SAE International Publishes Revision B of AS5553 and ARP6328
SAE International Publishes Revision B of AS5553 and ARP6328
By Anne-Liese Heinichen, ERAI
On September 12, 2016, SAE International published Revision B of Aerospace Standard AS5553 Counterfeit Electrical, Electronic, and Electromechanical (EEE) Parts; Avoidance, Detection, Mitigation, and Disposition along with ARP6328 Guideline for Development of Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition Systems.
The first obvious difference between Revision A and B is the visible reduction of the standard from 43 to 8 pages. SAE AS5553 Revision A, published on January 21, 2013, contained eight appendices. While the appendices were intended to provide guidance and best practices, industry feedback revealed that the inclusion of the appendices was causing confusion during implementation and the certification process. To better clarify the requirements outlined in AS5553, the G-19 CI Committee decided to parse out the content of the appendices to form a new aerospace recommended practice document, ARP6328, as a complimentary document to AS5553 Revision B. As was the case with the appendices in Revision A, the content in ARP6328 should not be considered as required, unless invoked by a customer as part of a contractual requirement. ARP6328 is designed to provide guidelines for implementing a counterfeit mitigation program per the requirements of AS5553.
Another large influence on Revision B was the publication of U.S. Department of Defense, Defense Federal Acquisition Regulation Supplement: Detection and Avoidance of Counterfeit Electronic Parts (DFARS Case 2012-D055), Part 252.246-7007 on May 6, 2014. This amendment defined new requirements for Cost Accounting Standards-covered contractors to establish and maintain a counterfeit detection and avoidance system and to flow down the requirements to lower tiers. These DFARS requirements would be applicable to many organizations that are purchasers and integrators of EEE parts, part of the target audience of AS5553.
Along with the release of the ARP and alignment to DFARS requirements, other changes in revision B include:
Removal of the term “fraudulent” throughout the standard, as the term was more applicable to an act performed by an individual or organization rather than a description of the parts themselves.
Revision of the term electronic parts to EEE parts to include electrical, electronic and electromechanical parts.
The Purpose and Application sections of the Scope were merged to provide clarification that the intent of the document is that it be used as a supplement to the requirements of a high level quality standard (e.g. ISO 9001, AS9120) and not as a stand-alone document.
Documents not specifically referenced in AS5553 were removed from the Applicable Documents section.
Several terms and definitions were either removed since they were not used in the standard or revised. One noteworthy change was made to the definition of counterfeit part to include a previously used part which is knowingly misrepresented as new. Accordingly, the definition of fraudulent part was removed from Revision B as previously mentioned. Additionally, a new term, authorized source, was defined relative to the purchasing process and includes suppliers who exclusively obtain parts from an OCM. On a side note, SAE International is developing AIR6273 which is intended to serve as a standardization document with regard to terms and definitions used throughout various counterfeit-related SAE standards. Once AIR6273 is published, it is the intent that the G-19 and G-21 Committees will refer to the terms and definitions contained therein by default.
Within the Purchasing Process requirements, Revision B states that the Counterfeit EEE Parts Control Plan must also address identification, detection, and avoidance of suspect counterfeit parts (in addition to mitigation, disposition and reporting from Revision A). To align with DFARS 252.246-7007 requirements, the Control Plan must also be updated as counterfeiting trends evolve and allows for the use of avoidance techniques from industry standards.
With regard to Personnel Training and for alignment with the DFARS 252.246-7007 requirements, the requirement that training must be updated was added.
In the Purchasing Process section, an emphasis was placed on sourcing parts from “authorized sources”. Requirements were added to “document and retain objective evidence” that the supplier is an authorized source and to assess and screen suppliers that are not authorized sources taking into consideration industry and government sources (e.g. ERAI). In addition, new requirements were defined for an organization’s risk assessment and risk mitigation plan per DFARS 252.246-7007 requirements.
With the Purchasing Information section, the requirement to obtain traceability from the OCM to the source of supply that includes all of the “supply chain intermediaries” was removed as many times this is not feasible.
The Failure Analysis section in Revision A was removed as this is already addressed in Verification of Purchased Parts.
The Material Control Section underwent a rewrite and combined some elements from Purchasing Information and Verification of Purchased/Returned Parts(s) from Revision A including: traceability must be maintained to the source during the procurement and receiving process; to control counterfeit parts, an organization can now disposition the parts when legal requirements allow (e.g. scrapping the parts including packaging material to avoid reuse); inventory affected by a counterfeit part(s) must be addressed; and a documented process for the verification of returned material is required to assure its authenticity.
Lastly, an Auditing section was added to require periodic internal auditing to ensure the organization’s compliance to their counterfeit control plan.
AS5553B - Counterfeit Electrical, Electronic, and Electromechanical (EEE) Parts; Avoidance, Detection, Mitigation, and Disposition
ARP6328 - Guideline for Development of Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition Systems
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