View Full Version : Validation Of Outsourced Special Processes under AS9100
Steve Weber 3rd April 2008, 03:17 PM We outsource special processes such as plating (chrome, Type I, II, & III anodize, nickle, etc.) What can we do to meet the standard requirements for validation AS7.5.2? Our auditor suggested purchasing a hand-held instrument to check the thickness ourselves and see if that meets the sspec requirements. We need something to satisfy the AS requirement and not a method that might create conflict with the vendor suppling the work.
world quality 3rd April 2008, 03:36 PM Steve,
See if your customer will accept this and have your supplier quality do a audit
and implement it and its requirements. Only the requirements that pretain to your process.
I would agree you need a elcometer or something to check and evrify the thickness.
If you need one for paint I can give you that to.
look under painting and plating for supplier quality here on the form and
download them (CQI-11 CQI-12)
Jeff Frost 3rd April 2008, 03:42 PM Steve,
I am assuming that you are saying AS9100 Clause 7.5.2 (It helps to tell us here at the cove which standard). It sound like your registrar is a little of his or her mark. Clause 7.5.2 with its aerospace adders relates to your special processes, not your suppliers.
Your suppliers are controlled through purchasing process 7.4.
Sidney Vianna 3rd April 2008, 03:46 PM But if you outsource a special process, you are still responsible to ensure it is validated. Obviously a thickness check is not adequate. That would defeat the definition of a special process that needs to be validated.
To what specs are these special processes supposed to be performed against? Many times, those specs define how the process gets validated.
One alternative (albeit costly) is for you to use NADCAP accredited suppliers for those processes.
Steve Weber 3rd April 2008, 05:12 PM Thanks Jeff, I'm new to this an appreciate your help. You are correct. The nonconformity deals with AS 7.5.2 (Validation Process)stating there is no objective evidence that company is requesting and keeping outsourced process records. We have a C of C but was informed that that was not the same as validation. How do we know that what they say they are doing is really being done?. I guess we did not know how to answer the auditor in a logical manner.
Jeff Frost 3rd April 2008, 07:53 PM Steve
Sidney is correct. Easiest way to handle this is to 1) perform a process audit at the supplier to the requirements of the specification. 2) Use OEM approved special processors (specified via PO), 3) Use NADCAP approved processors or 4) send a sample of the plated part to an independent lab and have it validated per the specification.
Look at the requirements of 7.4.3 of the AS9100 standard. If the plating is not considered a Key Characteristic or Critical to Flight Safety application then of one of the aerospace additional requirements listed plus a thickness and adhesion test may be only be required.
Kevin Mader 3rd April 2008, 09:01 PM Steve/All,
We might be confusing Validation with Verification. Interestingly, the registrar suggested a verification activity in order to satisfy a validation requirement. Purchasing the handheld device will probably satisfy two needs: 1) satisfying the registrar by fulfilling an expectation, 2) having the device available for the validation you will still need to perform (unless the supplier has one already, which they probably do).
Assuming that the AS requirement for validation of special processes is similar to the requirement in the medical device industry, the aim here is to qualify/validate the special process where 100% verification of an attribute would not be effective. Plating sounds like one to me. Investigate whether or not the plater has the ability to perform a process validation. If not, does your organization have the ability. If not, hiring a consultant to perform the validation for you might be the way to go.
What you will need to provide the registrar with is a summary report confirming that the process is capable and repeatable in delivering you product that meets specifications every time. The higher the degree of confidence you achieve, the less the need to do inspection from that supplier.
Back to the group…
Regards,
Kevin
Big Jim 4th April 2008, 01:17 AM Lets look at portions of 7.4.3 from AS9100B.
"Verification activities may include a) obtaining objective evidence of the quality of the product from suppliers (e.g., accompanying documentation, certicate of conformity, test reports, statistical records, process control)"
"b) inspection and audit at supplier's premises,"
"d) inspection of products upon receipt,"
"Where the organization utilizes test reposts to verify purchased product, the data in those reports shall be acceptable per applicable specification. The organization shall periodically validate test reports for raw material."
I hope I caught the pertinent portions here.
I wonder if they are suggesting periodic test reports? A common practice for this is to randomly select test reports to send samples (coupons) out for an independent lab to test and compare with the certs the supplier furnished. What I often see is something sent out every three to six months.
andygr 4th April 2008, 11:05 AM Since you are operating under the AS system this indicates that you are in the aerospace food chain. This being the case more and more the Nadcap requirement is being officially passed down the food chain ( Goodrich Corporation just issued the mandate letter for all suppliers and subtier suppliers to be Nadcap approved ).
Selecting a supplier that has been thru the Nadcap review gives you evidence of a review of their special process by a third party qualified individual and meet element a of 7.5.2.. While you may not have visibility to the audit details on line at eauditnet you can always ask that they send you the certificate that is issued.
If there is no need for Nadcap then they are still required to work to some process specifications and for the process that you listed plating (chrome, Type I, II, & III anodize, nickle, the applicable specs most likely define the solution control , periodic process panel and qualification that are required. I would use these records to show evidence of review of the process to cover elements a,b,c,d since it clearly states “as applicable”
The element e for revalidation also as applicable and if not required by spec or your own internal procedure in some way you would not be required to do anything.
:2cents:
Kevin Mader 5th April 2008, 11:48 AM Folks,
Let's keep in mind that verification and validation are not the same. Certs of Conformance and inspection on plating thickness (verification activity)will not suffice (but might if the auditor is weak).
