Positive Control of in-process nonconforming parts until rendered physically unusable

Hello all, I am thrilled to have stumbled upon this forum.

I saw a similar thread posted for electonic components. My products are metal springs (all types) which range in size from extremely tiny to over a foot long/wide. We are working towards an August as9100 pre-assessment and are currently ts16949. I am currently in a debate with my manager over the last parts of NC product control.
1. Positively controlled - currently we place all manufacturing/WIP scrap into red buckets marked 'scrap' right at the machines. At the end of the shift these are tranferred to scrap hoppers. We are trying to determine if we can get away with just locking the larger scrap hoppers of if we somehow have to have oneway/lockable scrap bins at each machine.

2. Regarding rendering physically unusable, I think we need to grind/smash or otherwise mutilate (individual cutting/bending is only practical on a small percentage of our parts, most are made in significant quanities). Others on the team feel that an unfinished part is iherently physically unusable since it will 'probably' not fit in the final assembly (too many variations here to describe but some are rather 'gray' as to whether or not they are unusuable while still in their original spring form but not 'finished'.)

I'm looking for opinions/ examples of what others have seen done for these topics and if anyone feels the above descriptions would pass an audit or be laughably insufficient!

Thanks for any insight.

Re: Positive Control of in-process nonconforming parts until rendered physically unus

Welcome

We have wrestled with the same issue for quite some time and handle it in much the same manner except that we have limited access containers for satellite, short term storage of such material. We call it “nonconforming material” at that point rather than “scrap”. Each manufacturing or service area has a container that looks like a mail drop box that is locked. These containers are labeled "nonconforming material" rather than "scrap". They are emptied on a regular basis and the then scrapped material is sent for hazardous waste disposal (circuit boards and/or components) or it is recycled (metals). Because of our requirement to recycle or properly dispose of hazardous materials, items dispositioned as scrap are moved from the satellite containers to a central locked cabinet and stored until they are sent for recycling or disposal. Only the EMS Engineer has a key to that cabinet.

I have always interpreted the scrap control requirement as having three options:

• Break it
• Permanently mark it
• Lock it up until it can be broken, melted, buried in a landfill, etc.

Re: Positive Control of in-process nonconforming parts until rendered physically unus

Thanks badgerman. Another part of our concern is that even if we lock up the containers and the locked containers are sent to recycling, the parts have not been rendered physically unuseable. You have not had any audit issues with only positive control? Do you have your recycler guarantee parts will remain in control until melted?

Re: Positive Control of in-process nonconforming parts until rendered physically unus

Yes, we do receive certifications that the material has been recycled or disposed of IAW haz-mat requirements.

We have challenges too. Mostly with parts that are so small that they cannot be marked or broken such as a batch of tiny screws or surface mount electronic components.

We are far from perfect but we have not had any third party audit nonconformances related to control of NCM or scrap. Once in a blue moon our internal auditors will have to document a NC. As I said above, we have struggled with this issue from time to time. :