One of the most significant risks within the aerospace sector is the introduction of counterfeit products into the supply chain and eventually onto aircraft.
82% of all known counterfeit products are electronics; the other 18% is raw material, so although the most significant risk is within electronics, raw material still has a part to play and can cause failures just as much as electronics. The aerospace supply chain is complex and runs many layers. Most counterfeit parts enter the supply chain at the bottom/start of the process; the raw material distributors and suppliers.
Everyone has a part to play
When questioned about their counterfeit controls, many organisations immediately refer to the goods in personnel, which is their responsibility for controlling and identifying the counterfeit products.
This is a myth, every person within the organisation has a part to play in the mitigation and identification of counterfeit products, and therefore everyone should be aware of the risk.
Design and Engineering Team
The design and engineering team are responsible for only design parts where components used are not likely to become obsolete before the part has ended.
If components become obsolete and organisations need to source these, they will rely on the black market, which is high risk. Obsolescence is where there is a greater risk of counterfeit products entering the supply chain.
If your organisation is a make-to-print manufacturer, you still have a role to play if designs are received and you identify a material shortage or lack of availability for any reason. The customer needs to be informed of the issue and only make assumptions or determine alternative products with customer authorisation. If a plane goes down, do you have the confidence to stand before a judge and tell them you said it was ok to use alternative parts or materials as it wouldn’t impact the final product?
The sales team is also responsible for identifying possible challenges with parts and materials, but their primary responsibility would be to give accurate lead times to the customer. Do not make promises you can’t keep, and do not bend over to the pressure put upon you to cut lead times, as this can force destructive behaviours.
If items have an extended lead time from the Original Equipment Manufacturer or their authorised distributors, this is the lead time. If the customer asks for it quicker, you need to inform them the lead time is as good as it will be. Do not do google searches for the products from other sources, as the risk of counterfeiting could be more significant. Again you start to enter the black market for supply.
The purchasing team is responsible for buying products from the correct sources; they should purchase directly from the Original Equipment Manufacturers or their authorised distributors—the further down the food chain, the greater the risk.
If you cannot buy from the OEM or the Authorised distributors, you should refer to your approved suppliers register and use suppliers who have been thoroughly vetted. Even if they have been approved, there is still a risk, so you must be vigilant. Refrain from pressuring other suppliers to obtain products and materials quicker than possible, as it can also force them to use alternative suppliers.
Stores and Goods In
The personnel within the store’s area or who are responsible for checking goods and documentation upon receipt and who most organisations believe are accountable for counterfeiting.
Although they are most likely to catch incoming counterfeit, you should ensure they know what to look for to identify the issues.
The most important thing here is controlling the items so they do not enter your production or storage area and are subsequently used. The products/material may not be confirmed as counterfeit, but you should assume it is if there is any doubt and treat it as such. The parts/material would be classified as Suspect Counterfeit until it is confirmed either way.
There are three critical categories at this stage:
- document indicators of fraud
- part (or physical) indicators of fraud
- facility indicators of fraud
Part (or physical) indicators
Parts can have the following significant physical indicators of fraud:
- other indicators
As a minimum, you must check documentation and packaging. Still, you can also identify and verify purchased products with NDT and DT. Some of the NDT and DT processes can be expensive; if you assess your suppliers and applications correctly, you do not need to do this frequently.
- Altered or unexplained markings, stampings, mouldings, and engravings.
- Improper surface treatment or signs of refurbishment without being identified as refurbished material.
- Re-marked, smeared or illegible bar codes (IUID or UII)
- Faceplates and nameplates showing signs of removal and re-installation
- Altered labels and tags
- Signs of re-painting or re-coating
- Other signs of re-used material include oil stains, overheated areas, disassembly and reassembly, erosion, wear, dents and scrapes, etc.
Documentation and Packaging:
- Lot and date codes on the packaging do not match the lot and date codes on the parts.
- Review logos, trademarks and other identifying marks to ensure they match manufacturers’ marks as applicable.
- Changes to or irregularities in the documentation and/or paper trail.
- The part number marked on the material does not match the part number on the Purchase Order and the certifications.
