The Suspect Counterfeit Quarantine SOP

Purpose

When anyone in the shop suspects a part is counterfeit, this procedure takes every unit of that part out of circulation within one working day, preserves the evidence a supplier or a regulator will ask for, finds any unit already installed, and closes the matter only on a written answer from the supplier. Without it, a suspect part gets set aside on a bench, drifts back into a bin, and goes into a wall the following week, and the shop has nothing to show the supplier but a story. Why provenance belongs to a part's rating in the first place is owned elsewhere; see related: Provenance Is Part of the Rating.

Scope

Covers any part, tool, meter or PPE item in stock, on a truck or on order that someone suspects is counterfeit, mislabeled or not what its listing claims, however the suspicion arose.

Does not cover: deciding whether a part is suspect in the first place (see related: How to Spot a Counterfeit Electrical Component), a genuine part under a manufacturer recall (see related: The Stock Recall Check SOP), or preserving a part that has already failed on a job and may be evidence in a loss (see related: How to Keep a Failed Part as Evidence). A suspect part that also failed in the field runs this procedure and that one together.

Roles and responsibilities

Procedure

1. Tag and isolate the unit in hand at the moment of suspicion. The finder fills a quarantine tag (number, date, finder, part, lot, where found, the reason in one line), ties it to the part or its box, and puts it in the locked quarantine bin at the shop or a sealed bag in the truck's cab, never back in a parts bin. Acceptance: the unit carries a numbered tag and is physically separated from usable stock, and the quarantine owner has the tag number by text or call the same day. Wrong looks like a part set "to one side" on a shelf or a note on the box with no number; stop rule: if no tag is at hand, the finder writes the tag fields on tape on the box and bags it, and nothing from that box is used on the current job. Hazard: if the suspect unit is already installed and energized or pressurized on the job in front of you, this step does not remove it; leave it in service only if it is not the protective device for that circuit or system, otherwise isolate that circuit or system, tag it out, and tell the customer it stays off until replaced.

2. Sweep the lot from shelf, trucks and open orders within one working day. The quarantine owner pulls every unit with the same part number and lot or date code from shop stock, each truck and any delivery not yet received, counts them against the purchase quantity, and tags them under the same quarantine number. Acceptance: units found plus units installed (step 3) plus units already scrapped equals units bought, or the gap is written down as a number. Wrong looks like a count that does not close, or a truck that was not checked; stop rule: an unchecked truck is reached by phone before its next job, and its tech pulls and bags the lot from the truck with a photo sent back, so the count can close the same day. Hazard: none at the shelf; at a truck, the bins are checked with the vehicle parked and off, not while the tech is driving.

3. Find every unit of the lot already installed. Search the installed-part records for the part number and lot or, where lots were not recorded, for the part number bought after the suspect purchase date, and list the jobs. Acceptance: every installed unit is named by job, customer and date, or the search period and method are written down where the record cannot resolve a lot. Wrong looks like installed units that trace to no job; stop rule: if the records cannot narrow the lot, every job using that part number in the window is treated as affected and goes to the owner for step 7's revisit decision. Hazard: none, desk work; the hazard sits at the customer's home, which is why a protective device found installed goes to the owner the same day rather than in the weekly review.

4. Photograph and document the evidence before anything else happens to it. Photograph one unit beside a known-genuine one where the shop has it: all faces, the label, the listing mark close enough to read its file number, the lot or date code, packaging, inserts, and a scale reading of each. Add the invoice, packing slip and the failed lookup. Acceptance: the evidence file holds at least six photos per suspect part type plus the invoice, and every photo is labeled with the quarantine number. Wrong looks like photos of the box only; stop rule: no unit is opened, tested to failure or returned before the photos are done, because the supplier and any regulator will want the part as found. Hazard: do not open a sealed device such as a breaker, a GFCI or a gas valve to look inside; that destroys evidence and, on anything with a spring or a charged capacitor, can release stored energy.

5. Notify the supplier in writing and ask for a written response. Email the supplier's account rep or returns desk with the quarantine number, part and lot, quantity bought and found, the specific reasons for suspicion, at least three photos, and two questions: where the supplier sourced this lot, and what disposition it wants. Ask for a written response within 10 working days, a shop default. Acceptance: a sent email with an acknowledgment, or a phone confirmation logged with the rep's name. Wrong looks like a call to the counter with nothing written; stop rule: no response in 10 working days goes to the supplier's branch manager in writing, and the shop stops buying that part number from that supplier until it answers. Hazard: none, desk work.

6. Report where the product type has a channel. The owner decides, the same week, which outside reports apply: the brand owner whose name is on the label (manufacturers run counterfeit investigations and want the lot), the U.S. Consumer Product Safety Commission's public reporting site for a consumer product that could cause injury, NIOSH for a respirator claiming an approval it does not hold, and EPA's violation reporting for refrigerant that is not what it claims. Acceptance: the file records, for each channel, "reported" with a date and confirmation, or "not applicable" with a reason. Wrong looks like nothing reported because the supplier is "handling it"; stop rule: if anyone was hurt or property damaged, report regardless of the supplier's answer and call the shop's insurer. Hazard: none, desk work. Section 15(b) of the Consumer Product Safety Act makes reporting mandatory for manufacturers, distributors and retailers of consumer products who learn of a possible substantial hazard; whether a shop that sells and installs counts is a question for your attorney (this is not legal advice), and voluntary reports are open to anyone.

