1. Fermilab Suspect / Counterfeit Item Identification Training

2. Introduction What are Suspect & Counterfeit Items (S/CI)? Suspect/Counterfeit Items are items which have been or may have been misrepresented to make them seem to be something they aren’t. The goal is to make lower cost materials appear to meet quality or performance specifications that they do not meet. 2

3. Introduction What is the real risk of using Suspect / Counterfeit Items? Items may be substandard and unfit for use They may not perform as expected They may fail, causing death or injury, equipment damage and/or downtime 3

4. Learning Objectives At the conclusion of this training, you should be able to… 1. Name three common attributes of components and products that make them most vulnerable to being misrepresented. 2. Describe some of the tactics for introducing S/CI into a sale. 3. Discuss how counterfeit piping components can be identified. (continued…) 4

5. Learning Objectives (continued) At the conclusion of this training, you should be able to… 4. Understand how molded-case circuit breakers may be refurbished and sold as new and name some common indicators that electrical devices may be suspect 5. Describe the use of DOE’s Manufacturers’ headmark list for fasteners and name some indicators of S/C fasteners. 6. Describe common indicators of S/CI hooks or shackles. (continued…) 5

6. Learning Objectives (continued) At the conclusion of this training, you should be able to… 7. Name several ways of detecting falsified documentation. 8. Name lesser-known types of S/CI discovered at DOE sites. 9. Describe some visual signs of S/CI and inspection techniques to screen for misrepresented items. (continued…) 6

7. Learning Objectives (continued) At the conclusion of this training, you should be able to… 10. Name the immediate steps to be taken when an individual identifies a potential S/CI according to the Fermilab “Controlling S/CI” procedure And… Pass a 10 question test on the course content 7

8. S/CI Program Definitions An item is considered to be: COUNTERFEIT if there is hard evidence to support an intent to misrepresent or to defraud SUSPECT if there are indications of a possible intent to misrepresent or to defraud DEFECTIVE if it is simply nonconforming or fails to perform as expected 8

9. Many commonly counterfeited items share the following attributes that make them more vulnerable to counterfeiting: They are of low cost & sold in high volume They are easily copied by secondary market suppliers They can bypass authorized suppliers and drop ship to customers 9 Attributes & Indicators of S/CI

10. What are some common indicators of suspect counterfeit items? Poor fit of assembled items Dimensions are inconsistent or wrong Dissimilar parts are evident Dirty or oily parts Wear marks or scratches on surfaces Loose or missing fasteners Handmade parts as part of assemblies Evidence of refinishing or painting Evidence of manual repairs or tool marks Indications that parts may be used 10 Attributes & Indicators of S/CI

11. How are counterfeit items introduced into the supply chain? Small percentages of counterfeit items can be “salted” in with good items to avoid detection Foreign parts may be packaged in domestically- labeled boxes Used or rebuilt items may be mixed with genuine new items 11 S/CI Introduction into the Workplace

12. Tactics for S/CI Introduction: Misrepresentation – Items are presented to be something they’re not Substitution – Substituting a used or reworked product for a new one Falsification of documentation – Altered documents misrepresent an item’s authenticity or capabilities (continued…) 12 S/CI Introduction into the Workplace

13. Tactics for S/CI Introduction (continued): Re-marking – Misrepresenting an item by altering its marking or labeling Repackaging – Misrepresenting items by repackaging them Knockoffs – Items manufactured to pass as higher quality products 13 S/CI Introduction into the Workplace

14. 14 Knock-off Example Watts Ball Valve The valve on the left incorrectly indicates a ½ PSI rating. It is a ½” valve. The valve on the right is genuine. S/CI Introduction into the Workplace

15. Knock-off Example: DURACELL® copyright infringement (name and/or black and gold copper top) 15 S/CI Introduction into the Workplace

16. 16 Misrepresentation Example: This saw has not been evaluated by UL and bears a counterfeit UL Mark for the US and Canada. UL posted an alert regarding this product. S/CI Introduction into the Workplace

17. Substitution Example: These breakers were sold as “new,” but are used or reconditioned 17 S/CI Introduction into the Workplace

