PRODUCT INTEGRITY - Detecting Counterfeit Parts. Roger Southgate Director, Avionics Certification St. Petersburg, Florida September 21, 2010

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1 PRODUCT INTEGRITY - Detecting Counterfeit Parts Roger Southgate Director, Avionics Certification St. Petersburg, Florida September 21, 2010

2 Florida Cradle Of US Commercial Aviation First Commercial Passenger Air Service St. Petersburg Tampa Airboat Line 1 January Miles / 23 Minutes Benoist Flying Boat Florida Airways Corp., Est E Rickenbacker & Major Reed Chambers Stinson Detroiter / Stout 2-AT Pullman Uninsured accident led to receivership Reed Chambers designed an aviation insurance program for airlines and later became head of US Aviation Underwriters 2

3 In The Early Days Aircraft parts were produced from original design drawings, wherever the capability existed Cycle or automotive shops essentially the approved suppliers Industry regulation began with the 1926 Air Commerce Act and the 1958 Federal Aviation Act, which created the DoT and FAA in 1967 No established concept of Approved Parts and Suppliers Conversely, no recognition of Unapproved or Counterfeit Parts Parts were just parts Created minimum performance and safety requirements for type design approval. Established approved production and inspection systems to assure conformity with type design 3

4 The Emergence Of Counterfeit Parts SAE Aerospace Standard 5553 defines a counterfeit part: A suspect part that is a copy or substitute without legal right or authority to do so or one whose material, performance, or characteristics are knowingly misrepresented by a supplier in the supply chain Increasing value of Aerospace & Defense commodities creates a potential for profit to those who would introduce lower quality, used, unapproved or counterfeit parts into the supply chain The long life-cycle of aircraft and their component parts, including aviation electronics, introduces issues of part obsolescence and scarcity of suitable replacements available from Original Component Manufacturers Some Service Life Examples Douglas DC-3-75 years and counting Lockheed C years Boeing years 4

5 Fast Forward To Today s Aerospace & Defense Environment 5

6 Escalation Of Aviation Electronics Counterfeit Parts Increasing A&D reliance on commercial (COTS) parts produced for shorter life-cycle applications, such as consumer electronics Current economy driving reduction of parts inventories by manufacturers and distributors Evolving electronic waste regulations promote growth of electronic part recycling 2008 BusinessWeek Report Dangerous Fakes ine/content/08_41/b htm 6

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8 Scope Of The Counterfeit Parts Threat January 2010 US DoC Report Counterfeit Electronics Increase in the Rate of Reported Counterfeit Incidents Over 150% Growth in 4 Years Microcircuits Represent Over 80% of 2008 total More than 50% of Original Component Manufacturers encountered at least 1 counterfeit incident Fastest growing segment by part resale value was the $1-10 range Fastest growing segment by counterfeit type was used parts remarked as higher-grade/mil-spec parts Top 3 counterfeit sources were China, Taiwan and the Philippines March 2010 US GAO Report to Congress Defense Supplier Base Found existing procurement and quality control practices limited in their ability to prevent and detect counterfeit parts in DoD s supply chain Broad-based examples of counterfeit parts, including GPS Oscillators used by the Air Force and Navy in over 4,000 Navigation systems 8

9 Implications Of The Counterfeit Parts Threat - Product Reliability and Aircraft Accident/Incident Investigations The principal risk to a product containing an undetected counterfeit part is reduced reliability Aircraft accident/incident investigation processes now include checks for any history and potential role of an undetected counterfeit part May be challenging to determine in post-accident equipment evaluation A - Review applicable product history 1. Installed equipment service history, by S/N 2. Field reliability (RECAP) 3. Airworthiness Directives (AD) 4. Mandatory Occurrence Reports (MOR) 5. Service Difficulty Reports (SDR, ASRS) 6. Problem Reports (PR, MDR) 7. Unapproved or Counterfeit parts 9

10 Counterfeit Example 1 Commercial Part Suspect Device Visual Inspection Rockwell Collins identified 31 suspect counterfeit devices, marked MAX3490EESA with a 446 date code but contain die from a lowergrade Sipex SP3490EN. This part is broadly used in avionics data bus applications. Maxim verified the 446 markings to be valid Maxim date codes. No significant differences were apparent during visual inspection. 29 suspect devices were electrically tested per the MAX3490E specification. All 29 devices failed functional tests. Maxim Device Visual Inspection 10

