Material Dispositioned for Scrap Positively Controlled - AS9100 Clause 8.3

I found a rack of 10 parts dispositioned seperately for scrap in production area with paperwork next to the parts. These parts were dispositioned 1 to 7 months ago They were not painted red or permanently marked. Anyone could get one of the parts and process it. They met the ISO9001 standard because they were identified and segregated.

For AS9100, the requirement is:

Is product dispositioned for scrap conspicuously and permanently marked, or positively controlled, until physically rendered unusable?

I consider this a nonconformance because they are not positively controlled. One auditor agreed with me and one auditor thinks that it is an observation. What do you think. How do you Interpret "Positively controlled".

TY

Back at ya with this one.....How is "Positive Control" defined by your system/organization.

If the parts meet your definition, no problem, if they don't then you have a non-fulfillment of a requirement. If you have not defined "Positive Control" the problem is a lack of definition and not the control...yet.

"Positive Control" is not well defined in the company procedures. The N/C material in production just need to be identified and segregated, according to a flow chart.

TY

phxsun2001 said:

I found a rack of 10 parts dispositioned seperately for scrap in production area with paperwork next to the parts. These parts were dispositioned 1 to 7 months ago They were not painted red or permanently marked. Anyone could get one of the parts and process it. They met the ISO9001 standard because they were identified and segregated.

For AS9100, the requirement is:

Is product dispositioned for scrap conspicuously and permanently marked, or positively controlled, until physically rendered unusable?

I consider this a nonconformance because they are not positively controlled. One auditor agreed with me and one auditor thinks that it is an observation. What do you think. How do you Interpret "Positively controlled".

TY

Click to expand...

I don't audit regularly in AS9100, but did pass the certification training a few years ago. Per the training, it was emphasized that the intent is to ensure the NC parts cannot be used (accidently or intentionally) due to the risks involved. Destroyed, ground, crushed, cut up, etc. The situation you describe definitely sounds like a nonconformance. You should also verify what the internal and customer or FAR requirements say about it. You should find your justification for a nonconformance.

The intent was much more stringent than the standard ISO 9001 requirement.

phxsun2001 said:

"Positive Control" is not well defined in the company procedures. The N/C material in production just need to be identified and segregated, according to a flow chart.

TY

Click to expand...

There lies your possible problem....a poorly designed process lacking clearly defined definitions. However if you can demonstrate adequate control with the existing procedure then it would not be a problem.

Ya gotta identify what must be done, develop a way to do it, actually do it and provide evidence that is being effectively accomplished.

Since you are under an AS9100 system there is one upstream stake holder that has strong concerns on this subject.

Here is some the of FAA check list questions that the procedure and practice would need to address.
Does the manual contain procedures for segregation of repairable from non- repairable articles?
Does the manual include a procedure for tagging or identifying articles, including repairable and non-repairable articles?

As long as the paper work next to the parts is the way the system states part acceptability is maintained and this paper work identifies the part status you have positive control. Could you improve? probably but if you never have had an escape then this should be no more than an observation at this time.
If the paper work was not with the parts or did not correctly identify their status then I would lean to issuing a finding.

Speaking from personal experience the situation you describe is a non conformance under AS9100 regardless of your own procedures. positive control is generally taken to mean identified and quarantined in a locked area that has limited access. The intent is to have a high level of confidence that all material dispositioned as scrap does not get used either inadvertantly or intentionally. (of course if the perpetrator is bound and determined they can get through a locked door - which is why the emphasis is really on permanent alteration of the part as soon as the material is dispositioned as scrap)

The aerospace industry takes this very seriously and it woudl in all probability result in a major NC and quite a tongue lashing form your SQE...

I walked into this very problem exactly as you described it shortly after being hired by an AS9100 supplier...not fun. depending on other current and past issues you could have have your self release status revoked as well....

Bev D said:

The aerospace industry takes this very seriously and it woudl in all probability result in a major NC and quite a tongue lashing form your SQE...

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Spot on.

No wonder the Aerospace Industry is concerned with the effectiveness of audits performed by CB's. Playing with words, creating artificial definitions of positive control is ludicrous. So, if the company in question had defined "positive control" as parts will be in the open rack, with their paperwork nearby (as in the described situation), would that satisfy the intent of positive control? Obviously not.

The situation, as described, is a CLEAR violation of the AS9100 requirement and I would categorize it as a Major nonconformity. We don't want parts waiting to be mutilated, or scrapped, to turn into bogus hardware floating in the black market. NC parts laying around for 7 months!

Observation? Give me a break!
Gutless auditors need to be shown the door out of the ICOP system...The Aviation, Space & Defense sectors don't need that kind of cowardice.

Yeah, I agree but the term "Positive Control" is subjective. I think it should be defined and demonstrated as effective....I've seen stuff tagged and locked up in a cage and still appear magically.

I got to work for a short time in a "Red Line Brig" back when they existed. We didn't have cell doors....we had a Red Line on the floor. The prisoners were under positive control because of what would happen if they crossed the line. No one did that I recall. (Kinda like the movie "Support Your Local Sheriff" except this was for real).

The argument used by this company was that these parts are serialized and it is impossible for these part to get into the production system by mistake. Their system is tight enough to control these parts without physical controls like using paint or locked area.

There are thousand of parts that goes into the final product and a lot of them are not serialized. It may be OK for these parts, but what about the parts that are not serialized? Their procedure does not address it.

The lead auditor thinks that it is acceptable. He did write a minor nonconformance against their procedure for not painting the parts for setup pieces. So the company will paint these part red, provides some training records and that would be the end of it. In the mean time there is still a hole in their QMS.

TY