Changing Companies: Retention of Records

[Imhotep]

Hello All:

I have a question regarding records retention when a job moves from one company to another. I have not been successful in finding an answer.

This is the scenario:
- A company makes a part for its tier 1 or OEM customer.

- The company decides on a change in business direction and the part is transferd to another company (the 2 companies are not connected), along with the tooling.

- The company rids itself of machinery and is no longer able to make the part.

- The company now has no responsibility for current part production.

- The part is "active" to the customer but is "inactive" or "dead" to the company.

My question is: what is the record retention requirement for the company for this part?
Some records (e.g. PPAP) must be retained for the life of the job + 1 year.
Can the company dispose of all records 1 year after the job is gone even though the part is still being made by someone else, or must the company contact its previous customer every year to find out the status of the part?

The QS wording in 4.16.1 is "...shall be maintained for the length of time the part (or family of parts) is active for production and service requirements plus one calendar year unless otherwise specified by the customer."

I have spent some time looking for the answer with no results.

Any help will be appreciated.

[Dave Johnson]

Hello Imhotep:
I was looking at the glossary of the big 3 PPAP manual. Under "Active Part", it says"...part remains active until tooling scrap authorization is given by the appropriate customer activity."

The customer knows you got rid of the machinery, so I would assume they agree that the part is dead to your company.

Therefore, IMO, records may be destroyed after 1 year.

(But you may want to get a letter from the customer's purchasing dept or your SQA contact just in case).

Hope this helps.

[tomvehoski]

Imhotep,

It is a gray area. The same issue pops up all the time in the TE Supplement since they did not modify 4.16.1. Since the TE supplier builds the tool and ships it to the manufacturer, they will probably never hear again about the life of the end product or receive a scrap notification for the tooling they no longer have. Most auditors I have run into look at it as a bogus requirement that should have been removed by the TE Supplement. I usually word the requiment along the lines of "expected life" of the tool.

I also ran into the same issue with a prototype supplier - they don't get scrap authorization on prototype tools. Your safest way to handle it is to get the letter from the customer stating what they want you to do. Just because it is not longer active for you, they will probably still want to maintain the records in case of recall, legal issues, etc.

Tom