4.3.18.3. Anti-Counterfeiting
4.3.18.3. Anti-Counterfeiting
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. “Overarching DoD Counterfeit Prevention Guidance” policy memorandum was signed by USD(AT&L) on March 16, 2012.
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, 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.
Anti-counterfeit activities have relations, as describe in Table 4.3.18.3.T1, with many of the other design considerations outlined in DAG section 4.3.18. Design Considerations, such as:
Table 4.3.18.3.T1. Anti-Counterfeit Design Consideration Relationships
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Design Consideration
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Relationship
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Commercial-Off-the-Shelf (COTS)
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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.
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Corrosion Prevention and Control (CPC)
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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.
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Critical Safety Items (CSI)
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From an anti-counterfeiting risk-based approach, CSI should be more carefully scrutinized to ensure no counterfeits infiltrate the supply chain.
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Demilitarization and Disposal
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An excellent source for counterfeiters to obtain parts that can be turned into “used sold as new” parts (fraudulently certified as new).
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Diminishing Manufacturing Sources and Material Shortages (DMSMS)
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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.
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Environment, Safety, and Occupational Health (ESOH)
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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.
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Item Unique Identification (IUID)
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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.
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Open Systems Architecture (OSA)
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OSA could provide a means to quickly certify a newer, more available part for use in weapon 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.
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Producibility, Quality, and Manufacturing (PQM)
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PQM can be severely degraded if supply is contaminated with counterfeits.
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Reliability and Maintainability Engineering
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Counterfeits that somehow get past receipt inspection and test can have radically different reliability and failure modes than the “honest” part.
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Supportability
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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.
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System Security Engineering (SSE)
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SSE implements anti-counterfeit protection measures as part of a comprehensive plan to protect CPI and mission-critical functions and components.
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During development of the Systems Engineering Plan (SEP), the Program Manager, Systems Engineer, and Product Support Manager should consider these relationships and develop plans to address the threat.
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