24, otherwise known as the Joint Regulation. PQDRs will be submitted for deficiencies detected on new or newly reworked government-owned products that do not fulfill their expected purpose, operation, or service due to deficiencies in design, specification, material, software, manufacturing process, and/or workmanship. NAVSOP 3683 Product Substitution. Substitution of a product or a component of a product that does not fully comply with all contract requirements. Department of Defense Instruction (DODI) 7050.05 Coordination of Remedies for Fraud and Corruption Related to Procurement Program Protection. The Department of Defense’s "integrating process for mitigating and managing risks to advanced technology and mission-critical system functionality from foreign collection, design vulnerability, or supply chain exploitation/insertion, battlefield loss, and unauthorized or inadvertent disclosure throughout the acquisition lifecycle." (DAG Chapter 13) QDR Category I Deficiency Report. A report of a product quality deficiency which may cause death, injury or severe occupational illness; would cause loss or major damage to a weapon system; critically restricts the combat readiness capabilities of the using organization; or which would result in a production line stoppage. AR 702-7-1 QDR Category 2 Deficiency Report. A report of a product quality deficiency that does not meet the criteria set forth in Category I. AR 702-7-1 Qualified Products List (QPL), Qualified Manufactures List (QML), and Qualified Bidders List (QBL). Qualification and listing in a QPL, QML, or QBL is the process by which products are obtained from manufacturers or distributors, examined and tested for compliance with specification requirements, or manufacturers or potential offerors, are provided an opportunity to demonstrate their abilities to meet the standards specified for qualification. The names of successful products, manufacturers, or potential offerors are included on lists evidencing their status. Generally, qualification is performed in advance and independently of any specific acquisition action. After qualification, the products, manufacturers, or potential offerors are included in a Federal or Military QPL, QML, or QBL. (48 CFR Part 9, Subpart 9.203 (a) - Qualifications Requirements, Department


of Defense, Defense Contract Management Agency Instruction (DCMA-DoDI) 1205 Counterfeit Mitigation Qualified Supplier. A commercial business that has completed the formal process for requesting, evaluating, and approving the capability of a supplier and has met the qualification requirements stated in the applicable military, federal or non-government specification for testing or other quality assurance demonstration that must be completed by an offer or before award of a contract. Department of Defense Instruction 4140.67 DoD Counterfeit Prevention Policy Remediation. The process of determining the cause and effects of counterfeit items on personnel safety and material readiness, the assessment of damages incurred, and the estimate of the costs to cure the effects incurred. Department of Defense Instruction 4140.67, DoD Counterfeit Prevention Policy Remedies. Criminal, civil, contractual, and administrative actions that should be initiated by a commander or official having responsibility over a matter central to a significant procurement fraud case in order to protect DoD interests and to deter future incidents of fraudulent conduct. Department of Defense Instruction 7050.05, Coordination of Remedies for Fraud and Corruption Related to Procurement Remedies Plans. Comprehensive, evolving plans prepared for pursuing all applicable remedies in significant procurement fraud cases. These plans are updated periodically to report new information and provide the status and success of all applicable remedies. Department of Defense Instruction 7050.05 Coordination of Remedies for Fraud and Corruption Related to Procurement Restitution. The process of determining the parties accountable to counterfeiting, the judicial penalties available against the parties accountable, and the financial redress required. Department of Defense Instruction 4140.67, DoD Counterfeit Prevention Policy Risk-Based Approach. An analytical strategy to focus attention on areas or applications where failure will produce higher severity of consequences and trigger impacts to the overall mission objectives and human safety. Department of Defense Instruction 4140.67, DoD Counterfeit Prevention Policy Safety Impact. The occurrence of death, permanent total disability, permanent partial disability, or injury or occupational illness requiring hospitalization; loss of a weapon system; or property damage exceeding $1,000,000. DFARS 252.246-7003 Notification of Potential Safety Issues Significant Investigations of Fraud or Corruption Related to Procurement Activities (Significant Investigations). Fraud investigations involving an alleged loss of $500,000 or more; all investigations of corruption involving bribery, gratuities, or conflicts of interest; all defective product, non-conforming product, or product substitution investigations involving a serious hazard to health, safety, or operational readiness; and investigations otherwise determined to be significant by the cognizant agency official. Department of Defense Instruction 7050.05, Coordination of Remedies for Fraud and Corruption Related to Procurement Source Control Item. An item whose source control drawing provides an engineering description, qualification requirements, and acceptance criteria for commercial items or vendor-developed


