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Counterfeit, Suspect, Fraudulent Item (CSFI)

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Presentation on theme: "Counterfeit, Suspect, Fraudulent Item (CSFI)"— Presentation transcript:

1 Counterfeit, Suspect, Fraudulent Item (CSFI)
Developing the NRC CSFI Response Community DOE Conference Call Nov. 11, 2009 Counterfeit, Suspect, Fraudulent Item (CSFI) Daniel Pasquale Sr. Operations Engineer Quality and Vendor Branch Office of New Reactors

2 Generic Communication IN 2008-04 “Counterfeit Parts Supplied To Nuclear Power Plants”
The 3 characteristics of an effective procurement and dedication plan: The involvement of engineering staff in the procurement and product acceptance process; Effective source inspection, receipt inspection, and testing programs; Thorough, engineering-based programs for review, testing, and dedication of commercial-grade products for suitability for use in safety-related applications.

3 Program Strategies The Defense
Self Assess – and be critical Encourage a questioning attitude Perform thorough receipt inspections Verify procurement requirements Provide CSFI training to QA/QC receipt inspectors Make Current CSFI information available Maintain a comprehensive CGD program

4 Program Strategies The Offense
Self Assess – and be critical Zero tolerance policy for counterfeiting Supplier selection Know your suppliers (Upstanding) Assess supplier’s return & scrap/disposal policies Precise procurement specifications based on engineering input IT protection of Intellectual Property Community Watch programs Outreach efforts

5 Some Proactive Best Practices
Protect Your Intellectual Property Register patents & trademarks Impose strong IP procurement clauses including specific CSFI language Question the supplier’s IP controls Institute anti-fraud techniques Maintain Robust Procurement Controls Perform vigilant receipt inspections that include CSFI elements Include a CSFI element for repair/returns receipt inspections Control disposal of process scraps, rejects, un-repairable returns etc Trust but verify Know Your Suppliers Use O.E.M. authorized distributors Employ rigorous supplier selection processes Maintain short supply chains

6 Some Proactive Best Practices
Communicate and Maintain Relationships with the O.E.M Seek O.E.M. assistance In detecting CSFI Ensure that the O.E.M. also has a robust CSFI program Take Action Report known or suspected Counterfeiting Guard Intellectual Property Take appropriate legal actions Stay Current Monitor counterfeiting news Participate in related industry committees Share information The NUPIC Vendor Interface Committee Meeting June 17 & 18, 2009

7 WHAT IS THE NRC DOING? Issuance of IN , “Counterfeit Parts Supplied To Nuclear Power Plants” (April 7, 2008) Developing the NRC’s CSFI community (June 4, 2009) Continuing to enhance the NRC’s Vendor Inspection program Working with NUPIC to enhance their audit process Working with EPRI’s Technical Advisory Group (TAG) on CSFI Cooperating with DHS’s Anti-Counterfeiting task forces Improving communications and sharing information with the nuclear community

8 COMMUNITY WATCH PROGRAMS
A community-based organization working together to combat CSFI activity: Take positive steps Share current information of new trends in CSFI Establish consistent programs for combating CSFI activity Awareness of & access to the various related government agencies Develop industry standards Evaluate CSFI claims Training for Inspectors, Purchasers and QA personnel

9 DEVELOPING THE NRC’S CSFI COMMUNITY
Internal NRC Family – 1st Tier NRO, Quality & Vendor Branch-BWR NRO, Quality & Vendor Branch-PWR NRR, Vendor Branch – Operating Units NMSS/SFST – Nuclear Fuel Storage NMSS/FCSS – Nuclear Fuel Transport OpE (Operational Experience) ConE- (NRC-Construction Experience) OI (Office of Investigations) OAC (Office Allegations Coordinator) OE (Office of Enforcement) ADM/DC (Excluded Parties List) NRC Regions IRS/IAEA (International Reporting System) ConX- (NEA-Construction Experience)

10 The NRC’s CSFI Community
TIER 1 (Family) TIER 2 (Neighborhood) TIER 3 (Associates) TIER 4 (Global) NRO/CQVB NEI DIA IAEA NRR/EQVB INPO GIDEP db IRS db NMSS /SFST EPRI US COC (CACP) US COC (GIPC) NMSS/FCSS NUPIC US DOD (DCIS) US DOC (BIS) NRC Event Reporting Program NIAC US Navy Dept (BMPCOE) INTERNATIONAL NUCLEAR REGULATORS Part 21 db EEI US DHS (ICE) US TR (E&ES ITAC) OpE db US DOE US DHS (CBP) US TR (AE&CG ITAC) ConE db S/CI db US CPSC db US PTO (FQA Markings) ConX db US DOC (ITA) US GAO (EPLS db) WTO Morning Reports db STOPFAKES.gov db UL db WIPO NRC OI NIST (FQA) NIST (MEP) APICS US DOS (IPR TP) NAM NEMA IPRTP ICC (CIB) INTERPOL

11 Outreach Efforts Government Information Data Exchange Program (GIDEP)
♦ Department of Defense Government Information Data Exchange Program (GIDEP) Diminishing Sources and Material Shortages (DMSMS) NASA Aerospace Standard AS5553, “Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition ♦ Department of Energy Suspect/Counterfeit or Defective Items Program (S/CDI) Occurrence Reporting and Processing of Operations Information (ORPS) ♦ Department of Commerce International Trade Administration, Office of Energy and Environment Manufacturing & Services Bureau of Industry & Security, Office of Technology Evaluation ♦ Nuclear Procurement Issues Committee (NUPIC) Commercial Nuclear Power Licensees & Suppliers ♦ Nuclear Energy Institute (NEI) ♦ Electric Power Research Institute (EPRI)

12 EXISTING DATA SOURCES 10 CFR Part 21 Reports - NRC
OpE: Operating Experience – NRC ConE: Construction Experience - NRC OpEx: Operating Experience - INPO EPIX: Equipment Performance & Information Exchange-INPO GIDEP: Government Industry Data Exchange Program SCI: Suspect & Counterfeit Items – DOE EPLS: Excluded Parties List System - GAO CPSC: Consumer Protection Safety Commission TheTrueCosts.org: U.S. COC STOPFAKES.gov: Joint Effort hosted by DOC IRS: Incident Reporting System – IAEA ConX: Construction Experience - NEA

13 NOW IS THE TIME TO SHARE CSFI INFORMATION
“I have suggested before that this kind of information (defective, counterfeit, or mis-used components) should be collected by all regulators and shared across national borders. Today I will modify my view by saying that this is not merely a good idea, but perhaps even a necessary one.” - NRC Commissioner and Former Chairman Dale E. Klein at the IAEA General Conference Senior Regulators Meeting, Vienna, Austria, October 3, 2008

14 SUMMARY The threat of CFSI is real – and growing
Industry vulnerabilities are growing also Maintain a robust CSFI program Refer to current NRC guidance Protect your Intellectual Property (IP) Incorporate Best Practices Build and maintain a solid CSFI community Federal agencies Industry communities Supply chain

15 QUESTIONS Daniel Pasquale Sr. Operations Engineer
Quality and Vendor Branch Office of New Reactors


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