By Darrell Oyer, Darrell J. Oyer & Co.:
DOD is yet to issue new regulations aimed at finding and removing counterfeit parts from the defense supply chain. The regulations would create definitions specific to counterfeit parts, define contractors’ responsibilities and explain how the federal government will require contractor business systems to comply.
Congress mandated the regulations which will require that the costs of finding and replacing counterfeit parts be on contractors who must implement the rules thorough inspection regime to prevent the parts from entering the supply chain.
Specifically the regulations would:
(1) ensure that prime contractors and subcontractors notify program managers when critical items are not obtained from an original manufacturer or authorized distributor;
(2) establish testing and verification requirements for contract items that do not come from an original manufacturer;
(3) ensure contractors and subcontractors report suspected counterfeit items into the Government-Industry Data Exchange Program (GIDEP), which DOD will use as a central reporting database and
(4) report counterfeit items to criminal authorities.