Reference:  252.246-7007 Contractor Counterfeit Electronic Part Detection and Avoidance System (May 2014)  http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/dfars/dfars252_246.htm#P342_27651   ,  per  246-872-3 - http://www.acq.osd.mil/dpap/dars/dfars/html/current/246_8.htm#246.870-3 

 

I am interested in initiating a discussion about the above referenced DFARS Counterfeit Parts clause in DoD contracts.  Some of the concerns I have are:

 

-  What is the appropriate department for ownership of this requirement? Sponsored Programs, Purchasing, Property, Capital Assets etc.  Perhaps a partnership?

-  Who can validate the parts received are not counterfeit?

-  How is the university going to handle the unallowable cost of replacing a counterfeit part?

-  How do you manage subcontractor compliance?  (The clause is a mandatory flow down) 

-  Who manages and documents training?

-  Would this be an interesting topic at one of the professional group meetings coming up this fall?

 

Here’s a little information about the clause taken straight from the DFARS.

 

Applicability:  Contractors that are subject to the Cost Accounting Standards (CAS) and that supply electronic parts or products that include electronic parts and their subcontractors that supply electronic parts or products that include electronic parts, are required to establish and maintain an acceptable counterfeit electronic part detection and avoidance system. Failure to do so may result in disapproval of the purchasing system by the contracting officer and/or withholding of payments (see 252.244-7001, Contractor Purchasing System Administration - http://www.acq.osd.mil/dpap/dars/dfars/html/current/252244.htm ). 

 

1.            Training of personnel

2.            Inspection and testing of electronic parts

3.            Use of suppliers that are the original manufacturer, sources with the express written authority of the original manufacturer or current design activity, including an authorized aftermarket manufacturer or suppliers that obtain parts exclusively from one or more of these sources

4.            Processes for maintaining electronic part traceability

5.            Flow down of counterfeit detection and avoidance requirements

6.            Methodologies to identify suspect counterfeit electronic parts and to rapidly determine if a suspect counterfeit electronic part is, in fact, counterfeit;

7.            Design, operation, and maintenance of systems to detect and avoid counterfeit electronic parts and suspect electronic parts

8.            Processes to abolish counterfeit parts proliferation

9.            The reporting and quarantining of counterfeit electronic parts and suspect counterfeit electronic parts

10.          Process for keeping continually informed of current counterfeiting information and trends 

11.          Process for screening the Government-Industry Data Exchange Program (GIDEP) reports and other credible sources of counterfeiting information

12.          Control of obsolete electronic parts

 

Feel free to contact me directly.

 

Dana Simpson

Director, Office of Sponsored Programs

Georgia Institute of Technology

505 10^th Street

Atlanta, Georgia 30318-0420

Phone: (404)894-6934

FAX: (404)385-0864