11 Counterfeit Example 1 Commercial Part, Cont d Suspect Device X-Ray X-Ray images show distinct differences in the bond wire layout of the suspect device Maxim Device X-Ray 11

12 Counterfeit Example 1 Commercial Part, Cont d De-encapsulating the devices reveals the die manufacturer De-encapsulated Suspect MAX3490EESA Close up view of Sipex die marking 12

13 Counterfeit Commercial Part Examples 2 and 3 This Microprocessor was marked as a Revision D device. De-encapsulation and die inspection told a different story A suspect part was diverted for evaluation. X-Ray image showed there was no die at all 13

14 Top Level Airline Product - Counterfeit Nameplate New Rockwell Collins Nameplate Typical example of excessive coating wear indicating a nonanodized aluminum nameplate Used Counterfeit Nameplate In this case, which also involved the installation of unapproved software, Rockwell Collins investigation resulted in successful legal claims and Unapproved Part reports being submitted for FAA investigation and enforcement action 14

15 Top Level Airline Product - Counterfeit Nameplate, Cont d Rockwell Collins Nameplate. Approved Font Counterfeit Nameplate. Unapproved Font Notice alignment in these areas 15

16 Counterfeit Detection At Rockwell Collins Substantial investment in Component And Material Evaluation Laboratories (CAMEL) detection tools Sonoscan, X-ray, Gas Chromatography, Integrated Circuit (IC) Testing Inorganic Analysis - Energy Dispersive X-Ray (EDX) & Scanning Electron Microscopy (SEM) Organic Analysis - Fourier Transform Infrared (FTIR) Spectroscopy Optical Deflection Analysis - Shadow Moiré Climatic & Dynamic Testing 16

17 Counterfeit Avoidance And Risk Mitigation At Rockwell Collins Procurement Controls Directed parts procurement from Original Component/Equipment Manufacturers (OCM/OEM) and Franchised Distributors Management of large supply base with many Franchised Distributors, including some who also broker parts Purchasing procedures containing stringent traceability certification, auditing, parts testing and approval processes when procurement from independent Part Brokers becomes necessary Focus on redesign of products affected by part obsolescence, to avoid exposure to counterfeit market Participation in Government & Industry Risk Mitigation Initiatives Examples: 17

18 Government Enforcement California MVP Micro, Inc. Owner Pleads Guilty in Connection with Sales of Counterfeit High Tech Parts to the U.S. Military Source: United States Attorney s Office Washington, D.C. - Mustafa Abdul Aljaff, 30, of Newport Coast, California, pleaded guilty today to Counts One and Six of an Indictment charging him and others with Conspiracy to Traffic in Counterfeit Goods and to Defraud the United States, and Trafficking in Counterfeit Goods. For the crime of Trafficking in Counterfeit Goods, he faces up to 10 years incarceration, a fine of $2,000,000, a threeyear term of supervised release, an order of restitution. Aljaff and others are alleged to have operated the conspiracy through a number of California companies: MVP Micro, Inc., BeBe Starr, Consulting, Inc., Red Hat Distributors, Inc. (also known as RH Distributors, and Red Hot Distributors ), Force-One Electronics, Inc., Labra, Inc., subsequently renamed Labra Electronics, Inc., then Becker Components, Inc., and Pentagon Components, Inc. They also operated websites related to those companies, including: and 18

19 Proposed Government & Industry Counterfeit Risk Mitigation The Aerospace Industries Association represents the nation's leading manufacturers and suppliers of civil, military, and business aircraft, helicopters, unmanned aircraft systems, space systems, aircraft engines, missiles, materiel, and related components, equipment, services, and information technology Rockwell Collins is participating with many other companies in preparing the AIA Counterfeit Integrated Process Team draft recommendations for: Industry and Government adoption of SAE AS5553 Counterfeit Electronic Part, Avoidance, Detection, Mitigation and Disposition Strengthening counterfeit reporting, counterfeit parts control plans, management of part obsolescence and counterfeit awareness and detection training Strengthening the GIDEP process and limiting the liability of companies that accurately report counterfeit parts through GIDEP 19

20 Our Common Goal Continued Operational Safety 20

21 Questions Thank you for your attention Questions? Copyright 2010 Rockwell Collins, Inc. All rights reserved. 21