Continued Discussion on DOD Definitions

June 19, 2015

 

To continue the discussion on DOD definitions related to electronic parts in Section 818(f) of the 2012 NDAA, the regulation states that an electronic part is an IC or integrated circuit, includes a discrete electronic component, which includes transistors, capacitors, resistors, diodes or a circuit assembly. But final regulations clearly include any embedded software or firmware in an electrical part. And the responsibility to detect and eliminate counterfeit parts applies to companies that supply products containing electronic parts as well as the companies that supply individual electronic units.

 

Major criticisms of DOD’s proposed regulations is that they haven’t identified what an effective detection system should be. Risk issues with parts required for mission critical obsolete parts remains high. DOD, in final regulations addresses the criticism by openly recognizing and even endorsing implementing a risk-based approach for contractors to detect counterfeits and avoid them utilizing risk-based policies an procedures as outlined in DFARS 246.870-2(b).

 

As a supplier do you currently evaluate parts before utilizing them for DOD use? What’s your risk if you do not do your due diligence? Can GCI assist you and reduce your risk or evaluation costs? Reach out to ed.odette@gci-global.com for additional information on safe obsolescence solutions.

 

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