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On February 3, AIA submitted a comment letter to the Federal Acquisition Regulatory Secretariat of the U.S. General Services Administration on behalf of its member companies in response to FAR CASE 2012—032, a proposed rule regarding “Higher-Level Contract Quality Requirements” to support initiatives pertaining to the proliferation of counterfeit parts.

AIA’s letter pointed out that the A&D industry already has in place sound management systems to address the counterfeit parts issue. Further, the letter addressed the following concerns: 1) the scope of the proposed rule is unduly broad, extending counterfeit prevention requirements beyond electronic parts; 2) the proposed rule broadens the application of higher quality standards beyond commodity-specific procurement activities, which in the long-run would cause unintended product costs to the government with no additional benefits; 3) expanding the scope of the Contractor Purchasing System Review process would intrude on existing industry business processes; 4) small businesses would be unduly burdened by the regulation; 5) commercial items generally and commercial off-the-shelf items in particular should be extended safe harbor exemptions by the government; and 6) in the fight against counterfeit parts, a more effective government focus would be to strengthen policy associated with obsolescence management as this is a key contributor to counterfeit risk.

AIA also co-signed a letter on the subject submitted by the Council of Defense and Space Industry Association. This combined approach ensures multi-industry solidarity with the prominent messages being conveyed to the FAR council prior the incorporation of the pending rule.

AIA and its member companies are committed to detecting and avoiding the proliferation of counterfeit parts sold in the global market and those potentially in the aerospace and defense supply chain. Initiatives already supported by industry  provide the foundation to ensure civil aviation safety and tactical military superiority remains uncompromised.

For more information regarding the AIA Comment Letter, please contact: Gery Mras, AIA’s Director, Life Cycle Management, (703) 358-1065.

To review all Comment Letters pertaining to FAR CASE 2012-032, please visit:!docketDetail;D=FAR-2012-0032

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