AS9100 Clause 8.3 "Rendering Scrap Unusable"

S

Sandra Shepard

I am having some difficulty with the implementation of the 8.3 clause which states:
"Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled until rendered physically rendered unusable".

We manufacture very small electronic components (capacitors). When we scrap parts, they are placed into well marked 55 gallon drums thru one-way openings (can't remove parts). We send these drums (with the lids locked in place) to a specialty metals shop for the purpose of reclaiming precious metals. We have a signed letter from the vendor indicating he will not sell or disperse these units. He further confirms that all capacitors purchased from us will be destroyed for the purpose of reclaiming these metals.

According to our AS9100 auditor, is this not acceptable and he's not convinced that some of these parts won't end up (unintentionally) back into the aerospace supply chain. Give me a break! :confused:

Can anyone help me determine what more I can do? Or should I have to? :bonk:
 

howste

Thaumaturge
Trusted Information Resource
Since this is an outsourced process (see 4.1), where is the control of the process identified? Can you demonstrate that the supplier has "positive controls" in place until they are physically rendered unusable? This may be where the auditor is coming from.
 
D

D.Scott

I am having some difficulty with the implementation of the 8.3 clause which states:
"Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled until rendered physically rendered unusable".

We manufacture very small electronic components (capacitors). When we scrap parts, they are placed into well marked 55 gallon drums thru one-way openings (can't remove parts). We send these drums (with the lids locked in place) to a specialty metals shop for the purpose of reclaiming precious metals. We have a signed letter from the vendor indicating he will not sell or disperse these units. He further confirms that all capacitors purchased from us will be destroyed for the purpose of reclaiming these metals.

According to our AS9100 auditor, is this not acceptable and he's not convinced that some of these parts won't end up (unintentionally) back into the aerospace supply chain. Give me a break! :confused:

Can anyone help me determine what more I can do? Or should I have to? :bonk:

There is a lot of "overkill" in the aerospace world. All inspections have to be confirmed and everything has to fit in its own slot. I am not surprised this is an issue with an auditor.

The requirement is all scrap must be rendered unusable and that it be strictly controlled until then. There is also an "out" in that you can can conspicuously and permanently "mark" the scrap until final disposition. This could also work in reverse in cases where the final product is marked (labeled, serial #, part # etc.) prior to shipping. If scrap is isolated into a one-way container identified as scrap, it can never "accidentally" receive the final marking needed for shipping and use. The scrap would, by virtue of containment and "NON-IDENTIFICATION", be positively controlled until such time as it could be rendered unusable.

I have found with our customers most are agreeable to "signing off" on stuff like this as long as you demonstrate the effectiveness. Ask your SQE to review the process and give his/her blessing.

Short of a work around with the SQE, you might try placing a red stamp pad at the inspection station where the rejection is being made. A slight touch of the capacitor to the pad should leave a red mark without hurting the metals. This, or a similar mark, may satisfy the auditor.

Good luck,

Dave
 

Sidney Vianna

Post Responsibly
Leader
Admin
This is an example of differing levels of expectations by outside auditors. The same process would have been assessed by other AEA's (Aerospace Experienced Auditors) and no concerns reported. You should approach your CB Technical Manager (or equivalent) and argue your case. In other words, appeal the non-conformity.

Howste has an excellent point. Since the scrapping process is being outsourced, what is the confidence level in the actual destruction of the product? What are (as Howste mentioned) the positive controls in place?

Also, keep in mind that, depending on the reason for the scrap disposition, the parts could already be unusable, and, if so, no need for further controls.
 
S

Sandra Shepard

Thanks for your replies. We have had multiple AS 9100 auditors in other facilities who accepted what we do even without the vendor letter, so there is some inconsistency in the understanding and application of the requirement. So, what else is new. And I do agree this item is being "overkilled" by some.

There is so much importance placed on certified suppliers, I can't imagine this is a recurring issue if AS9100 customers are truly buying from registered, reputable suppliers.

The SQE is the person that obtained the vendor letter to help our case. That didn't work. I will follow-up with them to get more concerning the supplier. We never really considered this an an outsourced process, since it isn't a mfg. step or process. It's all after the fact.
:thanx:
 

howste

Thaumaturge
Trusted Information Resource
I don't think it's the OEMs that end up buying gray-market parts generally. It's the maintenance, repair, and overhaul organizations (buying from distributors) that sometimes get bit. And there are a lot of them out there.
 

Randy

Super Moderator
I don't think it's the OEMs that end up buying gray-market parts generally. It's the maintenance, repair, and overhaul organizations (buying from distributors) that sometimes get bit. And there are a lot of them out there.

You betcha, for example that's probably where PART 43 & 145, AS9110 and AS9120 guys fall in.
 

RCW

Quite Involved in Discussions
What constitutes being "permanently marked"? Right now we attach (tape, rubber band) red "rejected" labels on the nonconforming item. I can see somebody who has no remorse in short-circuiting the nonconforming product process removing these labels though. (We are also obviously not up to an AS9100 level quality system yet.)

How do YOU permanently mark nonconforming product?
 

howste

Thaumaturge
Trusted Information Resource
What constitutes being "permanently marked"? Right now we attach (tape, rubber band) red "rejected" labels on the nonconforming item. I can see somebody who has no remorse in short-circuiting the nonconforming product process removing these labels though. (We are also obviously not up to an AS9100 level quality system yet.)

How do YOU permanently mark nonconforming product?

It's safe to say that tape and rubber bands are not permanent. I think the answer to your question may depend on the product. Paint on a circuit board may be considered permanent because attempting to remove the paint would probably damage the board. Paint on a large steel part probably wouldn't be considered permanent because it could be removed without damage to the part.

I was teaching a class one time and we were discussing this requirement. Some attendees were from a company that manufactures turbines for jet engines. They said that they used to drill a hole in nonconforming turbines and put them in the scrap bin. However, they later found that someone was pulling the turbines from the scrap bin, welding up the holes and attempting to sell them on the gray market. :mg: They no longer consider drilling holes to be permanent marking...

What kind of product do you have?
 

RCW

Quite Involved in Discussions
Typical items found to be nonconforming here: electronic components (i.c.'s, connectors), occasionally sheet metal housings (slightly larger than a toaster) and castings (smaller than a toaster).
 
Top Bottom