AS9100 Clause 8.3 "Rendering Scrap Unusable"

A

AlexanderS

Hello All,
I need your advice.
We are producing PCBs. So, the product is Custom by its nature, you can not take our boards and use them in production someplace else, like you can with capacitors.

The AS9100 auditor is saying that we need to physically render scrap boards unusable and insists that we physically damage them before sending them to for recycling.
Now, which risk I am mitigating when I decide to cut/shred the scrap boards in my case? Outside world cannot physically use my scrap boards. Depends on the definition of ?use?. Somebody can physically use my scrap board panels as trays. It?s true that my own people have access to recycling bin.
So, will I comply to 8.3 if I put the recycling bins behind cage and lock?

Alex.
 

Michael_M

Trusted Information Resource
As it was explained to me, it is two things:

1. They want to prevent the scrap parts from accidentally being returned to the usable pile.

2. They want to make sure that the parts are not usable outside of your control.

I would guess there might be an ITAR regulation restriction as well, but that is not part of the AS9100 standard (except the 'follow all regulations' part).

I take a hack saw to part of the parts and I have a certificate of destruction from our recycler as well.
 
A

AlexanderS

Thank you,

So, I think I comply to the spirit of the standard.

1. They want to prevent the scrap parts from accidentally being returned to the usable pile. Done. The scrap is locked behind the cage.

2. They want to make sure that the parts are not usable outside of your control. Done by default. Once the scrap boards are out of the building you cannot use them. Unless you are a designated Customer who is stealing your won scrap boards.

But the auditor does not seem to be convinced by my arguments.

P.S. We are not ITAR
 

RCW

Quite Involved in Discussions
.
Once the scrap boards are out of the building you cannot use them.

One cannot use the boards as they were fabricated and designed to be used BUT any of the electronic components can be removed from the boards and be reused, resold, or what not.
 
A

AlexanderS

Thank you!

We don't have any electronic components.
We are PCB shop.
We are producing just PCBs.
 
A

AlexanderS

Thank you!

That's what I am trying to explain to the auditor.
Our product is custom PCBs, the flat green stuff.
It's not possible to sell it on Ebay.
Nobody would buy them to introduce back into supply chain, except may be one customer who ordered it :)
Because they are custom.
 

AndyN

Moved On
Hello All,
I need your advice.
We are producing PCBs. So, the product is Custom by its nature, you can not take our boards and use them in production someplace else, like you can with capacitors.

The AS9100 auditor is saying that we need to physically render scrap boards unusable and insists that we physically damage them before sending them to for recycling.
Now, which risk I am mitigating when I decide to cut/shred the scrap boards in my case? Outside world cannot physically use my scrap boards. Depends on the definition of ?use?. Somebody can physically use my scrap board panels as trays. It?s true that my own people have access to recycling bin.
So, will I comply to 8.3 if I put the recycling bins behind cage and lock?

Alex.

It's also to prevent these boards being used to "make up" production numbers when there's a loss of yield from a production run. I've had stuff, which was "reject", taken by operators on 2nd and third shifts (they climbed in, over a wall to get them) to make up numbers where they had fallen short...

Cut them up!
 

normzone

Trusted Information Resource
[AlexanderS], I take small tribal outfits to standard certification, so I'm accustomed to seeing "worst practices".

I've had boards marked with NMR numbers removed from the dumpster by well-intentioned employees because they knew "these parts are hard to get". Fortunately the next time that same failed board went through MRB again, we figured out what was going on. A hammer was introduced into the disposition process.

I wager your auditor, while possibly overreacting, is aware of the counterfeit frenzy sweeping the world, unfortunately rightfully so.

If I had this problem, I'd implement some form of crushing for the components on their way to quarantine. Problem solved for certain, and probably without too much effort on anybody's part.
 
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