- Materials are inconsistent with the description on the supplied documentation.
- Serial number issues or duplication of UII (Unique Item Identifier).
Non Destructive Testing and Destructive Testing:
- Visual, Weight, Optical and Infrared
- Liquid Penetrant Inspection
- Magnetic Particle Inspection
- Ultrasonic Inspection
- Eddy Current Inspection
- Radiological Inspection
- Thermography Inspection
- Acoustic Emission
- Heat Flow Microcalorimetry
- Functional test
- Destructive: deformation, metallurgical, exposure, analytical, functional
82% of all known counterfeit product is electronic components. At a minimum, you need to check the packaging and perform a visual inspection, and it is highly recommended you also perform some Destructive Testing. Again though, this should all be based on risk. There are many tools and techniques for electronic components to help identify counterfeit. One of the best methods is to send a sample back to the OEM/OCM if you have yet to buy directly from them or one of their authorised distributors; they will know the product better than anyone else and can tell you if it is counterfeit or not.
- Documentation and packaging
- External visual inspection
- Remarking & resurfacing (destructive)
- Radiological (X-ray) inspection
- Lead finish evaluation (XRF of EDS/EDX)
- Delid/decapsulation internal analysis (destructive)
- Scanning electron microscope
- Quantitative surface analysis
- Thermal testing
- Electrical testing
- Hermeticity (fine and gross leak)
- Scanning acoustical microscopy
Production and Inspection
Production personnel and inspection are the last stop in the process, the last opportunity to capture counterfeit material or parts.
Production operatives should be able to detect anything that doesn’t appear normal when processing material; the material may seem too soft or hard. the material is porous. These are telltale signs of counterfeit material.
The inspection department is there to verify the completion of all possible checks; they should double-check the material and supplier certificates at a minimum. They should demonstrate the traceability of parts and material back to the source through the paperwork trail.
At this stage, testing may be performed, including functional testing with electronic components and board layout inspections. The electronics industry has standards for inspectors to be approved and follow, such as IPC610 and IPC620. The inspectors could also receive specific counterfeit training on standards such as AS6081.
So what to do if you find Counterfeit products?
This part usually confuses organisations; they don’t know who they should inform and what happens next.
The main thing to remember is you should NEVER RETURN THE PRODUCTS TO THE SUPPLIER. Sending the product back to the supplier just puts the material or product back into the supply chain; the supplier can just sell it to someone else who may not be as vigilant.
You must inform your customers as this situation will impact them with either delays or recalls. You should keep them up to date with your investigations and any actions you are taking.
The authority part is more challenging, but you should know yours based on your location. In the UK, you would report to both CAA and EASA and should do so via the EU 2014/376 occurrence reporting regulation. UK Aviation is no longer part of the EASA, however if the part has come from a EU manufacturer then it should be reported to EASA.
EASA may put you in touch with the CAA, but your first port of call should be EASA. In the USA, it would be the FAA. You should know the authority within your own country.
The EASA website has over 7500 known counterfeit parts listed on their website, you should use this website to check to see if any of your purchased items are on this list, and you can also subscribe for notifications of new issues. They also have a list of parts currently under investigation, and you can read what action was taken. The FAA has a similar process and website, although it could be more user-friendly and easy to identify parts that could impact you.
Whatever authority you contact should all take similar action and investigate further, they will take any necessary actions.
You should also contact ERAI and GIDEP if Electronics are related.
Founded in 1995, ERAI, Inc. is a global information services organisation that monitors, investigates, and reports issues affecting the global electronics supply chain. Members include aerospace, defence, medical, nuclear and commercial OEMs, CMs, OCMs, distributors, government agencies, industry associations, and other industry organisations.
ERAI provides services and in-depth information that enable its members to perform industry-specific risk mitigation on suspect counterfeit, high-risk, and non-conforming parts and identify problematic suppliers and customers.
Among ERAI’s host of risk assessment tools is the world’s largest database of suspect counterfeit and nonconforming electronic parts.
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.
Reporting to GIDEP will allow for global communication of known counterfeit issues.
For more information please contact firstname.lastname@example.org