Download - Counterfeit Material Training
Suspect/Counterfeit Item (S/CI) Awareness Training
What does Quality have
to do with Safety??
CPVC pipe touching the flue pipe? The fix?
Slip some cardboard between the warm flue pipe and melt-able plastic!
DefinitionsSuspect Item
Indication by visual inspection, testing, documentation, or other information that the item does not conform to established Government or industry-accepted specifications or national consensus standards e.g., UL, ASTM, SAE, ISO, ANSI
Suspect items must be further investigated to determine if they are counterfeit. When an item contains indications, but insufficient evidence of irregularities, it may be declared suspect
DefinitionsCounterfeit Item
A suspect item that isA copy or substitute without legal right or authority
to do so, or One whose material, performance, or characteristics
are knowingly misrepresented by the vendor, supplier, distributor, or manufacturer
If a product can be manufactured, it can also be counterfeited
Regulating Standards and Codes
The purpose of Regulating Codes:to ensure safetyto prevent catastrophic failures and the
resultant loss of life, injury, and property
Sets of Engineering requirements that are deemed necessary for safe design, maintenance, and construction
Why we have to follow codes and standard Federally regulated Required by OSHA standards
Code Requirements in the Field There are many industry regulatory codes to which
our clients and Turner must conform to in manufacturing and construction.
Examples: ASME - American Society for Mechanical Engineers
B31.1 – Power Piping B31.3 – Process Piping Section I - Power Boilers Section IX - Welding and Brazing Qualifications
API – American Petroleum Institute API 1104 – Welding of Pipelines and Related Facilities API 650 - Welded Tanks for Oil Storage API 510 – Pressure Vessel Inspection Code: In-Service
Inspection, Rating, Repair, and Alteration AWS – American Welding Society
AWS D1.1 - Structural Welding Code -Steel ANSI Standards
Manufacturing Code Requirements
Manufacturers are also required to follow specific codes and standards in product design, development, and manufacturing.
Many products are being imported that do not follow these standards.
- Customs caught $23 million electrical counterfeit in 2008, a 46% increase from 2007
Risks of Using S/CIs S/CIs are considered to be substandard materials and
failure could result in:An operational safety problemUnacceptable risk of injury to workers or the publicEnvironmental damage
Of particular concern are when S/CI are used:In a safety systemAt a critical load path
A structural component, such as a bolt, in a crane,hoist, or other handling or lifting equipment that bears the load being lifted or moved
Why should we care? Project: Huadian Datong 2x300
MW - China
Operation: In commissioning for six weeks at the time of failure.
Date of failure: 10/31/06
Fluid conditions: Steam at 2538 psig (175 barg), 1006 ºF(541ºC)
Material: ASTM A335 P91 – 18” OD, 1.693 in (43mm) wall (seamless pipe)
Result: two people died, others were listed as critical, and many were injured.
Material was a forgery sold through Houston, originating from China
Why should we care? … Continued
Industrial items that are commonly counterfeited include:high-strength mechanical fasteners (e.g., bolts,
washers, and nuts)lifting equipment (e.g., slings, shackles, and clevises)valves, pipe-fittingsFlangesBatteriesextension cordselectrical circuit breakersRelaysConnectorsmiscellaneous other electronic componentsLubricantsadhesives
Why should we care? … ContinuedExamples of locations in which counterfeit items have
been discovered include:
cranes, elevators, and fork lifts: critical load paths of lifting equipment;
aircraft: engines and attachments, wings, tails, or landing gear;
vehicles: engines, brakes, or steering mechanisms; and
facilities: valves, compressors, and vessels used to contain radioactive fluids, high temperature or high-pressure steam or fluids, or other hazardous material or safety systems supporting safe operation or shutdown of a facility or process.
