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

[Sidney Vianna]

Re: AS9100 Control of Non Conforming Product

Not sure I follow those in AS9100C Clause 8.3

Some of the AS9100C related requirements:

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.

Dispositions of use-as-is or repair shall only be used after approval by an authorized representative of the organization responsible for design.
NOTE Authorized representative includes personnel having delegated authority from the design organization.

Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled, until physically rendered unusable.

 

[Wes Bucey]

Re: AS9100 Control of Non Conforming Product

For the benefit of our Members, which FAA regulation in particular??

I'm so glad you asked that, Jan. Folks involved in Aerospace need to be aware of the governmental regulations (from any country where their product is sold or used) as a regular part of the business of conforming to rules and regulations.

Here's a brief excerpt from an FAA Advisory Circular AC 21-43, which references the requirement about dealing with nonconforming material. Most competent consultants to the aerospace industry would, of course, be willing and able to provide a complete list of regulation references when operating as a paid consultant to an individual organization.

Procedures.
PAHs should have procedures that ensure a material review board
(MRB) is established, documented, and operational. PAHs should have procedures that include how nonconforming products or articles are identified, controlled, and dispositioned.
b. Disposition Determinations.
Authorized individuals should review nonconforming material to determine if acceptance of the nonconformance constitutes a major or minor change to FAA-approved data. The FAA, through the design approval process, will approve any MRB disposition identified as a major change.
c. Data Analysis.
Senior management should review and analyze nonconforming material data to detect adverse trends and determine appropriate levels of corrective and preventive actions.
d. Disposition of Scrap and Salvageable Aircraft Products and Articles.
These products and articles should be disposed of in an acceptable manner.
Appendix E to this AC provides additional information on controlling and dispositioning scrap and salvageable aircraft products and articles.

Appendix E
Scrap or Salvageable Aircraft Products and Articles
1. Purpose.
The information provided in this appendix may be used by PAHs, and their suppliers. This information may be—
a. Applied to manufacturers involved in the control, distribution, sale, maintenance, or disposition of scrap or salvageable aircraft engines,
aircraft propellers, and aircraft articles and
b. Used to identify, segregate, and control rejected products and articles to preclude their use in a finished product.
2. Background.
Products and articles may be deemed scrap or salvageable once they are determined as unserviceable or ineligible for installation on an aircraft, aircraft engine, or aircraft propeller. In some cases, it has been common practice to dispose of scrapped products and articles by selling, discarding, or transferring the articles. A lack of proper industry controls may result in an article being copied or repaired, reintroduced into the market, and being falsely identified as an approved article. Use of such products and articles can have serious safety implications and liabilities for the manufacturer, aircraft operator, or repair facility. Using an effective system to control scrap or salvageable products and articles will reduce the chances that these articles will be distributed or sold as serviceable.
3. Documenting the Process.
Maintaining a well-defined quality program is fundamental to controlling rejected products and articles. One element to be addressed within this program is the control and disposal of scrap and salvageable products and articles. Quality systems without this element could allow products and articles to migrate back into active inventories.
4. Preventing Misrepresentation of Scrap Products and Articles.
a. Manufacturers should dispose of scrap products and articles through mutilation, when appropriate. Proper and thorough mutilation of products and articles will ensure they are unusable for their original application and render them incapable of being reworked or camouflaged to provide the appearance of being serviceable.
b. Effective mutilation may be accomplished by one or a combination of the following methods: grinding, burning, removal of a major integral feature, permanent distortion of products and articles, cutting a significant size hole with a cutting torch or saw, melting, sawing into many small pieces, and removing manufacturer identification, part, lot, batch, and serial number.
5. Disposing of Scrap Products and Articles.
Manufacturers disposing of scrap products and articles may choose to release them for legitimate non-flight use. This non-flight use may include training, education, research and development, tool set up, or non-aviation applications. In such instances, mutilation may not be appropriate. The following methods may be used to prevent future misrepresentation:
a. Permanently and clearly mark the products and articles as “Not for Aviation Use” and “Not Serviceable.” Ink stamping is not normally considered an acceptable method unless indelible ink is used and the products and articles are checked to ensure the ink cannot be removed.
b. Remove part number identification.
c. Remove identification plate and marking.
d. Maintain a tracking or accountability system, by serial number or other individualized data, to record transferred scrap products and articles.
e. In any agreement or contract transferring scrap products and articles, develop written procedures identifying disposition and disposal requirements.
f. Secure a signed certification statement from the purchaser indicating that “the purchaser will not use or convey these products and articles for use in aviation products.”
g. For those articles determined to be scrap and having no further aviation use, manufacturers should—
(1) Establish and maintain procedures requiring documentation (for example, a written contract) from scrap dealers indicating their intent to properly dispose of all products and articles received.
(2) Establish and maintain procedures to audit scrap dealers to their contract requirements.
(3) Maintain records of serial numbers for scrapped life-limited or other critical products and articles. In such cases, the owner who mutilates applicable products and articles is encouraged to provide the original manufacturer with the data plate or serial number and final disposition of the product or article.
6. Preventing Misrepresentation of Salvageable Products and Articles.
a. Manufacturers handling salvageable products and articles should—
(1) Establish secure areas to segregate such articles from active serviceable inventories and to prevent unauthorized access.
(2) Develop procedures to address the retention of records for products and articles exceeding current repair criteria and life limits and thatare being held in anticipation of future repair methods or extension to life limits. Caution should be exercised to ensure that these products and articles receive the appropriate final disposition.
b. Aviation safety is best served with sound processes that control scrap and salvageable products and articles.
Using the practices identified in this document will reduce the potential that these articles will be distributed and sold as serviceable products.
With aviation safety in mind, the aviation community is responsible for preventing misrepresentation of aviation products and articles. The FAA encourages manufacturers to establish a program that controls scrap and salvageable products and articles as an integral part of their quality management systems.
c. Misrepresented products and articles that are offered for sale, or have been furnished for aviation use, should be reported to the FAA.
This may be accomplished by submitting FAA Form 8120-11, Suspected Unapproved Parts Notification, or by calling the Aviation Safety Hotline toll free number, 800.255.1111

 

[Marc]

Re: AS9100 Control of Non Conforming Product

<snip> Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled, until physically rendered unusable. <snip>

Exactly. "Physically Rendered Unusable" is the key. As an aside in this conversation, I worked in aerospace (defense industry) in the 1980's and this requirement was the same way back then. The same requirement applied to naval parts and communications equipment parts. Back in those days MRB rooms were locked and all nonconforming and *potentially* nonconforming parts were locked up as well.

