1. Suspect / Counterfeit Item Identification Training
Fermilab
Suspect / Counterfeit Item Identification Training

2. What are Suspect & Counterfeit Items (S/CI)?
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.

3. What is the real risk of using Suspect / Counterfeit Items?
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

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

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

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

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

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

9. Attributes & Indicators of S/CI
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

10. What are some common indicators of suspect counterfeit items?
Attributes & Indicators of S/CI
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

11. How are counterfeit items introduced into the supply chain?
S/CI Introduction into the Workplace
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

12. Tactics for S/CI Introduction:
S/CI Introduction into the Workplace
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…)

13. Tactics for S/CI Introduction (continued):
S/CI Introduction into the Workplace
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

14. Knock-off Example S/CI Introduction into the Workplace
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.

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

16. Misrepresentation Example:
S/CI Introduction into the Workplace
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.

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

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

19. S/CI Introduction into the Workplace
The Following are Five Categories of the Most Common Suspect/ Counterfeit Items
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…)

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

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

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

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
Group fault circuit interrupters
Conduit fittings
Power strips and surge suppressors
Extension cords
Power cords
Telecommunications cable
Electrical connectors 24

25. Molded-Case Circuit Breakers (MCCB’s) Are Common S/CI’s
Electrical & Electronic S/CI
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

26. Example of Suspect MCCB:
Electrical & Electronic S/CI
Example of Suspect MCCB:
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. Example of Counterfeit MCCB:
Electrical & Electronic S/CI
Example of Counterfeit MCCB:
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. Some Visual Characteristics of Refurbished MCCB’s:
Electrical & Electronic S/CI
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

29. Fastener S/CI
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

30. Fastener S/CI
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.

31. Fastener S/CI
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.

32. Suspect Bolt Headmark Example
Fastener S/CI
Suspect Bolt Headmark Example
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. Suspect Bolt Headmark Example
Fastener S/CI
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.

34. S/CI Bolt Manufacturer Markings & Grademarks
Fastener S/CI
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

35. Hoisting & Rigging S/CI
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:

36. Hoisting and Rigging S/CI Example:
Hoisting & Rigging S/CI
Hoisting and Rigging S/CI Example:
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. Hoisting and Rigging S/CI Example
Hoisting & Rigging S/CI
Hoisting and Rigging S/CI Example
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. Documentation & Labeling S/CI
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…)

39. Some Indicators of Falsified Documents (continued):
Documentation & Labeling S/CI
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

40. Example of Falsified Labeling:
Documentation & Labeling S/CI
Example of Falsified Labeling:
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. Example of Falsified Labeling:
Documentation & Labeling S/CI
Example of Falsified Labeling:
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. Other S/CI
Many other items are subject to counterfeiting. Some examples of other items identified at DOE sites follow:
Beam clamps – No manufacturers mark

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

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

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

46. Remember, almost any item can be subject to counterfeiting if:
Other S/CI
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

47. Inspection for S/CI Inspection Controls
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.

48. Inspection Controls
Inspections are critical to identifying S/CI and also assist in preventing S/CI from being used:
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.

49. Inspection Techniques to Screen for S/CI
Inspection Controls
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

50. Inspection Controls
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

51. Inspection Controls
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.

52. S/CI Reaction Procedures
When S/CI are identified, 4 steps must be followed:
The discoverer removes the immediate risk by stopping work, isolating the S/CI from use, and notifies their supervisor
Line management, S/CI Coordinator, Senior Safety Officer (SSO) and Subject Matter Experts (SMEs) (as applicable) complete an investigation
Line management, S/CI Coordinator, and SMEs define the status of the S/CI and determine a disposition
The Quality Assurance Representative (QAR) records the disposition and actions in iTrack and communicates the incident

53. S/CI Reaction Procedures
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

54. S/CI Reaction Procedures S/CI Line Management Response:
When notified of a potential S/CI that is not yet installed or in-use, line managers shall:
Remove the S/CI from the work area and isolate them from inadvertent use (utilize S/CI Tag whenever possible)
Refer the incident to the organization’s S/CI Coordinator (and SSO if there is a potential safety risk) and participate in an investigation of the incident to determine disposition of the item
(continued…)

55. S/CI Reaction Procedures
S/CI Line Management Response (continued):
When notified of a potential S/CI that is installed or in-use, line managers shall:
Ensure involved workers are aware and that work remains suspended until the S/CI investigation is complete
Refer the incident to the organization’s S/CI Coordinator (and SSO if there is a potential safety risk) and participate in an investigation of the incident to determine disposition of the item

56. S/CI Reaction Procedures
When an S/CI is identified…
The S/CI Coordinator Response:
Verifies the suspect part(s) are segregated or isolated from inadvertent use
Notifies ESH&Q if parts are deemed a safety risk, even if they conform to specifications
Coordinates an investigation with area line management, SSO’s and SME’s (as needed) to determine S/CI status and recommended disposition
The QAR Response:
Ensures that ESH&Q, line management and SSO’s are advised of the disposition, records S/CI in iTrack, and ensures all actions for the investigation are completed

57. S/CI Reaction Procedures
Important Note: Fermilab S/CI procedures require that lab personnel shall not contact the supplier of a potential S/CI without approval by the ESH&Q Section Head and the Business Services Section Head, or their designated alternates.

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

60. DOE & Fermilab Resources
Links and References:
The following links contain reference information relating to DOE, and Fermilab S/CI resources:
DOE S/CI page:
Fermilab S/CI Program in FESHM 12020:

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