1 Counterfeit Avoidance Where will the road lead? Bob Bodemuller Supplier Quality Principle Engineer.

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Presentation transcript:

1 Counterfeit Avoidance Where will the road lead? Bob Bodemuller Supplier Quality Principle Engineer

2 Can You Tell the Difference?

3 Traceability FY 2015Percent Trading PartnerMSRP of Total China$ 697,083,700 52% Hong Kong$ 472,331,251 35% Singapore$ 10,267,324Less than 1% India$ 6,409,028 Less than 1% United Kingdom$ 4,358,128Less than 1% Korea$ 3,788,572 Less than 1% United Arab Emirates$ 3,432,950 Less than 1% Italy$ 2,849,267 Less than 1% Malaysia$ 2,345,427 Less than 1% Canada$ 1,973,812 Less than 1% All Others$ 147,655,882 11% Total FY 2015 MSRP$ 1,352,655,882Total FY 2014 MSRP$ 1,226,347,540 Number of Seizures28,865 Number of Seizures23,140 Data from: Intellectual Property Rights Seizure Statistics Fiscal Year 2015 China and Hong Kong made up 87% of 2015 seizures Source by Manufacturer’s Suggested Retail

4 Why is this issue so difficult? Aging systems resulting in obsolescence – –Diminishing Sources for parts Economic – –Cost – –Schedule pressures – –Minimum Buys Sources of parts – –Authentic parts manufactured in Asia – –Profitable and growing capability to counterfeit – –Organized crime Counterfeits more difficult to detect – –May not affect fit, form or function – –Tests, visuals and failure analysis may not detect counterfeits are good & getting better … Counterfeiters are good & getting better … They are fast and agile

5

6 Pending Regulations DFARS 2014-D005 – Further Implementation – –Released for public comment 9/21/15 – –Defines “Trusted Supplier” – –Requires traceability from OCM to product acceptance by the government DFARS 2015-D020 – Trusted Suppliers for Electronic Parts – –Focus on the requirement that DoD shall obtain electronic parts from trusted suppliers, and establish qualification requirements pursuant to which DoD may identify trusted suppliers DFARS 2016-D010 – Cost of Remedy for Use or Inclusion of Counterfeit Electronic Parts – –Amends c)(2)(B) with regard to the allowability of costs of counterfeit electronic parts or suspect counterfeit electronic parts and the cost of rework or corrective action that may be required to remedy the use or inclusion of such parts. DFARS 2016-D013 – Amendments Related to Trusted Suppliers – –makes contractor and subcontractor identification and use of additional trusted suppliers subject to approval (as well as review and audit) by appropriate DoD officials. Many questions … lots of confusion

7 Trusted Suppliers Proposed Rule, DFARS Case 2014-D005 – –Trusted supplier means: (1) The original manufacturer of a part; (2) An authorized dealer for the part; (3) A supplier that obtains the part exclusively from the original component manufacturer of the part or an authorized dealer; or (4) A supplier that a contractor or subcontractor has identified as a trustworthy supplier, using DoD-adopted counterfeit prevention industry standards and processes, including testing What is exclusively? How do you “identify”… audit/certification?

8 Traceability Proposed Rule, DFARS Case 2014-D005 (4) Processes to— – –(i) Enable tracking of electronic parts from the original manufacturer to product acceptance by the Government, whether the electronic parts are supplied as discrete electronic parts or are contained in assemblies; … How? Does AS5553B comply?

9 INDUSTRY STANDARDS

10 Industry Consensus Standards G-19 – –G-19ATestingAS6171 – –G-19ADAuthorized DistributionAS6496 – –G-19CComplianceVarious – –G-19CIOCM, System Integrators, etc.AS5553 – –G-19DIndependent DistributionAS6081 – –G-19TDefinitionsAIR6273 G-21 MaterialsAS6174 Standards look in review view mirror. Potentially give counterfeiters the blueprint for detection Is an industry consensus standard based approach realistic for DFARS compliance? Make it data driven? How will AS9100 play with these requirements?

11 Lockheed MFC Strategy

12 Lockheed Martin Definition – –(a) definition of counterfeit “work” – –… means Work that is or contains unlawful or unauthorized reproductions, substitutions, or alterations that have been knowingly mismarked, misidentified, or otherwise misrepresented to be an authentic, unmodified part from the original manufacturer, or a source with the express written authority of the original manufacturer or current design activity, including an authorized aftermarket manufacturer… Applies to all materials not just electronic parts

13 MFC Counterfeit Strategy Corporate Counterfeit Working Group MemberCorporate Counterfeit Working Group Member Influence procedures to improve risk mitigation processes Align CRX-126, Counterfeit Electronic Parts and Material with MFC contractual requirements Subject Matter Expertise Communications in place to include Legal, DCMA, GSC, QMS, etc.Communications in place to include Legal, DCMA, GSC, QMS, etc. Engaged with “new business” to examine counterfeit mitigation as a market discriminator Nexpert identified Knowledge Transfer & Communication Partnered with GSC/programs to review supplier changes to Corp Docs and text notes Perform supplier surveys as required Supplier Engagements Developed MFC control plan for all “work” MFC command media aligns with CRX-126 requirements, i.e. DFARS Review and update training Command Media & Business Processes Risk Analysis & PrioritizationRisk Analysis & Prioritization Proactive ValidationsProactive Validations Survey & Audit ActivitySurvey & Audit Activity Material Risk Mitigation Educate, Communicate & Drive Risk Prevention Measures

14   Traditional industry systems and methods were not designed to detect deliberate and deceptive product alterations   Threat is Real & Growing …Prevention Methods must Out Pace the Threat   Continue to Evolve, Educate, Communicate & Enforce Prevention Measures   Government requirements are growing for counterfeit avoidance systems at all tiers of the supply chain Summary

15 Questions Contact Info: Bob Bodemuller