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Suspect/Counterfeit Item (S/CI)Awareness Training
Ruth McDunnOffice of Assurance
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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Prevention through Procurement
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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Prevention through Procurement
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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Visual Inspection Indicators
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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Visual Inspection Indicators
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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VisualSurface Changes
Flange surface marks on
new flange and item isnot clean
Internal corrosion of anair-dryer valve sold asnew
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Visual Inspection Indicators
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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Visual Inspection Indicators
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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Visual Inspection Indicators
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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Documentation Indicators
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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Documentation Indicators
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/