The Defense Department has proposed updating its acquisition regulations to require major contractors subject to cost accounting standards – and their large subcontractors – to have anti-counterfeit avoidance and detection systems in place for electronic parts.
The long-awaited proposal, issued mid-May, would implement requirements from the fiscals 2012 and 2013 national defense authorization acts, passed amid concern that counterfeit milspec electronic parts have made their way into weapons systems, potentially undermining their reliability or making them open to a remote cyber attack – although cybersecurity experts have said the risk presented by the latter possibility is relatively low.
The proposal would require companies with cost-reimbursement contracts subject to cost-accounting standards (a requirement that can’t be valid for contracts worth less than $700,000) to mount an acceptable anti-counterfeiting effort that would include training, inspection, parts traceability, use of “trusted suppliers” and a methodology to rapidly determine whether a suspect part is, in fact, counterfeit. The proposed rule doesn’t define what a trusted supplier would be.
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