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POLICY AND PROCEDURE FOR CONTROLLING SUSPECT/CONTERFEIT ITEMS A suspect item is one in which there is an indication by visual inspection, testing, or other information that it may not conform to established government or industry-accepted
specifications or national consensus standards. A counterfeit item is a suspect item 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 the vendor, supplier, distributor, or manufacturer. The use of suspect/counterfeit items (S/CIs) can lead to unexpected failures and undue risk of mission impacts, environmental
impacts, and personal injury, contamination, or death. For these reasons, Berkeley Lab has instituted mitigating measures for the prevention, detection, and disposition of S/CIs at the Laboratory.
Identification The range of items at the Laboratory that should be considered as possible S/CIs includes the following:
- High-strength fasteners (bolts, screws, nuts, and washers)
- Electrical/electronic components: circuit breakers, current and potential transformers, fuses, resistors, switch gear, overload and protective relays, motor control centers, heaters, motor generator sets,
DC power supplies, AC inverters, transmitters, computer components, semiconductors
- Piping components: fittings, flanges, valves and valve replacement products, couplings, plugs, spacers, nozzles, pipe supports
- Pre-formed metal structures, elastomers (O-rings, seals), spare/replacement kits from suppliers other than original equipment manufacturers, weld filler material, diesel generator speed governors and pumps
DOE maintains a list of S/CIs and identification guidance on the DOE web site at http://www.sci.doe.gov
.Procurement
- Any item known to have been counterfeited in the past (e.g., Grades 5 and 8 high-strength bolts, circuit breakers, and other S/CIs listed on the DOE S/CI web site) should be procured only from qualified or
dedicated suppliers, particularly items intended for use in safety systems or critical applications. The Berkeley Lab Procurement Department can qualify suppliers and provide technical specifications and
quality clauses prohibiting delivery of S/CIs in the purchase orders and contracts.
- High-strength fasteners (graded bolts, screws, nuts, and washers) must be purchased directly through the Procurement Department. Procurement buyers will purchase from prequalified suppliers and will retain
the manufacturer's certificate of conformance and/or certified material test report. Once on site, high-strength fasteners must be segregated and secured from the general stock to eliminate mixing with
nongraded fasteners and to prevent general purpose use.
- Onsite stores, shops, and end users should inspect newly received items known to have been counterfeited in the past. S/CI identification guidance is provided on the DOE S/CI web site. Periodic
inspection of open stock and storage areas should continue to ensure they have been purged of S/CIs.
Installed Items
- During routine Laboratory inspections of facilities and equipment (e.g., self-assessment, EH&S functional inspections, maintenance and construction inspections), consideration should be given to identify
S/CIs (identification guidance provided on the DOE S/CI web site). Additional training for personnel to recognize S/CIs can be arranged through the Office of Assessment and Assurance (OAA) in the
Environment, Health and Safety Division.
- If an installed item is suspected of being a S/CI, OAA must be contacted to coordinate any engineering evaluation, verification testing, or disposition process.
- If it is determined that the S/CI in safety systems and critical applications (e.g., heavy equipment, critical load paths in lifting equipment, and facility structures) can adversely affect the environment or
create a safety hazard, the system or application must be locked/tagged out and the S/CI removed and replaced. If there is no adverse affect or creation of a hazard, the S/CI must be identified and entered
into the Division's Laboratory Self-Assessment Database (LSAD), and either removed and replaced during routine maintenance or determined to remain in place. If the S/CI is to remain in place, the structure
or equipment must be tagged or marked, and the LSAD entry so annotated and closed out.
- For non-safety systems and noncritical applications, the S/CI must be identified and entered into LSAD, and either removed and replaced during routine maintenance or determined to remain in place. If the S/CI is
to remain in place, the structure or equipment must be tagged or marked, and the LSAD entry so annotated and closed out.
Disposition and Reporting
- If an S/CI requires removal, OAA must coordinate and document the disposition. S/CIs must be removed from the work/use site and transferred to the LBNL Warehouse to be temporarily stored in a segregated
area. Efforts will be made by the Procurement Department to identify the supplier, manufacturer, or distributor to seek restitution for the Laboratory.
- OAA must report all discovered S/CIs to the local DOE Office of Inspector General (OIG) and the cognizant DOE operations office manager by means of the Occurrence Reporting and Processing System (ORPS).
- After the S/CI is no longer needed as material evidence by OIG, the LBNL Warehouse will coordinate the destruction or alteration of the S/CI to render them unusable.
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