DOE Bolt Head mark Lists
Hoisting and Rigging Example
Lifting HookAltered working load limit (WLL) markingGrind marksHand stamped
rather thancast mark
Crosby Shackle counterfeit – circulating in Europeand Africa (authentic Crosby on left)a) Crosby name embossed per Crosby logo, b) should see CEmark, c) 45-degree angle markings, d) pin stamped on headwith traceable ID number (www.imca-int.com/safetyflashes)
Flange Examples
Suspect IndicatorsHand stampedASA 150 CHINA
Meaningless information.ASA is an obsolete
consensus standards organization
Visual—Construction
150 lb rated flange should be 0.940” thickThis one is only
0.69920” thick
Circuit Breaker ExampleSuspect indicators
Missing labelsLeft - Counterfeit
Used 600 volt, 100 amp breaker sold as “new”
Right - GenuineOriginal Breaker
Counterfeit Genuine
Visual Inspection Indicators
Known S/CIThe item or component matches the
description of one that is listed on a suspect item listDOE Suspect/Counterfeit Fastener Headmark ListFastener Quality Act (FQA)
» http://ts.nist.gov/WeightsAndMeasures/fqa.cfm
Country of origin is China, Taiwan, India, Korea, or Mexico and has no manufacturer mark
Visual Inspection IndicatorsSurface changes
Wear marks or scratches on external surfaces or “new” products
Heat discoloration marksMetallic items are pitted or corrodedCasting markings ground off and re-stamped
with other markingsSigns of weld repairs
Visual Inspection IndicatorsElectrical Components
Underwriters Laboratories (UL) marks missing one or more of the four elements:UL trademarkThe word LISTED
in capital lettersProduct identityControl number
There is a UL mark on the package, butnot on the product
Visual—Genuine UL Listing Marks
How to identify counterfeit UL markshttp://www.ul.com/ace/fake.html
The new holographic label will be available for manufacturers on July 1, 2008
It will be required worldwide on all new production in the 32 hologram categories starting July 1, 2009http://www.ul.com/marks_labels/hologram.html
Visual Inspection Indicators
ConstructionAssembled items fit poorlyConfiguration is not consistent with other
items from the same supplierConfiguration varies from the supplier
literature or drawingsHandmade parts are evident
rough-cut or evidence of cutting/dressing with hand tools
Obvious attempts to repair or beautifyexcess paint, wire brushing, hand-painted touch-up,
painted stainless steel
Visual Inspection IndicatorsPackaging
Inconsistent vendor name on the item and on the shipping container, or no name on the container
Shipping boxes contain mixed batch numbers, expiration dates, and UPC codes
Unusual packaging and boxing of itemsInconsistent with the manufacturer’s normal packaging
or documentation requirementsQuestionable or meaningless numbers on the item(s) or
packagingObviously changed labeling (crossed out or erased)Inconsistent appearances of items in the same shipmentPacking material includes newspapers from a foreign
country
Visual—Packaging
Erased markings on shipping box
Square washers/spacersBoth types received in
the same shipmentThe genuine item has
the proper markingsGenuine Counterfeit
Documentation IndicatorsAltered Documents
Excessively faded or unclear or missing dataUse of correction fluid or correction tapeType style, size, or pitch change is evident Data on a single line is located at different
heightsLines on forms are bent, broken, or
interrupted indicating data has been deleted or exchanged by “cut and paste”
Handwritten entries are on the same document where there is typed or preprinted data
Text on page ends abruptly and the number of pages conflicts with the transmittal
Documentation IndicatorsSignatures and initials
Corrections are not properly lined-out, initialed and dated
Document is not signed or initialed when required
The name of the document approver, or title, cannot be determined
Approvers name and signature do not matchDocument has missing or illegible signature,
initialsDocument is not traceable to the items
procured
Documentation Indicators
ContentTechnical data is inconsistent with code or
standard requirementsCertification or test results are identical
between all tested itemsNormal variations should be expected
Documentation is not delivered as required on the purchase order, or is in an unusual format
Documentation Indicators
Procurement IndicatorsQuoted price for the item is unusually
discounted or lowUnusual disclaimers, or denials, of
responsibility for the accuracy of the test results
The supplier is not a manufacturer’s authorized distributorRequest a sample to test in the intended
application prior to purchase or purchase a small lot
Dimensions of the item are inconsistent with the specification
More InformationOffice of Assurance S/CI Website
http://www-group.slac.stanford.edu/oa/suspectcounterfeit.htm Office of Assurance S/CI SharePoint Site
https://slacspace.slac.stanford.edu/sites/assurance/SCI/ DOE HSS S/CI Website
http://www.hss.energy.gov/csa/csp/sci/
UL Anti-Counterfeiting Operations http://www.ul.com/ace/
UL Public Notices http://www.ul.com/media/notices.html
SourcesSuspect/Counterfeit-Defective Items Awareness
Training for DOE and Contractor Employees http://www.hss.energy.gov/CSA/CSP/sci/LANL1030
5awarenesstraining.pdf
Suspect/Counterfeit Items Information Guide for Subcontractors/Suppliershttp://www.efcog.org/wg/ism_qa/docs/EFCOG_Alert
s/SCI_Guide_for_Suppliers.pdfSuspect/Counterfeit Items Awareness Training
(DOE HSS)http:/www.hss.energy.gov/CSA/CSP/sci/SCIAwaren
essTrainingManual062007.pdf