Management should have a formal system under Quality Assurance with adequate controls defined and implemented to identify and preclude Suspect/Counterfeit Items (S/CI) from being introduced into safety systems and applications that create potential hazards.
- Management should have a formal system of controls in place for assurance that all items procured meet the requirements for their intended use.
- Management should have a system of mechanisms to continuously maintain current, accurate, updated information on SC/Is and associated suppliers using all available sources.
- Management should have a training program with detailed records that ensures managers, supervisors, and workers of S/CI controls are being trained and informed on prevention, detection, and disposition of S/CIs.
- Management should ensure that the standards and methods used for determining the acceptability of items are continuously reviewed, and based on consensus standards and/or commonly accepted industry practices consistent with applicable law.
- Management should have S/CI controls that include Engineering involvement in the procurement process, notably in the development of specifications during inspection and testing and when replacing, maintaining, or modifying equipment.
- Management should have procurement procedures that preclude the introduction of S/CIs by: (1), identifying technical and QA requirements; (2), accepting only those items that comply with procurement specifications; and (3), inspecting inventory and storage areas to identify, control, and disposition S/CIs.
- Management should have testing methods approved by Engineering for the testing of procured or in-place S/CIs.
- Management should have routine maintenance cycles or inspection activities for their safety as well as non-safety systems that shall include provisions for the identification of S/CIs.
- Management, both federal and contractor, should have established policies and procedures using a government-wide system, Government/Industry Data Exchange Program (GIDEP), for exchanging information on nonconforming products and materials among other agencies.
- Management, both federal and contractor, should have specific procedures for receiving and disseminating S/CI information through their respective Inspectors General or other appropriate officers.
- Management, both federal and contractor, should notify their suppliers of nonconforming products in accordance with GIDEP procedures (in addition to the required actions specified in FAR Part 46.407).