AS9100:D Counterfeit internal audit questions

I need to create internal audit questions for section 8.1.4 Prevention of Counterfeit Parts.

I have only been able to come up with the following questions to ask, any suggestions for additional questions? The standard is very slim in this area.

Is there a policy, procedure, etc. on how to prevent counterfeit parts from entering the supply chain?

Is there a requirement to train all relevant personnel on the prevention of counterfeit parts?

Does receiving inspection follow the counterfeit parts prevention process?

Is there a method to report suspect or confirmed fraudulent parts and keep them from entering the supply chain?


On Holiday
What does your own QMS say about this? You should be using that to do internal audits. You should already know if there’s a policy or procedure. You job is to check it’s implemented. If you ask questions like that before the system has been put in place, your audits won’t get very far…

Randall Beck

Involved In Discussions
I used to have section checklists for our internal auditors too and they eventually turned into just a yes or no checklists. I dropped the checklists when the new revision of AS9100 was put out. If you are going to use internal audit checklists I would suggest that it is a much more useful tool, and actually does provide valuable 3rd party audit resources if you reword the questions a little. Since the section of the standard is very vague for a reason and you don't actually need any documentation or procedure I would have the internal auditor just document the verbal personnel responses and what documents the operators show you when you ask witness questions like:

"What is the policy or procedure for preventing counterfeit parts from entering the supply chain or how do you know that the wire in the cable you are using is the correct type that the packaging says it is."

"Can you explain to me how were you trained to be able to tell if that valve you just put into the assembly is the not a counterfeit part that will break as soon as our customer installs it on an airplane wing and the plane is in flight?"

"How do you know that the receiving inspection of that epoxy has been verified to be from the approved supplier and it is not cheap or fake epoxy?"

"What would you do if you suspected that some of those titanium wing bolts were not genuine titanium or they looked different? How would you keep them from being used on the assembly line until they could be verified?"

"Can you tell me where that widget plug you were just going to use in the assembly came from in order that I can verify the purchasing and receiving department used a supplier that is on the approved vendor list, or if this is your responsibility can you show me the process you would use to verify these are genuine OEM parts?"

If all the responses agree with your actual counterfeit prevention documents, training and processes that's all you can ask for from your internal auditors.

This makes it much easier to document a process based audit and develops audit trails to audit the next part of the process. It is also very nice to have these internal observations during a recertification audit as well.


On Holiday
These read like 3rd party auditor questions. An internal auditor should be checking to see if the organization‘s planned arrangements are actually implemented.

Mike S.

Happy to be Alive
Trusted Information Resource
Do you have a procedure covering this process?? Look for the "shalls" in the procedure and see if they are being followed.

And ask open-ended questions, not questions that can be answered with a yes or no.
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