Delegation of Verification Activities to a Supplier - 7.4.3 Interpretation

[rmorgan3]

Hello everyone!

We recently had an "incredibly qualified" consultant perform Rev. C internal auditor training at one of our facilities. When it came to the topic of "delegation of verification activities to a supplier", this person maintained that this would include:

Any outside calibration houses
Any special processor
Any testing lab of raw materials

When I stated that I haven't seen the aerospace industry interpret the requirement that way, I was met with an icy stare and dismissed.

Doesn't this requirement only apply to purchased product (as in the title of the clause)? Is special processing a "product" or a service? Any thought on this?

I've always seen this requirement as a company is delegating the supplier's quality system as its own acceptance (inspection), where a log of approved inspectors are on file, etc. The company can issue its authority media (i.e. stamp) to the delegate for i.d. of acceptance, with a procedure in place for define supplier delegates.

[BadgerMan]

Unless I am misunderstanding your question, I tend to agree with your consultant at least for a special processor. The service they would provide is the product. That said, I am not sure how (or why) you would delegate inspection/acceptance responsibility to a test lab or cal house.

[Sidney Vianna]

Your consultant is mistaken. AS9100 lists several methods for incoming product acceptance and supplier delegation is ONE of them. It also allows for CoC's and test reports, what you normally get from special process houses and cal labs. Note 2 under AS9100C 7.4.3 clarifies:

NOTE 2 Verification activities can include
- obtaining objective evidence of the conformity of the product from the supplier (e.g., accompanying documentation, certificate of conformity, test records, statistical records, process control records),
- inspection and audit at the supplier’s premises,
- review of the required documentation,
- inspection of products upon receipt, and
- delegation of verification to the supplier or supplier certification.

[dsanabria]

In Reply to Parent Post by rmorgan3

Hello everyone!

We recently had an "incredibly qualified" consultant perform Rev. C internal auditor training at one of our facilities. When it came to the topic of "delegation of verification activities to a supplier", this person maintained that this would include:

Any outside calibration houses
Any special processor
Any testing lab of raw materials

When I stated that I haven't seen the aerospace industry interpret the requirement that way, I was met with an icy stare and dismissed.

Doesn't this requirement only apply to purchased product (as in the title of the clause)? Is special processing a "product" or a service? Any thought on this?

I've always seen this requirement as a company is delegating the supplier's quality system as its own acceptance (inspection), where a log of approved inspectors are on file, etc. The company can issue its authority media (i.e. stamp) to the delegate for i.d. of acceptance, with a procedure in place for define supplier delegates.

7.4.3 Verification of Purchased Product
The organization shall establish and implement the inspection or other activities necessary for ensuring that purchased product meets specified purchase requirements.

Now..
Any outside calibration houses - (Not applicable - not product)
Any special processor - (special process - YES, if sent out from your shop -
you want to verify what it was done)
Any testing lab of raw materials - Not applicable on AS9100 C - unless
customer makes a statement on PO or your company wants to
do it because it has had bad experiences with certain suppliers)

[Mikishots]

I agree with your interpretation. We use DSQR's (Designated Supplier Quality Representative) for assemblies made out of house to our specifications; they are approved by us and have stamping authority to show that they have inspected the assembly against set criteria. Note that this does NOT free us from the responsibility of ensuring that the product or service is good; follow-up is still our baby.

Cal houses? No.

[Douglas E. Purdy]

In Reply to Parent Post by dsanabria

7.4.3 Verification of Purchased Product
The organization shall establish and implement the inspection or other activities necessary for ensuring that purchased product meets specified purchase requirements.

Now..
Any outside calibration houses - (Not applicable - not product)
Any special processor - (special process - YES, if sent out from your shop -
you want to verify what it was done)
Any testing lab of raw materials - Not applicable on AS9100 C - unless
customer makes a statement on PO or your company wants to
do it because it has had bad experiences with certain suppliers)

I am still a little fuzzy on how to interpret 'WHERE THE ORGANIZATION DELEGATES VERIFICATION ACTIVITIES TO THE SUPPLIER, THE REQUIREMENT FOR DELEGATION SHALL BE DEFINED AND A REGISTER OF DELEGATIONS MAINTAINED.'

We have special processes being performed by outside sources, and we receive Certification of Compliance to the specified requirements. We have Destructive Testing and NDT performed by outside sources, and we receive Test Reports. We have calibrations performed by outside sources, and we receive calibration certificates / reports. But we have no register of delegated verification activites by these suppliers. I am not understanding when this delegation is required.

Thanks In-Advance!

Doug

[goodnede]

My interpretation is....If your company approves a supplier to manufacture a product completely (from start to finish) and your company approves that that supplier can inspect, test and ship that product without your company doing any inspection, testing or verification activities then you have "delegated verification activities" to that supplier. Your company must have documentation within your supplier management process stating that this supplier has this authorization. We have never authorized this but we have a process to document a supplier with codes that would show up on our Qualified Supplier listing if we ever decided to do that.....I hope this isn't too far off.....

[kiwisfly]

Hi rmorgan3,
Your interpretation is correct, the requirement at 7.4.3 is about delegated verification activities that you may assign to a supplier, regardless of who they are or what they supply. I can't say I have seen many delegations to Special Process providers or calibration organisations.

You may decide that, following several months or years of successful delivery of a supplied product, that you provide the supplier with an approval to act on your behalf and undertake verification activities in their own premises, rather than you doing it when you receive the product. You essentially approve one or more of their inspectors under your approval system. Some of the larger aircraft manufacturer's actually issue the supplier's inspector with their stamps.

Product can then come straight into your production line without any further inspection as it already holds the release the your need, no further inspection required. You need to have a register of who holds these delegations. I normally ask how they were trained and what records show equivalence to your own training and approval process for incoming inspectors.

I'm not sure what to say about your incredibly qualified consultant, other than go with your first instincts when you suspect there is something not quite right.

Cheers,