AS9100 D Counterfeit Prevention Program - We just service parts

[Big Jim]

We are currently switching over to AS9100 from Nadcap AC7004. Our stage II audit is next week. We hired a third party consultant to perform our Internal Audit for AS9100 (just to make sure we are on the right track). We also had our Stage I audit. Both the consultant and auditor agree that this statement in our Quality Manual covers this exact item.

• Prevention of Counterfeit Parts (8.1.4) – XXXXXXX does not manufacture parts or components therefore this section is not applicable to our operation. We do take precautionary measures to validate that product we use is authentic by reviewing certifications and performing testing on alloys used in brazing.

Not sure if this helps but thought I'd throw it out there.

That doesn't seem to be suffecent justification for nonapplicability. It actually looks like you are describing how you comply.

 

[John Broomfield]

Kokolita,

“We do take precautionary measures to validate that product we use is authentic by reviewing certifications and performing testing on alloys used in brazing.”

These would appear to be your controls. No need to apply for an exception. Just make sure you have evidence these controls are effective.

John

 

[Cari Spears]

I agree with Jim and John

In addition, although AS9100 doesn't require it, we have customers that require we have a documented process for counterfeit parts prevention. So our procedure describes how we verify traceability to the mill when we purchase raw materials, and how we protect anything we scrap so that no one can dumpster dive and potentially create counterfeit parts from parts of our tooling.

 

[dsanabria]

Hello!

Our company does not make parts, we just service parts (plating, e-polish, cleaning) and have no way of knowing if the parts we service are counterfeit.
Would this clause still apply to us?

Your help is highly appreciated.

Thanks!

This clause applies to you as you need to verify your incoming material to make sure that it meets requirements and are not substitud and when you process the parts - you need to verify that you have not produced the wrong application - thus creating a counterfeit product. Note: Counterfeit product does not mean bad product - it just means that you arre not providing the customer with what they paid for.product can b

 

[Cari Spears]

Counterfeit means that there is intention to deceive or defraud - making fraudulent exact imitations. So while counterfeit parts are definitely nonconforming - not all nonconforming product falls into the category of counterfeit.

 

[dsanabria]

Counterfeit means that there is intention to deceive or defraud - making fraudulent exact imitations. So while counterfeit parts are definitely nonconforming - not all nonconforming product falls into the category of counterfeit.

No disagreement but I have seeing that in coating people take shortcuts and apply the same coating from one product to another just because it was already prepared and it was a better coating. It does not make a non conforming part but what the company was creating a substitute / counterfeit product.

3.1 Counterfeit Part
An unauthorized copy, imitation, substitute, or modified part (e.g., material, part, component), which is knowingly misrepresented as a specified genuine part of an original or authorized manufacturer.
NOTE: Examples of a counterfeit part can include, but are not limited to, the false identification of marking or labeling, grade, serial number, date code, documentation, or performance characteristics.

 

[Sidney Vianna]

you need to verify that you have not produced the wrong application - thus creating a counterfeit product.

I think we are mixing apples and oranges here. An improper configured part is non-conforming and failed to be processed under proper configuration management practices. As @Cari Spears mentioned and, as supported, by the IAQG dictionary definition, a counterfeit part is knowingly misrepresented. In other words, there is deceitful intent.

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[dsanabria]

I think we are mixing apples and oranges here. An improper configured part is non-conforming and failed to be processed under proper configuration management practices. As @Cari Spears mentioned and, as supported, by the IAQG dictionary definition, a counterfeit part is knowingly misrepresented. In other words, there is deceitful intent.

View attachment 25992​

Agree...

A product might be of better quality because a short cut was taken but it does not meet the customer requirements and a counterfeit product was sold claiming to be the same...