 

[Boingo-boingo]

Re: AS9100 Control of Non Conforming Product

Here's a brief excerpt from an FAA Advisory Circular AC 21-43, which references the requirement recommendations about dealing with nonconforming material.

There, I fixed it for you. An AC (ADVISORY Circular) is NOT mandatory. As the word "advisory" implies, it contains recommendations.

If you read carefully the text of the AC you pasted, you should note that it uses words such as may, should, consider, etc. Requirements would be associated with words such as shall, must, have to, etc.....

http://www.faa.gov/documentLibrary/media/Order/1320.46C.pdf

 

[Marc]

Re: AS9100 Control of Non Conforming Product

In case the link goes away in the future.
.

 

[Wes Bucey]

Re: AS9100 Control of Non Conforming Product

There, I fixed it for you. An AC (ADVISORY Circular) is NOT mandatory. As the word "advisory" implies, it contains recommendations.

If you read carefully the text of the AC you pasted, you should note that it uses words such as may, should, consider, etc. Requirements would be associated with words such as shall, must, have to, etc.....

http://www.faa.gov/documentLibrary/media/Order/1320.46C.pdf

I suppose you "could" refer to Order 81.20 (Section 530) which gives guidance to the FAA Inspectors as to what the Parts Approval Holders should be doing in order to earn their certificates.

Think of it this way: FAA inspectors take the guidance documents as the way THEY should interpret the regulations in deciding whether to grant or deny certification. My experience is that it is much easier to get certification by adhering to the guidelines than by trying to impose one's own interpretation on the FAA.

My own experience with FAA inspectors is that they are very persnickety and unlikely to be willing to champion a PAH for certification when the PAH challenges the Guidance documents. They are NOT receptive to "jawboning" and will simply say, "No!" without entering into any argument about the merits of the PAH's viewpoint.

If you have a different experience, I'd be interested in hearing more, but I'm not interested in a non-experienced person saying, "I think . . ."

 

[DarrellH]

Re: AS9100 Control of Non Conforming Product

There, I fixed it for you. An AC (ADVISORY Circular) is NOT mandatory. As the word "advisory" implies, it contains recommendations.

If you read carefully the text of the AC you pasted, you should note that it uses words such as may, should, consider, etc. Requirements would be associated with words such as shall, must, have to, etc.....

http://www.faa.gov/documentLibrary/media/Order/1320.46C.pdf

You are 100% correct, however, I did once have the debate with a CAA (UK FAA) auditor about "but that's only advice",

Lets just say I won't be having that debate again.

Advice is given for a reason, if you want to find an alternative "method" that addresses all the issues raised by the advice, you go for it!!

Me, I prefer to listen to good advice.

 

[Boingo-boingo]

Re: AS9100 Control of Non Conforming Product

but I'm not interested in a non-experienced person saying, "I think . . ."

I think any professional worth his/her salt must clearly understand the difference between a regulation and a recommendation (show me the shall!) . The FAA regulation basically stipulates:

Procedures to ensure that discarded articles are rendered unusable.

The reality is: FAA regulations, despite carrying the power of the law, are archaic, when it comes to quality systems. Current modern practices in terms of quality management are decades ahead of FAA's demands.

 

[Jim Wynne]

Re: AS9100 Control of Non Conforming Product

I think any professional worth his/her salt must clearly understand the difference between a regulation and a recommendation (show me the shall!) . The FAA regulation basically stipulates:


The reality is: FAA regulations, despite carrying the power of the law, are archaic, when it comes to quality systems. Current modern practices in terms of quality management are decades ahead of FAA's demands.

Note also that the regulation refers to "discarded" articles, and not "nonconforming" articles. Nonconforming parts can be salvaged in some cases; the dictum to render parts unusable applies only to parts that are actually being discarded.

 

[Bev D]

Re: AS9100 Control of Non Conforming Product

Note also that the regulation refers to "discarded" articles, and not "nonconforming" articles. Nonconforming parts can be salvaged in some cases; the dictum to render parts unusable applies only to parts that are actually being discarded.

So true. nonconforming material may be dispositioned as rework or repair or even use-as-is. (Of course these dispositions must comply with the requirements regarding training and experience for Preliminary review and MRB personnel, validation of repairs and approval of all non-pre-approved work - seviations or concessions) to prevent the shipping of substandard product that would pose a safety risk. Typically in my experience this is more highly specified in the Customer requriements as flowed down from the FAA requirements.)

The disposition of scrap is equivalent to the phrase 'discarded'. This is done to prevent the parts from entering the black or gray market or being reintroduced into the production stream - again for safety reasons as well as national security for defense related arespace work. A 'special' case is made for materials that will be recycled; their storage until time of recycling must be secure and teh recycler must be approved or certified (Again in my expereince this is more highly specified in the Customer requriements than the FAA requirements.) I have had auditors insist that the parts destined for recycling be renedered useless as they deemed that a padlock on the 55 gallon drum of scrap was not a very secure solution.