items procurable from a specialized segment of industry, that provide the performance, installation, interchangeability, or other characteristics required for critical applications. The drawing provides a list of approved sources of supply and the vendor's item identification for the item(s) that have been qualified and approved for use in the critical application(s). The source control drawing establishes the source control item identification. (IAW ASME Y14.24), MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Subcontractor. Any supplier, distributor, vendor, or firm that furnishes supplies or services to or for the Contractor or another subcontractor under this contract. DFARS 252.246-7003 Notification of Potential Safety Issues Supply Chain. The linked activities associated with providing material from a raw material stage to an end user as a finished product or system, including design, manufacturing, production, packaging, handling, storage, transport, mission operation, maintenance, and disposal. Department of Defense Instruction 4140.67, DoD Counterfeit Prevention Policy Supply Chain Traceability. Documented evidence of a part’s supply chain history. This refers to documentation of all supply chain intermediaries and significant handling transactions, such as from OCM to distributor, or from excess inventory to broker to distributor. SAE AS6081 Suspect. A part in which there is an indication that it may have been misrepresented by the supplier or manufacturer and may meet the definition of fraudulent part or counterfeit part provided below. SAE AS6081 Suspect Counterfeit. Material, items, or products in which there is an indication by visual inspection, testing, or other information that it may meet the definition of counterfeit material provided herein. Department of Defense Instruction 4140.67, DoD Counterfeit Prevention Policy Suspect Counterfeit Electronic Part. An electronic part for which credible evidence (including, but not limited to, visual inspection or testing) provides reasonable doubt that the electronic part is authentic. DFARS 252.246-7007, August 2, 2016 Suspect Item. An item in which visual inspection, testing, or other means indicate that it may not conform to established Government or industry-accepted specifications or national consensus standards, or one whose documentation, appearance, performance, material or other characteristics may have been misrepresented by the supplier or manufacturer. DOE in a 2004 Suspect/Counterfeit Items Guide Suspect Material. Material, items, or products in which there is an indication by visual inspection, testing, or other information that it may meet the definition of fraudulent part or counterfeit material. SAE AS6174A System Security Engineering. An element of system engineering that applies scientific and engineering principles to identify security vulnerabilities and minimize or contain risks associated with these vulnerabilities." (DoD Instruction 5200.44) Traceability. The process that connects the requirement to design implementation in parallel with life-cycle management events related to systems development, acquisition, property accountability,


storage, operation, maintenance, safety, physical security, retirement, and disposal by commodity, e.g., a stock numbered product, a lot or batch of a product, a single instance of a stock numbered product, a single assembly or sub-assembly, an end item type, or a single instance of an item. Department of Defense Instruction 4140.67 DoD Counterfeit Prevention Policy Trusted Foundry Program. The DoD Trusted Foundry program provides a cost-effective means to assure the integrity and confidentiality of integrated circuits (ICs) during design and manufacturing while providing the U.S. Government with access to leading edge microelectronics technologies for both Trusted and non-sensitive applications. "Trusted" is the confidence in one's ability to secure national security systems by assessing the integrity of the people and processes used to design, generate, manufacture and distribute national security critical components (i.e. Microelectronics). The highest possible classification level of these components will be SECRET. sdhttps://www.dodtechipedia.mil/dodwiki/display/TFP/Trusted+Foundry+Program Unbroken Chain of Custody. Verifiable evidence of chronological documentation without gaps, showing the custody control, transfer, and traceability to the OCM or OEM. Unique Item Identifier (UII). The formatted data derived from the encoded in an item unique identification (IUID) compliant data matrix bar code symbol used by IUID. The UII is intended to be a permanent mark placed on a single instance of an item of material and cannot be changed over the life of that item, Department of Defense Instruction DODI 4140.67 DoD Counterfeit Prevention Policy Vendor Item Control Items. A vendor item whose control drawing provides an engineering description and acceptance criteria for commercial items or vendor-developed items that are procurable from a specialized segment of industry. The vendor's PIN, along with the vendor's design activity identification (DAI) is the item identification. It provides a list of suggested source(s) of supply, the vendor's item identification, and sufficient engineering definition for acceptance of interchangeable items within specified limits. The vendor item control drawing number with suffixed identifier, if applicable, establishes the administrative control number(s) for identifying the item(s) on engineering documentation. (IAW ASME Y14.24), MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Verification. The process for assessing the quality of a machine-readable symbol and assigning a grade to the results or otherwise indicating acceptance in accordance with the applicable specification or MRI protocol quality control document. Verification is performed using an electronic/optical verification device. (IAW Department of Defense Guide to Item Unique Identification Quality Assurance), MIL-STD-130N DoD Standard Practice Identification Marking of US Military Property Verification Investigation. An investigation, whether or not it is a significant investigation, to verify that the misconduct and the damages resulting from the misconduct were not greater than described and quantified in the report of investigation or estimate of damages provided by the contractor in connection with a voluntary disclosure admitted under the DoD Voluntary Disclosure Program. DoDI 7050.05 Coordination of Remedies for Fraud and Corruption Related to Procurement Activities

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