Sci Training

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Suspect/Counterfeit Item (S/CI)Awareness Training

Ruth McDunnOffice of Assurance

[email protected]

Updated January 13, 2009


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Suspect/Counterfeit Item (S/CI) Awareness TrainingPage 2

Outline

Definitions

Risks of Using S/CIs

Typical Examples

Prevention through Procurement

Suspect Item Indicators

Detection of Installed S/CIs

More Information

More Examples


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Definitions

Suspect Item

Indication by visual inspection, testing,

documentation, or other information that the itemdoes not conform to established Government orindustry-accepted specifications or nationalconsensus standards

e.g., UL, ASTM, SAE, ISO, ANSI

Suspect items must be further investigated todetermine if they are counterfeit. When an item

contains indications, but insufficient evidence ofirregularities, it may be declared suspect


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Definitions

Counterfeit Item

A suspect item that is

A copy or substitute without legal right or authority todo so, or

One whose material, performance, or characteristicsare knowingly misrepresented by the vendor, supplier,

distributor, or manufacturer

If a product can be manufactured, it can also becounterfeited


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Definitions

Defective Item or Material

Any item or material that does not meet the

commercial standard or procurement requirementsas defined by catalogues, proposals, procurementspecifications, design specifications, testingrequirements, or contracts

It does not include parts or services that fail or areotherwise found to be inadequate because of randomfailures or errors within the accepted reliability level


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Risks of Using S/CIs

S/CIs are considered to be substandard materialsand failure could result in:

An operational safety problem Unacceptable risk of injury to workers or the public

Environmental damage

Of particular concern are when S/CI are used: In a safety system

At a critical load path

A structural component, such as a bolt, in a crane,hoist, or other handling or lifting equipment that bearsthe load being lifted or moved


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Typical Examples

Moderate to low priced items that are high-demandor have a high turnover rates

Within the DOE complex Bolts, fraudulently marked as high-strength

Refurbished electronic components sold as new

Hoisting and rigging equipment Valves, pipe, pipe fittings, and flanges

At SLAC

high-strength bolts Schottky rectifiers


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DOE Bolt Headmark Lists


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Counterfeit Bolt Example, SLAC Salvage

Grade 8 (six slashes)

No headmark

Grade 5 (three slashes)

KS headmark


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Circuit Breaker Example

Suspect indicators

Missing labels

Left - Counterfeit

Used 600 volt, 100 ampbreaker sold as new

Right - Genuine

Original Breaker

Counterfeit Genuine


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Hoisting and Rigging Example

Lifting Hook

Altered working load limit (WLL) marking

Grind marks Hand stamped

rather thancast mark


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Flange Examples

Suspect Indicators

Hand stamped

ASA 150 CHINA

Meaningless information.

ASA is an obsoleteconsensus standardsorganization


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Any item known to have been counterfeited in thepast (particularly if the planned use is in a safety

system or mission critical application) should onlybe obtained through Stores or Purchasing.

They will:

Qualify procurement sources based on technicalspecifications you provide

Specify inspection requirements

Include a quality clause in the terms and

conditions


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Follow the Hoisting and Rigging PurchasingGuidelines 1

Do not use a purchase card to buy items known tohave been S/CI in the past. This includes:

Tools and industrial supplies

Items readily available through Stores Hoisting and rigging equipment, except as noted in

Attachment L of the P-Card procedures 21 http://www-group.slac.stanford.edu/esh/eshmanual/references/hoistingProcedPurchase.pdf

2 https://www-internal.slac.stanford.edu/bsd/pur/forms/creditcardprocedure.pdf


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Suspect Item Indicators

LANL-SCI Guide for Suppliers

The following examples are from this guide

Items that appear to be suspect are just thatsuspect

A thorough investigation is needed to determine thata suspect item is, in fact, counterfeit


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Visual Inspection Indicators

Known S/CI

The item or component matches the description of

one that is listed on a suspect item list DOE Suspect/Counterfeit Fastener Headmark List

Fastener Quality Act (FQA) http://ts.nist.gov/WeightsAndMeasures/fqa.cfm

Country of origin is China, Taiwan, India, Korea, orMexico and has no manufacturer mark


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Nameplates, labels, tags

Appear to have been altered, photocopied, or painted over

Have incomplete or missing data

Preprinted labels that show typed entries

Attached in a different location than normal or withinconsistent fasteners (screws instead of rivets, or acombination of rivets and screws)

Missing manufacturers standard markings, stamps, or logos,and with irregular stamping or inconsistent font

Multiple logos and seals

Warning labels with grammatical errors or that conflict with

information found elsewhere on the packaging


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Surface changes

Wear marks or scratches on external surfaces or

new products Heat discoloration marks

Metallic items are pitted or corroded

Casting markings ground off and re-stamped withother markings

Signs of weld repairs


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Suspect/Counterfeit Item (S/CI) Awareness Training