18. Re-marking Example: This stainless steel “T” Weldalet connector shows subtle grind markings are visible where information was removed and new information stamped 18 S/CI Introduction into the Workplace

19. 19 The Following are Five Categories of the Most Common Suspect/ Counterfeit Items S/CI Introduction into the Workplace Category 1 – Piping Category 2 – Electrical/Electronic Components Category 3 – Bolts/Fasteners Category 4 – Hoisting and Rigging/Material Handling Category 5 – Documentation and Certification

20. S/CI Introduction into the Workplace Some S/C Items Commonly Identified at DOE Sites: Fasteners (bolts & brackets represent more than 70% of S/CI’s) Hoisting & Rigging equipment Ratchet straps/tie down straps Refurbished molded-case circuit breakers (continued…) 20

21. S/CI Introduction into the Workplace Some S/C Items Commonly Identified at DOE Sites (continued): Transformers, fuses, resisters, switch gear Metal struts Pipe components, fittings, flanges, valves Material and testing certificates Electronic components 21

22. 22 Example of counterfeit McDonald valve (left). Note the subtle difference in the logo. The valve on the right is genuine. Piping & Valving S/CI Example of S/CI Piping:

23. 23 This counterfeit Watts ½ “forged ball valve bears 4 logos: FM (Factory Mutual) AGA (American Gas Association) CGA (Canadian Gas Association) UL (Underwriters Laboratory) Watts only manufactures to UL and CGA Piping & Valving S/CI Example of S/CI Piping:

24. Some Common Indicators of Electrical/Electronic S/CI: Connections show evidence of previous attachment, arcing, or discoloration Fasteners are loose, missing or marred UL or other labels are missing Rivets are missing, screws may be used to replace them Terminals or connectors are of the wrong type or length 24 Electrical & Electronic S/CI

25. 25 Molded-Case Circuit Breakers (MCCB’s) Are Common S/CI’s Demolished buildings are a source of MCCB’s which are refurbished and resold More than 700 used MCCB’s have been sold to DOE or the National Nuclear Security Administration MCCB’s are not designed to be disassembled. There are no standards for refurbishing MCCB’s Electrical & Electronic S/CI

26. 26 Example of Suspect MCCB: Electrical & Electronic S/CI Suspect General Electric MCCB, refurbished and sold as new. Label printed with both “General Electric” and “GE” markings - GE stopped marking with both indicators over 20 years ago. New breakers are now only marked with “GE”. Look for worn labels as sign of refurbished breakers.

27. 27 Example of Counterfeit MCCB: Electrical & Electronic S/CI Left - Counterfeit No amperage rating on end of switch. Original number has been filed off Middle and Right - Good 20-amp breakers with rating clearly displayed

28. 28 Some Visual Characteristics of Refurbished MCCB’s: Outdated breaker style Product is not in the original boxes Labels are counterfeited or removed Manufacturer’s seal is broken or missing Wire lugs show tampering Scratches or nicks on case Altered amperage rating Electrical & Electronic S/CI

29. 29 Bolts and fasteners are the most common S/C items. Some common indicators are: Headmarks are shown on the DOE Suspect Fastener Headmark list There is no manufacturer’s mark Poor thread form or evidence of wear Headmarkings are marred, missing or altered Both metric & SAE stampings are evident Evidence of machining marks Double stamping Fastener S/CI

30. 30 Bolt marking requirements are specified by ANSI, ASTM, ASME, SAE and other organizations. This is an ANSI specification for grade markings. Such standards should be referenced in procurement specifications. Fastener S/CI

31. 31 Suspect/Counterfeit Headmark List The headmark list is based on manufacturers known to not meet industry standards. Fasteners bearing marks on this list should be considered S/CI. Fastener S/CI

32. 32 Suspect Bolt Headmark Example Fastener S/CI Example of a suspect bolt with “JH” marking. This marking is found on the DOE S/CI headmark list and should be considered suspect.

