AS 9100a Clause 7.4.3 - Verificaton Of C of C (Certificate of Compliance)

[DAHSR]

I am looking for ideas on how to validate certificate of compliance received with product/raw materials IAW AS9100A 7.4.3.

[CarolX]

Originally Posted by DAHSR

I am looking for ideas on how to validate certificate of compliance received with product/raw materials IAW AS9100A 7.4.3.

Hello DAHSR and welcome to the Cove.

I have been out of the aircraft business for a while, but what I use to do was to perform and independent test on each mill once a year. We would send a sample out to a local labe, have them perform the tests and then compare the results with the mill test report sent with the shipment.

I don't know much about the spec....but I hope this helps.

CarolX

[howste]

Validation can be done by sending material out for an independent lab analysis, or by doing analysis in-house if you have the capability. I believe the intent is to correlate results and to establish confidence in your supplier's test results.

[Wes Bucey]

Originally Posted by howste

Validation can be done by sending material out for an independent lab analysis, or by doing analysis in-house if you have the capability. I believe the intent is to correlate results and to establish confidence in your supplier's test results.

Howtse' suggestion and Carol's solution are similar to a service we provided for our customers when I was in the high tech contract machining business in which we dealt with a lot of exotic alloys.

We would take one or several "coupons" (test size sample) of the bar stock or ingot, tag and store it with a copy of the mill cert. We offered each customer the option of having us send out the coupon to an independent metallurgy lab for a comparison to the mill specs listed on the cert. We held the coupon with our quality records until retention period was up and then offered it to the customer to hold for reference. We notified all our raw material suppliers of our policy as part of our purchase contract, including a clause we would hold them liable for any substantial discrepancy, not least of which would be the cost of the analysis. Two of our suppliers thought it was such a good idea, they asked us to cut a coupon for them as well, with the agreement we would send random coupons to our independent lab at the supplier's notice and expense as a check on his own internal analysis procedures.

Obviously, if you have the coupons in hand, only random samples are sent to the lab to confirm supplier's certs unless there is a failure somewhere down the line and confirmation/traceability of the material is a critical factor.

[DAHSR]

It seems I would have to send out a sample of a raw material, like aluminum for independent lab analysis. Does this apply to ALL raw materials, like chemicals I use, paints & thinners, glues and adhesives? What about nuts, bolts & screws or electronic components?

[Wes Bucey]

Originally Posted by DAHSR

It seems I would have to send out a sample of a raw material, like aluminum for independent lab analysis. Does this apply to ALL raw materials, like chemicals I use, paints & thinners, glues and adhesives? What about nuts, bolts & screws or electronic components?

It may not even be necessary to send it out and pay for the analysis in advance, if you trust your supplier. Just keep a sample tagged and handy with a copy of the supplier's cert should the occasion arise where the supplier's certificate of conformance comes into question. (If you do a good supplier survey, you will know whether you can trust it, subject to an error at the supplier. Like grandpappy says, "Trust everybody, but count the cards!")

It seems to me that each organization has separate requirements for what needs to be tracked and confirmed, just as each organization has different components as part of its product. Customers create one of the major requirements for tracking/confirming components, but regulatory bodies can create the greatest risk.

For example, there are several European nations that ban cadmium plated products or cadmium plated components in complex products, with various penalties for violations. It seems to me, then, any organization whose products might end up in such nations have a need to ensure and document that fact that none of their products start out with cadmium plated components (that any cadmium plated components are probably unauthorized "field replacements" done by unaffiliated third parties.) Without such testing and documentation, the organization has little defense.

True story: My organization ran into this problem 3 years ago. Purchase records and tagged "exemplar" products which had been pulled from production and sent to our lab for functional testing established our innocence with a minimum of fuss. The initial paperwork from the foreign government was VERY scary, though. Our CEO ran around like a goose for a whole day because he had been served with the papers while at a conference in that country. He rested easily when he called us at work during his European supper time and we were able to tell him we were covered. (Kind of reminds me of the Mastercard ad ("Being able to sleep that night - Priceless!")

Also note (for your query "Does this apply to ALL raw materials, like chemicals I use, paints & thinners, glues and adhesives? What about nuts, bolts & screws or electronic components?"), there are "threshhold" amounts of product which need reporting and tracking. Governments have lists of toxic and carcinogenic substances which need to be tracked and reported, but they have reasonable limits. It's up to the organization to keep informed whether a customer or regulatory body will want ANYTHING documented and tracked.