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VisualSurface Changes

Flange surface marks on

new flange and item isnot clean

Internal corrosion of anair-dryer valve sold asnew


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Electrical Components

Underwriters Laboratories (UL) marks missing one

or more of the four elements: UL trademark

The word LISTEDin capital letters

Product identity

Control number

There is a UL mark on the package, butnot on the product


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VisualGenuine UL Listing Marks

How to identify counterfeit UL marks http://www.ul.com/ace/fake.html

The new holographic label will be available formanufacturers on July 1, 2008

It will be required worldwide on all new productionin the 32 hologram categories starting July 1, 2009

http://www.ul.com/marks_labels/hologram.html


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Packaging

Inconsistent vendor name on the item and on the shippingcontainer, or no name on the container

Shipping boxes contain mixed batch numbers, expiration dates,and UPC codes

Unusual packaging and boxing of items

Inconsistent with the manufacturers normal packaging or

documentation requirements Questionable or meaningless numbers on the item(s) or

packaging

Obviously changed labeling (crossed out or erased)

Inconsistent appearances of items in the same shipment


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VisualPackaging

Square washers/spacers

Both types received in thesame shipment

The genuine item has theproper markings

Genuine Counterfeit

Erased markings onshipping box


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Construction

Assembled items fit poorly

Configuration is not consistent with other items fromthe same supplier

Configuration varies from the supplier literature ordrawings

Handmade parts are evident rough-cut or evidence of cutting/dressing with hand

tools

Obvious attempts to repair or beautify

excess paint, wire brushing, hand-painted touch-up,painted stainless steel


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VisualConstruction

150 lb rated flangeshould be 0.940 thick

This one is only0.69920 thick


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Procurement Indicators

Quoted price for the item is unusually discountedor low

Unusual disclaimers, or denials, of responsibilityfor the accuracy of the test results

The supplier is not a manufacturers authorizeddistributor

Request a sample to test in the intended applicationprior to purchase or purchase a small lot

Dimensions of the item are inconsistent with the

specification


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Documentation Indicators

Altered Documents

Excessively faded or unclear or missing data

Use of correction fluid or correction tape

Type style, size, or pitch change is evident

Data on a single line is located at different heights

Lines on forms are bent, broken, or interrupted

indicating data has been deleted or exchanged bycut and paste

Handwritten entries are on the same documentwhere there is typed or preprinted data

Text on page ends abruptly and the number of pagesconflicts with the transmittal


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Signatures and initials

Corrections are not properly lined-out, initialed and

dated Document is not signed or initialed when required

The name of the document approver, or title, cannotbe determined

Approvers name and signature do not match

Document has missing or illegible signature, initials

Document is not traceable to the items procured


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Content

Technical data is inconsistent with code or standard

requirements Certification or test results are identical between all

tested items

Normal variations should be expected

Documentation is not delivered as required on thepurchase order, or is in an unusual format


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Detection of Installed S/CI

During compliancewalkthroughs, functionalinspections, maintenance

or constructioninspections, and self-assessments, be alert topossible S/CIs

If in doubt, contact a theS/CI Subject Matter Expert

S/CI Experts

Bolts, fasteners, andhoisting and rigging

equipment Chemical and General

Safety Department,ES&H Division

Electric circuit breakers Electrical Safety

Officer

For all other items

ES&H Division or OA


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Detection of Installed S/CI

If an installed item is determined to be suspect:

In a safety system or critical application, item must

be locked/tagged out, replaced, and removed If item must be removed, notify OA to coordinate

and document disposition

If there is no hazard or adverse affect, S/CI item

must be tagged/marked and entered into CATS,then:

Removed and replaced during the next routinemaintenance and close the CATS entry

Leave in place, note this in CATS and close the CATSentry


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Sources

Suspect/Counterfeit-Defective Items AwarenessTraining for DOE and Contractor Employees

http://www.hss.energy.gov/CSA/CSP/sci/LANL10305awarenesstraining.pdf

Suspect/Counterfeit Items Information Guide forSubcontractors/Suppliers

http://www.efcog.org/wg/ism_qa/docs/EFCOG_Alerts/SCI_Guide_for_Suppliers.pdf

Suspect/Counterfeit Items Awareness Training(DOE HSS)

http:/www.hss.energy.gov/CSA/CSP/sci/SCIAwarenessTrainingManual062007.pdf


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More Information

Office of Assurance S/CI Website

http://www-group.slac.stanford.edu/oa/suspectcounterfeit.htm

Office of Assurance S/CI SharePoint Site https://slacspace.slac.stanford.edu/sites/ipm/oa/SCI/

DOE HSS S/CI Website http://www.hss.energy.gov/csa/csp/sci/

UL Anti-Counterfeiting Operations http://www.ul.com/ace/

UL Public Notices http://www.ul.com/global/eng/pages/corporate/newsroom/publicnotices/