33. 33 Suspect Bolt Headmark Example Ratchet Tie-down The bolt in the ratchet is a Grade 8 with no manufacturer’s mark. A manufacturer’s mark is required. Fastener S/CI

34. 34 S/CI Bolt Manufacturer Markings & Grademarks “J” & “KS” manufacturer markings are still being routinely identified on bolts, despite being on the S/CI list for years Items can be S/CI regardless of the position of suspect manufacturer markings (e.g., centered vs. off to the side) If you cannot trace an item back to its origins, the item remains, at minimum, suspect Fastener S/CI

35. 35 Hoists and rigging are commonly counterfeited items identified at DOE Sites. Parts should be specified and inspected for the appropriate manufacturers markings and certifications. Some examples follow: Hoisting & Rigging S/CI

36. 36 Hoisting and Rigging S/CI Example: Hoisting & Rigging S/CI This shackle bears only a country of origin mark, not a manufacturer’s mark. This is not acceptable. DOE standards require the manufacturer’s name or trademark.

37. 37 Hoisting and Rigging S/CI Example Hoisting & Rigging S/CI This red hook bears “ELD” markings. The Crosby brand has a trademark on the red hook color and should be marked with a “GG” or “Crosby” mark.

38. 38 Falsified documents and labels are often used to misrepresent items. Some common indicators are: Text shows signs of altering, such as correction fluid or tape Text entries are mixed, both hand-written and typed Fonts are different Text is misaligned (continued…) Documentation & Labeling S/CI

39. 39 Some Indicators of Falsified Documents (continued): Lines on forms are bent or broken Technical data is inconsistent Unclear document to product traceability Document shows signs of duplication Page numbers conflict Documentation & Labeling S/CI

40. 40 Example of Falsified Labeling: Documentation & Labeling S/CI The WATTS Gas Ball Valve label above is S/CI because WATTS does not have a Woodbridge, Ontario, Canada facility. Note, this would not be obvious to most users.

41. 41 Example of Falsified Labeling: Documentation & Labeling S/CI The blue and white colored GE label (bottom) is authentic. GE does not affix black and white labels on boxes for this item nor should the product number be handwritten without any proper GE labeling.

42. 42 Many other items are subject to counterfeiting. Some examples of other items identified at DOE sites follow: Beam clamps – No manufacturers mark Other S/CI

43. 43 S/CI identified at DOE sites: Spring clips - No manufacturer’s name, logo or part numbers Other S/CI

44. 44 S/CI identified at DOE sites: Respirator components- substandard materials caused premature aging Other S/CI

45. 45 S/CI identified at DOE sites: Faulty Bushmaster rifle - failed due to substandard materials Other S/CI

46. Remember, almost any item can be subject to counterfeiting if: They are of low cost & sold in high volume They are easily copied by secondary market suppliers They can bypass authorized suppliers and drop ship to customers 46

47. Inspection for S/CI Because S/CI are intentionally concealed to avoid detection, 100% inspection or test are often the primary tool for S/CI identification. The Business Services Section Receiving Department does NOT inspect received items for indications of S/CI. Inspection of received items is the responsibility of those receiving, installing, and/or using them. 47

48. Inspection requirements for S/CI are specified in Fermilab QA Program document 1006 – “Suspect/ Counterfeit Item (S/CI) Program”, which states: All not yet in-service equipment, products or parts must be inspected prior to installation or use to ensure they are not S/CI. Existing equipment, products or parts which are in use or installed shall be inspected for S/CI by persons operating and/or maintaining them. 48 Inspection for S/CI

49. Inspection Techniques to Screen for S/CI Inspect cartons, boxes, packaging and packing materials Inspect carton and box labels Inspect nameplates or identification tags Inspect multiple items of an identical type for differences in appearance 49 Inspection for S/CI

50. 50 For inspection, remember the indicators common to many S/CI from the first section: Poor fit of assembled items Dimensions are inconsistent or wrong Dissimilar parts are evident Dirty or oily parts Wear marks or scratches on surfaces Loose or missing fasteners Handmade parts as part of assemblies Evidence of refinishing or painting Evidence of manual repairs or tool marks Indications that parts may be used Inspection for S/CI

