DI-MISC-81832

Counterfeit Prevention PLAN

The Counterfeit Prevention Plan will be used by the procurement activity to determine and evaluate the effectiveness of the contractor's counterfeit protection plan and award fee.

Approval DateJanuary 21, 2011

AMSC Number9181

Preparing Activity—

Project Number—

OPRNRO

DTIC ApplicableNo

GIDEP ApplicableNo

Limitation—

Applicable Forms—

Approval Limitation—

Form Version—

DID Formatdd_form_1664

963C CompliantNo

DISTRIBUTION STATEMENT A: Approved for public release; distribution is unlimited.

Supersedes

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Description & Purpose

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Application & Interrelationship

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Use & Relationship

The Counterfeit Prevention Plan will be used by the procurement activity to determine and evaluate the effectiveness of the contractor's counterfeit protection plan and award fee. This Data Item Description contains the format and content preparation instructions for the data product generated by the specific and discrete task requirements delineated in the statement of work. This DID is related to Parts, Materials and Processes Selection List (PMPSL). This DID is related to 'As Designed' and 'As Built' Parts List. The Counterfeit Prevention Plan will be updated as counterfeiting methods evolve to include any new indicators, as well as new prevention processes needed (either discovered directly or provided by the Government).

Preparation Instructions

1The Counterfeit Prevention Plan shall be in contractor format and shall include the following, as a minimum:

1.1Procurement practices and procedures to include procurement of all parts and materials from original qualified parts/materials equipment manufacturer (OEM) or it franchised/authorized distributor.

1.2Procurement practices and internal processes used for exceptions to buying from OEM or OEM franchised distributors in cases where items are no longer available including a process to qualify/certify non-OEM parts & materials.

1.3Monitoring procedures to include the delivery of test results from random sampling and supply chains surveillance that does not assume any source is safe to identify possible penetration of OEM supply chain.

1.4Training/certification program for receiving inspectors.

1.5Process to verify counterfeit.

1.6Processes to identify, store, and report counterfeit parts.

1.7Process to ensure subcontracts contain the following requirements (As a minimum):

1.7.1Requirements to procure only from Original Equipment Manufacturer (OEM) or OEM franchised distributors

1.7.2Procurement practices and internal processes used for exceptions to buying from OEM or OEM franchised distributors including a process to qualify/certify non-OEM parts & materials obtained

1.7.3Requirements to monitor supply (including delivery of test results from random sampling and supply chain surveillance that does not assume any source is safe) to identify possible penetration of OEM supply chain

1.7.4Training/certification program for receiving inspectors

1.7.5Process to verify counterfeit

1.7.6Processes to identify, store, and report counterfeit parts.

1.7.7Notification procedure (tailored to specific sub-contractor based on following Notification Procedure)

1.8Self-audit of internal processes.

1.9Monitor processes at all subcontractor levels processes and verify compliance through on-site audits.

1.10Notification Procedure:

1.10.1Step 1: The contractor shall quarantine all suspect products pending further direction. The contractor shall provide a statement, with problem description, justifying why this is considered suspect and how it was detected. The contractor shall NOT notify the supplier that the items are suspected as being counterfeit items. However, consultation with the OEM is authorized. Make certain the parts and all members of the lot procured for use on this contract are stored in correct environmental controls. These parts need to be protected as evidence.

1.10.2Step 2: Contractors that identify suspect items shall immediately notify their customer that is the next link toward the prime contractor. Notification shall be passed up the customer chain until reaching the prime contractor. The prime contractor shall immediately notify the cognizant Contracting Officer (CO) and Contracting Office Technical Representative (COTR) of all suspect items identified.

1.10.3Step 3: The contractor shall make certain that the original documentation is secured as evidence and maintain any and all documentation associated with the part to include:

1.10.3.1Part information such as part identifying number, lot date code, manufacturer information and originator/point of contact information

1.10.3.2Any information reflecting part procurement/acquisition traceability which should include a copy of the purchase order, any and all correspondence between the buyer and the supplier to include: e-mails, records of phone conversations and paper letters of correspondence

1.10.3.3Part documentation from the purported original manufacturer, distributors and suppliers (certificate of compliance and certificate of conformance)

1.10.3.4All visual examination and physical analysis/testing results and the technical data package showing that the parts passed the required screening and qualification tests

1.10.3.5List of company products affected

1.10.4Step 4: Determine that the part is or is not counterfeit (Usually accomplished as part of root cause analysis of non-conforming parts and/or materials)

1.10.5Step 5: If the parts are found to be counterfeit, they shall be isolated and controlled pending direction from law enforcement.

1.10.6Step 6: The contractor shall provide any additional required information to the government's investigation team

References

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