Anti-Counterfeiting

About

An increasing threat of counterfeit (and fraudulent) parts in the global marketplace affects every component of the program from commercial-off-the-shelf (COTS) assemblies to military-unique systems. Preventing counterfeit parts from entering the supply chain reduces cost and negative impacts to program schedule and system performance. DoDI 4140.67 ???DoD Counterfeit Prevention Policy??? provides direction for anti-counterfeit measures for DoD weapon and information systems acquisition and sustainment to prevent the introduction of counterfeit materiel.

Counterfeit parts are becoming pervasive in various supply chains and therefore have become a significant threat to the Defense supply chain. Counterfeiters??? motives are primarily greed (profit) and/or malicious intent. Counterfeits may appear at all phases of the life cycle, making it necessary for the Program Manager (PM), Systems Engineer, and Product Support Manager to plan for prevention, detection, remediation, reporting and restitution activities from the beginning of the life cycle to disposal and demilitarization.

In order to properly assess the risks of counterfeit products, the PM needs to be aware that anti-counterfeit activities have relationships, as described in Systems Engineering (SE) Guidebook, Table 5-3: Anti-Counterfeit Design Considerations Relationships, with many of the other design considerations outlined in SE Guidebook, Section 5 Design Considerations, such as:

SE Guidebook, Table 5-3: Anti-Counterfeit Design Considerations Relationships

Design Consideration Relationship
Commercial-Off-the-Shelf (COTS) The Government and its industry agents have little to no visibility into the supply chains that create COTS products. Implications of this lack of visibility into the supply chain include counterfeit vulnerabilities and counterfeit parts being more readily available.
Corrosion Prevention and Control (CPC) Counterfeits, by their nature, may have been falsely certified. In addition, if the counterfeit is a compound/material or component (e.g., gaskets, ground wires) intended to prevent or reduce corrosion, then effects of wear may appear sooner than predicted and the impacts to the system may be worse than expected or catastrophic.
Critical Safety Items (CSI) From an anti-counterfeiting risk-based approach, CSIs should be more carefully scrutinized to ensure no counterfeits infiltrate the supply chain.
Cybersecurity Cybersecurity in the supply chain cannot be viewed as an IT problem only. Cyber supply chain risks touch sourcing, vendor management, supply chain continuity and quality, transportation security, and many other functions across the enterprise and require a coordinated effort to address. (National Institute of Standards and Technology (NIST), Cyber Supply Chain Best Practices).
Demilitarization and Disposal An excellent source for counterfeiters to obtain parts that can be turned into "used sold as new" parts (fraudulently certified as new).
Diminishing Manufacturing Sources and Material Shortages (DMSMS) As systems age and the trustworthy sources for the piece parts dry up, counterfeiters increasingly take advantage of the situation by offering a source for hard-to-find parts.
Item Unique Identification (IUID) Successful implementation of IUID could reduce the ability of counterfeiters to introduce parts into supply. Conversely, IUID may provide a false sense of security if it can be duplicated by counterfeiters.
Manufacturing and Quality Manufacturing and Quality can be severely degraded if supply is contaminated with counterfeits.
Modular Open Systems Approach (MOSA) MOSA could provide a means to quickly certify a newer, more available part for use in systems, thus reducing the impact of DMSMS. Conversely, it could also result in more part numbers (equivalents) being introduced into supply, thus increasing the likelihood of counterfeit intrusion.
Reliability and Maintainability Engineering Counterfeits that somehow get past receipt inspection and test can have radically different reliability and failure modes than the "honest" part.
Supportability Increased failure rates due to counterfeits can have a negative impact on supportability and might drive the wrong problem-resolution behaviors and increase sustainment costs.
System Safety (including Environment, Safety and Occupational Health (ESOH)) Several examples of counterfeit materials that can increase ESOH risks include: false R-134, a refrigerant which produces explosive by-products; fire extinguishers compressed with air; and faulty smoke detectors. Furthermore, Restriction of Hazardous Substances (RoHS) (2002/95/EC) has led to increased numbers of counterfeits, where a lead-free (Pb-free) microcircuit is sold as having tin-lead (SnPb) leads.
System Security Engineering (SSE) SSE implements anti-counterfeit protection measures as part of a comprehensive plan to protect CPI and mission-critical functions and components. (See Technology & Program Protection (T&PP) Guidebook (forthcoming)).

During development of the Systems Engineering Plan (SEP) and Program Protection Plan (PPP), the PM, Systems Engineer and Product Support Manager should consider these relationships and develop plans to address the threat.

Products and Tasks

Product Tasks
10-3-1: Develop and document counterfeit countermeasures in program system engineering plan (SEP) and program protection plan (PPP)
  1. Obtain the system???s technical data package.
  2. Identify critical technologies and mission-critical functions / components, critical safety items, electronic parts and components for the system.
  3. Identify risks of counterfeit parts risk for identified components.
  4. Document identified counterfeit parts risk and recommend countermeasures for mission critical components.
  5. Provide recommended countermeasures to decision maker.
  6. Document approved countermeasures in the program protection plan (PPP) and the program???s systems engineering plan (SEP).

Source: AWQI eWorkbook

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Key Terms

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