Presentation on theme: "Counterfeit, Suspect, Fraudulent Item (CSFI)"— Presentation transcript:
1 Counterfeit, Suspect, Fraudulent Item (CSFI) Developing the NRC CSFI Response CommunityDOE Conference CallNov. 11, 2009Counterfeit, Suspect, Fraudulent Item (CSFI)Daniel PasqualeSr. Operations EngineerQuality and Vendor BranchOffice 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 criticalEncourage a questioning attitudePerform thorough receipt inspectionsVerify procurement requirementsProvide CSFI training to QA/QC receipt inspectorsMake Current CSFI information availableMaintain a comprehensive CGD program
4 Program Strategies The Offense Self Assess – and be criticalZero tolerance policy for counterfeitingSupplier selectionKnow your suppliers (Upstanding)Assess supplier’s return & scrap/disposal policiesPrecise procurement specifications based on engineering inputIT protection of Intellectual PropertyCommunity Watch programsOutreach efforts
5 Some Proactive Best Practices Protect Your Intellectual PropertyRegister patents & trademarksImpose strong IP procurement clauses including specific CSFI languageQuestion the supplier’s IP controlsInstitute anti-fraud techniquesMaintain Robust Procurement ControlsPerform vigilant receipt inspections that include CSFI elementsInclude a CSFI element for repair/returns receipt inspectionsControl disposal of process scraps, rejects, un-repairable returns etcTrust but verifyKnow Your SuppliersUse O.E.M. authorized distributorsEmploy rigorous supplier selection processesMaintain short supply chains
6 Some Proactive Best Practices Communicate and Maintain Relationships with the O.E.MSeek O.E.M. assistance In detecting CSFIEnsure that the O.E.M. also has a robust CSFI programTake ActionReport known or suspected CounterfeitingGuard Intellectual PropertyTake appropriate legal actionsStay CurrentMonitor counterfeiting newsParticipate in related industry committeesShare informationThe NUPIC Vendor Interface Committee MeetingJune 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 programWorking with NUPIC to enhance their audit processWorking with EPRI’s Technical Advisory Group (TAG) on CSFICooperating with DHS’s Anti-Counterfeiting task forcesImproving communications and sharing information with the nuclear community
8 COMMUNITY WATCH PROGRAMS A community-based organization working together to combat CSFI activity:Take positive stepsShare current information of new trends in CSFIEstablish consistent programs for combating CSFI activityAwareness of & access to the various related government agenciesDevelop industry standardsEvaluate CSFI claimsTraining for Inspectors, Purchasers and QA personnel
9 DEVELOPING THE NRC’S CSFI COMMUNITY Internal NRC Family – 1st TierNRO, Quality & Vendor Branch-BWRNRO, Quality & Vendor Branch-PWRNRR, Vendor Branch – Operating UnitsNMSS/SFST – Nuclear Fuel StorageNMSS/FCSS – Nuclear Fuel TransportOpE (Operational Experience)ConE- (NRC-Construction Experience)OI (Office of Investigations)OAC (Office Allegations Coordinator)OE (Office of Enforcement)ADM/DC (Excluded Parties List)NRC RegionsIRS/IAEA (International Reporting System)ConX- (NEA-Construction Experience)
11 Outreach Efforts Government Information Data Exchange Program (GIDEP) ♦ Department of DefenseGovernment Information Data Exchange Program (GIDEP)Diminishing Sources and Material Shortages (DMSMS)NASAAerospace Standard AS5553, “Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition♦ Department of EnergySuspect/Counterfeit or Defective Items Program (S/CDI)Occurrence Reporting and Processing of Operations Information (ORPS)♦ Department of CommerceInternational Trade Administration, Office of Energy and EnvironmentManufacturing & ServicesBureau 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 – NRCConE: Construction Experience - NRCOpEx: Operating Experience - INPOEPIX: Equipment Performance & Information Exchange-INPOGIDEP: Government Industry Data Exchange ProgramSCI: Suspect & Counterfeit Items – DOEEPLS: Excluded Parties List System - GAOCPSC: Consumer Protection Safety CommissionTheTrueCosts.org: U.S. COCSTOPFAKES.gov: Joint Effort hosted by DOCIRS: Incident Reporting System – IAEAConX: 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 alsoMaintain a robust CSFI programRefer to current NRC guidanceProtect your Intellectual Property (IP)Incorporate Best PracticesBuild and maintain a solid CSFI communityFederal agenciesIndustry communitiesSupply chain
15 QUESTIONS Daniel Pasquale Sr. Operations Engineer Quality and Vendor BranchOffice of New Reactors
Your consent to our cookies if you continue to use this website.