7. Never install, use or resell; dispose only as the evidence allows. Quarantined units leave the bin for exactly three reasons: return to the supplier under a written return authorization, transfer to a manufacturer or regulator who asked for them, or destruction recorded with a witness after the close-out. The owner also decides each installed-unit revisit from step 3; a protective device is replaced within 2 working days, a shop default. Acceptance: the bin count matches the step 2 count less documented transfers, at every weekly check. Wrong looks like a short bin count; stop rule: a missing unit counts as installed until found, and step 3 is rerun. Hazard: at a revisit, the replacement is electrical, gas or pressure work and carries that trade's isolation: for a circuit device, de-energize and prove dead on a known live source before and after, per NFPA 70E Article 120 (120.5 in the 2021 edition, renumbered in 2024), with work practices at 29 CFR 1910.333(b)(2); on restoring, stand to the side of the panel as the breaker closes and confirm the new device performs its protective test before leaving.

8. Close out only on the supplier's written response. File the supplier's answer, the disposition record, the outside reports and the revisit list, and the owner signs the close-out. Acceptance: a written response is in the file, whether it confirms, denies or says the supplier cannot tell, plus a signed close-out date. Wrong looks like a file closed because the supplier issued a credit; stop rule: a credit without an answer on sourcing keeps the file open and the part number off that supplier's approved list until the sourcing question is answered. Hazard: none, desk work.

The record this produces

One quarantine file per suspect lot, kept with the purchasing records: tag numbers, the sweep count with its arithmetic, the installed-unit list, photos, supplier correspondence, each outside report with date and confirmation, the witnessed disposition, and the signed close-out. It is read by the owner deciding whether to keep the supplier, the next person who suspects the same part, an insurer after a loss, and a manufacturer or regulator tracing the lot. A tag:

QUARANTINE  Q-0417          DO NOT USE / DO NOT SELL
date found   Tue 10-07      finder   R. tech, truck 2
part         20 A GFCI receptacle, white, 10-pack box
lot / date   lot code on box only, none on device
where        truck 2 bin, job prep
reason       no listing mark on device body; box mark
             file number not found in lab directory
count here   1 box (10)     bin   shop locked bin B

Worked pass: a lot of GFCI receptacles

Step 1. A tech prepping a kitchen job opens a 10-pack of 20 A GFCI receptacles bought three weeks earlier from a supplier added in the spring. The devices carry no listing mark on their bodies, only on the box. He tags it Q-0417, bags it in the cab, texts the office manager the number, and takes genuine stock for the job.

Step 2. The purchase was 4 boxes of 10, 40 units. Found: 2 full boxes on the shop shelf (20), the tagged box (10), and a partial box on truck 4 holding 8. That is 20 plus 10 plus 8, 38 units. Units bought minus units found is 40 minus 38, a gap of 2.

Step 3. This step fails. The installed-part records show truck 4 installed 2 GFCI receptacles of that part number at a bathroom remodel eight days earlier, and the lot was not recorded on that job. The gap of 2 matches, but the record cannot prove those 2 came from this lot, so the stop rule applies: the job is treated as affected and goes to the owner the same day. Count closes: 38 found plus 2 treated as installed is 40.

Step 4. Suspect and genuine devices photographed side by side: 8 photos plus the invoice. The suspect weighs 4.6 oz against the genuine 5.9 oz; the box's file number has no match in the lab's directory. Nothing is opened.

Step 5. Email to the rep with Q-0417, the count of 40, five photos and the two questions; acknowledged the same afternoon.

Step 6. Reports to the brand owner named on the box and on the CPSC public site, both confirmations logged. NIOSH and EPA: not applicable.

Step 7. The bathroom devices are replaced two days later with genuine stock, under the step's isolation and proved-dead sequence; on restoring, each new device trips on its test button and on a plug-in tester and resets. The two removed devices join the bin, count 40.

Step 8. The supplier answers in writing on day 7: the lot came from a secondary distributor it has dropped, and it wants all 40 back under a return authorization. The brand owner asks for 4; 4 ship to it, 36 to the supplier, and the owner signs the close-out.

References

• Consumer Product Safety Act, Section 15(b), 15 U.S.C. 2064(b), reporting duties of manufacturers, distributors and retailers
• U.S. Consumer Product Safety Commission public product-safety reporting site
• NFPA 70E Article 120 (120.5 in the 2021 edition, renumbered in 2024), and OSHA 29 CFR 1910.333(b)(2), for the device replacement at a revisit
• See related: The Installed-Part Record SOP
• See related: How to Return a Suspect Part to the Supplier With Evidence