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DOE HSS Guidelines for Counterfeit Valves Cheat Sheet (DRAFT) by [deleted]

DOE HSS guidelines for Counterfeit Valves

This is a draft cheat sheet. It is a work in progress and is not finished yet.


In 2007 the Department of Energy’s Health, Safety and Security Office of Corporate Safety Analysis issued Rev 6 of Suspect/ Counte­rfeit Items Awareness Training, available at www.hs­s.e­ner­gy.g­ov­/CS­A/C­SP/­sci­/SC­IAw­are­nes­sTr­ain­ing­Man­ual­062­007.pdf. Appendix B of that document lists indica­tions that render items suspect. They include:

A. General Indica­tions

Used component appearance
Unusual or inadequate packaging
Foreign newspapers used as packaging
Scratches on component outer surface
Evidence of tampering
Components with no markings
Pitting or corrosion
External weld or heat indica­tions
Questi­onable or meanin­gless numbers
Typed labels
Evidence of hand-made parts
Painted stainless steel
Ferrous metals that are clean and bright
Excess wire brushing or painting
Ground off casting marks with stamped marks in the vicinity
Ground off logo mark
Signs of weld repairs
Threads showing evidence of wear or dressing
Incons­istency between labels
Old or worn nameplates
Nameplates that look newer than the component
Missing manufa­ctu­rer’s standard markings and logos
Overla­pping stamps
Different colors of the same part
Traces of Prussian Blue
No specif­ication number
No size design­ation
Missing pressure class rating
Other missing design­ations per the specif­ication
Evidence of re-sta­mping
Deficient welds on chemic­al/­nuclear shipping casks
Thinner than expected
Parts identified as “China” only, or “Korea,” “Mexico,” “Thail­and,” “India”
Excess certif­ication logos (i.e. “UL,” “FM,” “CGA,” “AGA”) all on one valve body – not normal, usually will have one or two logos plus ANSI or ASME

B. General Valve Indica­tions

Wrench marks on valve packing glands, nuts, and bolts
Nameplates attached with screws rather than rivets
Poor fit between assembled valve parts
Dirty internals
Scratched or marred fasteners or packing glands
Gate valve: gate off-center when viewed through open end
Fresh sand-b­lasted appearance of valve bodies, eyebolts, fittings, stems
Loose or missing fasteners
Different types of hand wheels on valves of the same manufa­cturer
Some parts (e.g., hand wheels) look newer than rest of the valve
Improper materials (e.g., bronze nut on a stainless stem)
Post-m­anu­fac­turing alteration to identi­fic­ati­on/­rating markings
Indication of previous joint welding
Excessive standards markings (e.g. UL, FM, CGA, AGA) (check manufa­cturer literature for standards they use)
Valves will not open or close, even when wrench applied.
Substa­ndard valves mixed in with standard valves (subst­itu­tion)

Immediate actions: Robust Procur­ement Controls

Use approved distri­bution networks.
Safeguard design inform­ation, prevent it from becoming available to counte­rfe­iters.
Question suppliers’ return policies and design control measures—how do they control parts and subass­emblies purchased from sub-tier suppliers?
Incorp­orate terms and conditions that address expect­ations (and conseq­uences) relative to counte­rfeit, fraudulent and substa­ndard items.
Open lines of commun­ication with suppliers, ask them to provide instru­ctions for how to recognize and avoid any counte­rfeits if they know of instances where the items you purchase have been counte­rfe­ited.
Trust but verify—perform diligent inspection in receiving items procured, partic­ularly when they are provided by a new supplier or must be procured outside of approved distri­bution networks.
Pursue incidents when they are identi­fied; notify the authentic OEM; prosecute if possible