For instance, an inspector makes a measurement of plating thickness and finds that it meets PRODUCT specifications. Have the PROCESS specifications been maintained through the plating of the part? How would you know? Will the part flake due to poor surface preparation? Is plating thickness the same uniformaly especially in corners? What is the suppliers Preventive Maintenance program and how well do they monitor/maintain equipment, solutions in tanks, etc.? (I’ve emphasized PRODUCT and PROCESS to draw distinctions and not to shout at anyone)
Special Processes are those processes which inspection and test alone are insufficient to determine the acceptability of a part/good. It is necessary to understand how well designed a process is at meeting the design requirements of the part/component. Consider the inputs to producing a finished part/component/good: man, machine & equipment, material, methods, measures and environment. Validation examines the robustness of each of these areas in meeting the PROCESS specifications. Invariably, some means of test and inspection will need to be performed to confirm the process capability at meeting the PRODUCT specifications. Often times the inspection and test methods themselves are Special Processes requiring their own verification and VALIDATION. Validation challenges that the process designed to manufacture (plate) a good consistently produces product meeting PRODUCT specifications.
Keep in mind that verification and validation are both necessary. I’d like to also offer that Statistical Process Control is also a critical element in assuring product quality and conformity. SPC more so than SQC, perhaps, but both are important.
Good discussion folks! Back to the group…
Regards,
Kevin
Big Jim 5th April 2008, 04:54 PM And why would a C of C be limited to verification? If the C of C was to show that a particular process was followed, would that not be validation?
Kevin Mader 6th April 2008, 10:31 PM Big Jim,
I tied the label of verification to the inspection of plating (the suggestion of the registrar). The C of C was an entry from an earlier poster. I'm sorry for any confusion. My point was that neither of these supports that a validation has taken place.
A C of C states all the good and obvious - a mini insurance policy if you will supplied with product arriving at the dock. It does not provide Objective Evidence that the organization providing the special process/plated parts has taken the necessary steps to validate the process. At a minimum, I would be looking for summary reports for the IQ, the OQ, the PQ, any interim reports that may have been written, and the final validation report that ties them all together. I would also expect to have on hand the Process Specification and the Validation Master Plan. Having all these pieces is essential for getting through the auditor's line of questioning. Verification can obviate the need to perform validation, to the greater degree in some cases, but it's still the expectation that the need for validation be reviewed and rationalized if not performed. This is where a riskbased approach can pay dividends. If this were the route of the supplier performing the special process, I'd expect to have on hand the Process Validation Plan with the discussion on why a limited/no validation required effort was to be given and the summary report to summarize the rationale and validation activity.
Back to the group...
Regards,
Kevin
Steve Weber 14th April 2008, 09:17 AM I want to thank all of you for the information. We probably will try to utilize a bit of all suggestions. Require periodic test reports from some vendors we cannot personnaly vist for our own audit. Auditing the close vendors ourselves, and sending out some parts to independent labs for verification. Any other suggestions would be appreciated.
Ajayqms 26th April 2008, 02:51 PM Dear all,
Can any body help in list out what all are the special processes. (generally found in industry), and how to control special process which is happening at suppliers, supplier end (i.e supplier to our supplier)
Do we need to go to the final level of chain where actually the special process is undergoing or how we can address.
Regards
Ajay
Sidney Vianna 26th April 2008, 03:49 PM The NADCAP controlled processes and commodities give you an indication:
Chemical Processing (http://www.pri-network.org/Nadcap/Chemical-Process-Supplier-Accreditation-Task-Group.id.52.htm) – based on the SAE standard AS7108, AS7108/1 and AS7108/2
Coatings (http://www.pri-network.org/Nadcap/Coatings-Supplier-Accreditation-Task-Group.id.53.htm) – based on the SAE standard AS7109
Composites (http://www.pri-network.org/Nadcap/Composites-Task-Group.id.423.htm) – based on the AC7118 checklist
Elastomer Seals (http://www.pri-network.org/Nadcap/Elastomer-Seals-Supplier-Accreditation-Task-Group.id.55.htm) – based on the AC7115 series of checklists
Electronics (http://www.pri-network.org/Nadcap/Electronics-Accreditation-Task-Group.id.625.htm) - based on the AC7119, AC7120 and AC7121 checklists.
Fasteners (http://www.pri-network.org/Nadcap/Fasteners-Task-Group.id.793.htm) - based on the AC7113 series of checklists
Fluids Distribution (http://www.pri-network.org/Nadcap/Fluid-Distribution-Standards-Supplier-Accreditatio.id.56.htm) – based on the SAE standard AS7112, AS7112/1, AS7112/2 and AS7112/4
Heat Treating (http://www.pri-network.org/Nadcap/Heat-Treating-Supplier-Accreditation-Task-Group.id.57.htm) – based on the SAE standard AS7102
Materials Testing Laboratory (http://www.pri-network.org/Nadcap/Materials-Testing-Laboratory-Supplier-Accreditatio.id.58.htm) – based on the SAE standard AS7101, AC7101/1-9, AC7101/11 and AC7006
Nondestructive Testing (http://www.pri-network.org/Nadcap/Non-Destructive-Testing-Supplier-Accreditation-Tas.id.60.htm) – based on the AC7114 series of checklists
Nonconventional Machining and Surface Enhancement (http://www.pri-network.org/Nadcap/Nonconventional-Machining-and--Surface-Enhancement.id.59.htm) – based on the SAE standard AS7116 and AS7117
Sealants (http://www.pri-network.org/Nadcap/Sealants-On-Site-Surveillance-Supplier-Accreditati.id.61.htm) – based on the SAE standard AS7200/1 and AS7202
Welding (http://www.pri-network.org/Nadcap/Welding-Supplier-Accreditation-Task-Group.id.62.htm) – based on the AC7110 series of checklists
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