OMB Receives New DOD Counterfeit Parts NPRM

Yesterday the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had received a copy of a new notice of proposed rulemaking (NPRM) from DOD on the subject of the detection and avoidance of counterfeit electronic parts. Apparently this is an additional part of the implementation of the Congressional mandate on this subject in the 2014 National Defense Authorization Act.

The initial final rule on this subject was issued last year followed quickly by a DOD meeting on what additional measures needed to be addressed. This rule has not been mentioned in the Unified Agenda so there are no publicly available details about what might be included.

I will note that I am not planning on going into any detailed analysis of this rule when it comes out as this is not a blog on the defense acquisition process. I continue to mention these rulemaking actions since DOD plays a major role in establishing manufacturer requirements in the electronics industry.

DOD Announces Counterfeit Parts Meeting

Today the DOD’s Defense Acquisition Regulations System (DARS) published a meeting notice in the Federal Register (79 FR 26725-26726) for a public meeting in Washington, DC on June 16^th, 2014 “to obtain the views of experts and interested parties in Government and the private sector regarding further implementation of the requirement for detection and avoidance of counterfeit electronic parts”. This is part of DOD’s ongoing effort to implement the requirements of  §818, “Detection and Avoidance of Counterfeit Electronic Parts,” of the National Defense Authorization Act for Fiscal Year 2012 (PL 112-81).

DOD is soliciting public participation in this process. Advanced registration is required and may be accomplished on the meeting web page. Registrations should be submitted by June 9^th, 2014. Individuals wishing to make a presentation at the meeting should submit an electronic copy via email (osd.dfars@mail.mil) by June 11^th, 2014.

NOTE: I am certainly not intending to broaden the scope of this blog to detailed coverage of the DOD acquisition process, but DOD is a very large purchaser of electronics. That means that these counterfeit parts processes could be a large influence on the entire industry, including control system vendors.

DOD Announces Electronic Counterfeit Parts Detection Meeting

Today the Department of Defense Acquisition Regulations System (DARS) published a notice in the Federal Register (78 FR 35262-35263) announcing a public meeting to be held on June 28^th concerning their proposed coverage of electronic parts detection and avoidance in the Defense Federal Acquisition Regulation Supplement.

DARS published a NPRM (78 FR 28780) last month addressing congressional requirements to implement requirements for detection and avoidance of counterfeit electronic parts in DoD contracts. The NPRM “addresses the responsibility of DoD contractors for detecting and avoiding the use or inclusion of counterfeit electronic parts or suspect counterfeit electronic parts in items delivered to the Department”.

DARS is soliciting public participation in this meeting. Registration is required (http://www.acq.osd.mil/dpap/dars/counterfeit_electronic_parts.html). Public presentations will be allowed; pre-submission of electronic copies (dfars@osd.mil) is required no later than June 24^th.