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Detection and Avoidance of Counterfeit Electronic Parts— Further Implementation

Detection and Avoidance of Counterfeit Electronic Parts— Further Implementation. Public Meeting June 16, 2014 Scott Bousum, Director, National Security Policy, TechAmerica. TechAmerica & DIB Interests. Represent companies in the DIB, IT and COMM Sectors

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Detection and Avoidance of Counterfeit Electronic Parts— Further Implementation

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  1. Detection and Avoidance of Counterfeit Electronic Parts—Further Implementation Public Meeting June 16, 2014 Scott Bousum, Director, National Security Policy, TechAmerica

  2. TechAmerica & DIB Interests • Represent companies in the DIB, IT and COMM Sectors • Hardware manufacturers, integrators and operators • Commercial as well as Public Sector companies • Our members are on the leading edge of detection and avoidance of counterfeits

  3. Goals • Convey need for flexible systems, based on company-unique circumstances, to detect and avoid counterfeit parts • Strict compliance unworkable and disruptive to the supply chain • Need to avoid multiple interpretations of new standards • Clarification on extent DCMA takes DIB’s use of risk based analysis (RBA) • Clarity around flow down issue as it relates to non-CAS covered suppliers

  4. Questions Facing Industry • When will guidance from DCMA on Contractor Purchasing System Reviews (CPSR) be forthcoming? • Will Industry be able to offer input on this guidance? • How will DCMA administer the requirements of this rule? • Through individual contracting officers? • Special Audits?

  5. Questions Facing Industry • Will DCMA train government personnel to a common standard? • Will there be some backward looking review to ensure uniform application of this standard?

  6. Questions Facing Industry • What are the requirements for traceability and authentication for parts already in inventory? • Many parts are acquired in “pool buys,” not associated with a specific government contract, and commingled with other parts in inventory. • Will industry have to trace each of these parts?

  7. Questions Facing Industry • If tracing each part in inventory is not possible, will Industry have to test each part individually? • Or will Industry have to purge current inventory because of the costs to authenticate?

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