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March 2014 • SMT Magazine 95 have never been produced; for all intents and purposes, these parts never existed! According to the GAO, the motivation behind GAO-12-375 is the fact that "Counterfeit parts— generally the misrepresentation of parts' identity or pedigree—can se- riously disrupt the Department of Defense (DoD) supply chain, harm weapon systems' integrity, and en- danger troops' lives." Ultimately, counterfeit components endanger our sons and daughters, who brave the front lines in the field. Some of the preliminary findings from the GAO investigation of the procure- ment and testing of select elec- tronic components which have the potential to enter the supply chain of the U.S. Department of Defense are presented in GAO- 12-213T, released in November of 2013. As reported in last month's column, many programs to re-use and recycle materials were devel- oped with good intentions, but they wind up being used to cre- ate counterfeit electronic parts. Known as "e- waste," this material is shipped from the United States and other countries to desperate parts of the world, where the e-waste is disassembled in dirty, dangerous environments, and trans- formed to deceive the buying community. In an effort to counteract this practice, President Obama signed into law Section 818 of the Na- tional Defense Authorization Act for 2012. It applies to all contractors who supply electronic parts or products that include electronic compo- nents. DoD contractors are required, whenever possible, to obtain electronic parts that are in production or currently available in stock from the original component manufacturer (OCM) of the parts or their authorized/franchised dis- tributors. In addition, electronic parts that are not in production or are out of stock must be purchased from "trusted suppliers." The term "trusted suppliers" is not well defined in the legislation and further clarification is needed. Section 818 requires change Throughout the Supply chain Reporting requirements under Section 818 is a new necessity that trustworthy suppliers must implement into their procedures. A contractor who knows or "has reason to suspect" that he has received a counterfeit electronic part is re- quired within 60 days to report to the appropri- ate government authority, the Government In- dustry Data Exchange Program (GIDEP). As an example, just this week, Secure Components, following an extremely aggressive quality pro- tocol, determined that an electronic compo- nent delivered to the company and headed to the Defense Department was detected to have failed "resistance to solvent" testing. Further testing revealed the part was remarked and carried a false date code. Once these anoma- lies were identified, it was our responsibility as the contractor to report and quarantine the counterfeit parts. As the GIDEP representative, KraMer on CoMponenTS INvESTIGaTIONS, EvIDENcE, aND aN UNcLEar SOLUTION FOr 2014 continues figure 3: Part of the authenticity testing is to X-ray the product.