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