51. Remember: At Fermilab, a nonconforming item is not considered suspect unless there are indications that it may have been intentionally misrepresented. If there are no such indications, these items should be managed as if they are simply nonconforming materials. 51 Inspection for S/CI

52. The Fermilab S/CI Program is defined in the following program documents: 1. “Suspect/Counterfeit Item (S/CI) Program”, QA Document 1006 2. “Controlling Suspect/Counterfeit Items Procedure”, QA Administrative Procedure 1006.1001 3. “Suspect/Counterfeit Items OQBP Procedure”, QA Administrative Procedure 1006.1002 All can be found at: http://www.fnal.gov/directorate/OQBP/oqbp_active_procedures.html 52 S/CI Reaction Procedures

53. When S/CI are identified, 4 steps must be followed: 1. The discoverer removes the immediate risk by stopping work, isolating the S/CI from use, and notifying their supervisor 2. The supervisor, Senior Safety Officer (SSO) and S/CI Coordinator Investigate the incident to determine the scope & cause 3. The same group defines the status of the S/CI and determines a disposition 4. The S/CI Coordinator records and reports the incident 53 S/CI Reaction Procedures

54. Discoverer’s S/CI Response: If you encounter a suspect item in your work area, eliminate the immediate risk of use: If the item is not installed or in use: Segregate the item to prevent its use Notify line management If the item is installed or in use: Suspend work activity Notify other workers in the area Notify line management 54 S/CI Reaction Procedures

55. S/CI Line Management Response: When notified of a potential S/CI that is not yet installed or in-use, line managers should: Remove the S/CI from the work area and isolate them from inadvertent use Refer the incident to the organization’s S/CI Coordinator and participate in an investigation of the incident (continued…) 55 S/CI Reaction Procedures

56. S/CI Line Management Response (continued): When notified of a potential S/CI that is installed or in-use, line managers should: Determine if the S/CI poses a potential ES&H risk and if so, refer to the SSO Notify the organization’s S/CI Coordinator and participate in an investigation of the incident Ensure involved workers are aware and that work remains suspended until the S/CI investigation is complete Consult with subject matter experts (SME’s) for assistance in the ES&H risk assessment as needed 56 S/CI Reaction Procedures

57. S/CI Coordinator Response: When an S/CI is identified, the S/CI Coordinator will: Verify the suspect part(s) are segregated or isolated from inadvertent use Notify OQBP if parts are deemed a safety risk, even if they conform to specifications Coordinate an investigation with area line management, SSO’s and SME’s (as needed) to determine S/CI status and recommended disposition Ensure that OQBP, line management and SSO’s are advised of the disposition and that it’s carried out 57 S/CI Reaction Procedures

58. Important Note: Fermilab S/CI procedures require that lab personnel shall not contact the supplier of a potential S/CI without approval by the Office of Quality & Best Practices. 58 S/CI Reaction Procedures

59. S/CI Disposal: If disposal is the determined disposition for S/CI, destruction must be carried out to prevent its unintended reuse by others For offsite destruction, contact the Property & Inventory Control Manager within the Business Services Section Destruction of S/CI materials considered hazardous is handled in accordance with FESHM 8021 59 S/CI Reaction Procedures

60. Points to Remember: 1. Almost any part can potentially be counterfeited. 2. Signs of counterfeiting may be subtle – unlike simple defectives, the intent is to deceive you. 3. Know your products… What are their required markings or certifications? What should they normally look like? 4. You as the originator have the primary responsibility to ensure your specifications preclude S/CI. 5. You as the receiver or installer have the primary responsibility to ensure S/CI are not released for use. 6. The use of high quality suppliers alone is no guarantee against S/CI. 60 Summary

61. Links and References: The following links contain reference information relating to DOE, Fermilab and other S/CI resources: DOE S/CI page: http://www.hss.doe.gov/sesa/corporatesafety/sci/sci.html OQBP S/CI page http://www.fnal.gov/directorate/OQBP/index.html# 61

62. Please remember to take the online test to complete the course and to update your training records. 62