If a tree falls in the forest and the wife does not hear it,
is the husband still wrong? Of course he is, or will be! So, if reporting or
notifications of certain events appear to be waning, does that infer those
events are correspondingly declining?
Regarding Counterfeit Parts, consider the following:Regarding Counterfeit Parts, consider the following:
Your initial impression of this graph might lead you to conclude that Counterfeit parts are on the decline...unless of course there are problems with the methods used in the reporting system. That's the conclusion reached in a Government Accounting Office (GAO) report titled "COUNTERFEIT PARTS: DOD Needs to Improve Reporting and Oversight to Reduce Supply Chain Risk 1."
How about the reporting of Suspected Unapproved Parts (SUPs)? Consider this illustration:
According to an FAA Report, the "FAA's" process for monitoring and investigating SUPs is not as effective as it could be, because of recordkeeping weaknesses and the lack of a management control to capture and accurately report the number of SUPs." This, from a report by the Office of Inspector General titled "ENHANCEMENTS ARE NEEDED TO FAA'S OVERSIGHT OF THE SUSPECTED UNAPPROVED PARTS PROGRAM 2"
In this blog we'll address the following:
Selected topics from the Counterfeit Parts report including GIDEP information
When it comes to jeans, purses, shoes, jewelry, watches, and paper money, counterfeit activity is well known and quantified, but what about our segment of business? Consider this from the GAO report:
"Department of Defense (DOD) agencies and contractors submitted 526 suspect counterfeit parts reports in the Government-Industry Data Exchange Program (GIDEP) from fiscal years 2011 through 2015..."
That figure should raise some eyebrows, especially considering that "The DOD supply chain is vulnerable to the risk of counterfeit parts, which have the potential to delay missions and ultimately endanger service members.1"
For those of you involved in supplying parts and services to the DOD, I'd like especially to remind and/or introduce you to GIDEP, the Government-Industry Data Exchange Program. According to their website3: "GIDEP (Government-Industry Data Exchange Program) is a cooperative activity between government and industry participants seeking to reduce or eliminate expenditures of resources by sharing technical information essential during research, design, development, production and operational phases of the life cycle of systems, facilities and equipment."
Now or in the future you will be required to participate in GIDEP by clause and/or DFAR. If you encounter any instances of impropriety including suspected counterfeit parts, the preferred means to report it is the GIDEP.
The report cited some weaknesses with this process however, which the DOD has acknowledged and is in the process of fixing. These include the following portions of the report which I've bolded:
DOD is not conducting oversight to ensure that defense agencies are reporting as required. As a result, the Defense Logistics Agency (DLA), for example, may be underreporting suspect counterfeit parts in GIDEP.
Defense agencies typically limit access of suspect counterfeit GIDEP reports to government agencies, so industry is not aware of the potential counterfeiting issues identified. DOD policy does not include guidance about when access to these reports should be limited.
Observations and selected topics from the SUPs report
Following Congressional hearings in the 90's, the FAA created a SUPs Program Office. It was the focal point for fixing known issues regarding unapproved parts. Part of its charter was to flow-down training to the rest of the FAA on how to handle SUP reports. By the way, for most of its years, the FAA Program Office was headed by Mr. Ken Reilly, who became a recipient of the ASA's life-time achievement recognition, the Edward J. Glueckler Award. The Program Office hosted and worked closely with the SUPs steering committee which the ASA and I participated in for many years. In 2007, the program office was disbanded after the Agency determined its functions had been firmly established at FAA offices at the regional, directorate, and local levels2.
Although in theory the disbanding of the SUPs Program Office was based upon sound training and planning flowed down to other FAA employees and departments, this subsequent FAA report has determined that enhancements are needed to shore up apparent shortfalls on the handling of SUP issues. The issues identified in the report included:
FAA Does Not Consistently Notify the Industry About Unapproved Parts
Industry Lacks Information Needed To Identify and Eliminate Unapproved Parts
FAA SUP Investigations Lack Uniformity
FAA Neither Accurately Accounts for SUPs Nor Conducts Trend Analyses of SUPs Data
The FAA response to the report was contained in a Memorandum (attached to the published report) in which the FAA concurs with all 11 recommendations and established closeout corrective-action deadlines. All very good developments.
By the way, I researched the amount of FAA Unapproved Parts Notices since their inception. Here are the results in graph form:
It seems the instances of UPNs are trending down. If that is the result of our industry taking effective steps to mitigate and eliminate Unapproved Parts, then that is a good thing. If however that is the result of less reporting and/or less of an industry focus on the issue, is not clear, and certainly remains un-analyzed and unquantified.
Since the disbanding of the FAA SUPs Program office, one of the things we don't have is in-depth analysis of quantified data. When the Program Office was active, we on the steering committee would see such useful analyzed data as follows (of course this is quite dated):
Today it does not appear we have such useful data.
An interesting observation regarding the report is that it seemed to focus exclusively on Hotline reports (calling in a report). Certainly there are other means of reporting such as use of the FAA Form 8120-11, Suspected Unapproved Parts Report. It would have been interesting to see the same investigative report cover a broader scope of reporting. Also, it would be interesting to see the raw numbers for all types of reporting; are they on the decline? Keep in mind that although we see UPNs, we in the public don't know how many reports are being submitted. In my opinion this is an important indicator of program effectiveness.
Also, in the same way I encouraged those in the DOD market to sign up for GIDEP reporting, I encourage anyone in Quality and Logistics in the civilian sector to access FAA Unapproved Parts Notices (UPN) and sign up for distribution of all new notices. Go to the FAA UPN website4, pick a year, and click on the email icon. You don't need a pw.
Both reports should be welcomed by our industry community in that they identified areas which could be improved upon, with the DOD and FAA both largely acknowledging the report's recommendations. Advancements are thus forthcoming.
Finally, we are tempted to wonder if the DOD and FAA collaborate on investigations; intelligence sharing for example? There is some recent evidence to indicate yes, thankfully. In 2016 the FAA issued a UPN on counterfeit parts. Based on background information not reflected in that UPN, it is almost certain the FAA UPN was based on DOD reports and investigations.
One thing is for sure, counterfeit parts and other types of unapproved parts are not going away. Let's hope the industry has indeed instituted effective countermeasures into our routines to properly mitigate this activity. Bravo to the FAA and DOD for leading the way.
Over 'n out
Roy 'Royboy' Resto
1COUNTERFEIT PARTS: DOD Needs to Improve Reporting and Oversight to Reduce Supply Chain Risk; Report Number GAO-16-236; Date Issued: February 2016; Government Accounting Office
2ENHANCEMENTS ARE NEEDED TO FAA'S OVERSIGHT OF THE SUSPECTED UNAPPROVED PARTS PROGRAM; Federal Aviation Administration; Report Number: AV2017049; Date Issued: May 30, 2017