AS9100 Control of Non Conforming Product - Personnel who make Disposition Decisions

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jesterjay8

Our Internal Auditor wants us to have a more robust process for approving personnel who make disposition decisions as outlined on 8.3 Control of Non Conforming Product.

We have defined the persons responsible for making the disposition decisions in our procedure. But how would we define the process of approving these personnel within our procedure? Our competence is measured by Training Records and Performance Evaluation other than that it is basically their knowledge of the product….please help…

Thank you!!
 

DannyK

Trusted Information Resource
Re: AS9100 Control of Non Conforming Product

You could qualify or re-qualify the persons responsible for making disposition decisions based on their aerospace experience. You can also provide a test.
Some companies require that the person dispositioning has at least 3 years of aerospace experience..
 
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alspread

Re: AS9100 Control of Non Conforming Product

I know of one prime that requires annual training of all personnel assigned for preliminary review (internal isposition) of nonconforming material.

Set up a periodic training for the assigned personnel and review your procedure requirements and emphasize the significant responsability associated with NC disposition.

Good luck
 

Wes Bucey

Prophet of Profit
Re: AS9100 Control of Non Conforming Product

Yeah. This Control of Nonconforming Product issue can cause a lot of angst in aerospace and in FAA-regulated industries.

Essentially, the basis is that nonconforming material has to go through a systematic process of determining whether it can be made conforming by rework or repair or must be destroyed (disposition does not mean "destroyed" - it only means that the product or "thing" is "positioned" under a set of controls to assure it does not get back into use while still in nonconforming condition.)

One of the big issues in the past has been that parts or products deemed incapable of being reworked or repaired to bring them into conformance have been "disposed" into a trash where unscrupulous or ignorant folks have retrieved them and put them into use as if they were conforming.

Thus, regulators have imposed a requirement that unrepairable items be further destroyed so as to make them absolutely incapable of being used.

Many folks in aerospace and FAA-regulated industries have created procedures and processes and work instructions to create a systematic appraisal of suspect product, documenting whether they are repairable or not. Those deemed repairable are diverted to a repair facility, unrepairable are held in quarantine until they can be destroyed (not merely trashed.) Destruction does not have to be in-house; it can be contracted out, but the contractor must go through an approval process to assure product slated for destruction does not reenter the production/installation cycle at some other facility. (think of document destruction where outside contractors bring big trucks with paper shredders to a company site and feed documents through the shredder to be destroyed. Some of the outsourced companies merely haul the documents back to a large central facility to be shredded - obviously the approval process is a little more elaborate because the documents are out of the chain of custody of the document owner while in transit.)

Once such processes are in place, individuals are trained and evaluated by supervisors to carry out those processes. Periodic audits and evaluations continue to assure the processes are being followed. Folks are not allowed to be part of the process until approved. Obviously, just like in school, "advance placement" by testing (without training) is allowed and encouraged for the sake of efficiency to eliminate redundant training.

It is important not to let the approval of employees be "once and done" - periodic assessment and audit is necessary to provide assurance to aerospace OEMs and FAA regulators.
 
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Jeff Frost

Re: AS9100 Control of Non Conforming Product

Actully you just need to justify their experience. DE's and PE's, by education, have the knowledge to understand the design requirements. This hold true for QM or QE's who bring education in quality to the table. Process Engineers (education) and production manager have an understand the manufacturing process of your company.
 

amadisonr

Inactive Registered Visitor
Re: AS9100 Control of Non Conforming Product

It seems to be industry standard to lock up our MRB or non conforming product. The statement to "positively control" this product seems to lead to this practice. Does anyone know of any CFR, or other regulatory requirement that drives this practice?

We have military and commerical manufacturing. Our Quality Engineers seem to recall a customer requirement, but this was before my time in this company.

Please advise
 

dsanabria

Quite Involved in Discussions
Re: AS9100 Control of Non Conforming Product

You could qualify or re-qualify the persons responsible for making disposition decisions based on their aerospace experience. You can also provide a test.
Some companies require that the person dispositioning has at least 3 years of aerospace experience..


Thanks DannyK:

...and 3 to 6 months - as a minimum with the company / customer - (you want to know the Quality requirements of the customer(s) before making a decision).
 

RCW

Quite Involved in Discussions
Re: AS9100 Control of Non Conforming Product

Thanks DannyK:

...and 3 to 6 months - as a minimum with the company / customer - (you want to know the Quality requirements of the customer(s) before making a decision).

I need to play 'devil's advocate' on this one. So if your company adds a new (never done business with them before) aerospace company / customer, no one at your company can process a noncon for 3 to 6 months?
 

dsanabria

Quite Involved in Discussions
Re: AS9100 Control of Non Conforming Product

I need to play 'devil's advocate' on this one. So if your company adds a new (never done business with them before) aerospace company / customer, no one at your company can process a noncon for 3 to 6 months?

You are over thinking the standard...

"The organization's documented procedure shall define the responsibility and authority for the review and disposition of nonconforming product, and the process for approving personnel making these decisions."

All we are saying is that the more experience your team has - the better the decision is to make.:notme:
 

RCW

Quite Involved in Discussions
Re: AS9100 Control of Non Conforming Product

No, what I am saying is that it is backing oneself into a corner by stating that a person responsible for dispositioning nonconforming material has 3 to 6 months experience working with that customer. If you start doing business with a new customer, no one there would have 3 to 6 months experience working with that customer.

I've been burned too many times by over-specifying and backing into that corner.

I do agree however that customer requirements are integral in the nonconformance disposition process and need to be taken into consideration.
 
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