AS9100 Repairs - Approval from a non-aerospace customer prior to conducting a repair

[QLearning]

All,

Hope you can help. We are small electronics manufacturer that has both aerospace and non-aerospace customers. We are AS9100c/ISO 9001:2008 certified.

Do we have to notify/get approval from a non-aerospace customer prior to conducting a repair, if the customer does not seem to have a notification of change clause or terms in their contract?

Thanks.

 

[Sidney Vianna]

Re: AS9100 repairs

Do we have to notify/get approval from a non-aerospace customer prior to conducting a repair, if the customer does not seem to have a notification of change clause or terms in their contract?

If your organization and your registrar were not careful when defining your scope of certification and your certificate implies that your AS9100 compliant (and certified) system applies to all customers and products, even the non-aerospace ones, you can not disposition any product for repair without the consent of the customer and/or the design responsible organization, as it would violate the AS9100 requirement in 8.3 which reads:

Dispositions of use-as-is or repair shall only be used after approval by an authorized representative of the organization responsible for design.

 

[QLearning]

Re: AS9100 repairs

Dear Sidney,

Thank you very much for your reply. It is very helpful. I checked our certification, which says it's applicable to the type of work we do, but does not distinguish between aerospace vs. non-aerospace (ugh!).

Again, your response is pretty definitive. Thanks.

 

[Sidney Vianna]

Re: AS9100 Repairs - Approval from a non-aerospace customer prior to conducting a rep

If this is a serious issue for your organization, you could work with your CB to clarify that the AS9100 certified system applies exclusively to the aerospace customer/products and ISO 9001 applies to the commercial customers/products.

As ISO 9001:2008 does not have the requirement mentioned below, you would not infringe any requirement if you dispositioned commercial products for repair, as long as the commercial customers do not have any contractual clause limiting your MRB authority.

It might sound just a bureaucratic procedure, but certification scopes should be paid attention to, in order to remain relevant.

I would recommend you to work with your AS9100/ISO 9001 registrar and have the certificate revised to clarify the intended field of certification coverage.

Good luck and thanks for the feedback.

 

[PaulJSmith]

Re: AS9100 Repairs - Approval from a non-aerospace customer prior to conducting a rep

While agreeing with Sidney, I'll also add that you need to ensure that your own internal procedure allows this as well. If it states that you must have customer approval, then you either need customer approval or you need to re-write that procedure to allow repair without it (I'm not convinced this is a good idea, especially if the customer owns the design).

 

[John Broomfield]

Re: AS9100 Repairs - Approval from a non-aerospace customer prior to conducting a rep

Rework is not a design change but repair is.

...so which is it?

 

[PaulJSmith]

Re: AS9100 Repairs - Approval from a non-aerospace customer prior to conducting a rep

Good point, John. OP said "repair." I inserted "rework." Poor choice of word on my part. Sorry.

Edited to correct that post.

 

[QLearning]

Re: AS9100 Repairs - Approval from a non-aerospace customer prior to conducting a rep

Paul,
Thanks for your input. Our own internal procedure for nonconforming material/product states that we need customer approval for repairs, so we at a minimum, we didn't follow our own requirements. But, if the customer is not an aerospace customer, and they do not have any specific terms/requirements for us to obtain approval prior to performing repairs, can they issue us a CAR?

 

[QLearning]

Re: AS9100 Repairs - Approval from a non-aerospace customer prior to conducting a rep

John, we are dealing with a repair for a non-aerospace customer who does not have specific terms/requirement for us to seek their approval prior to conducting repairs. They issued us a CAR. Is it legit?

 

[Big Jim]

Re: AS9100 Repairs - Approval from a non-aerospace customer prior to conducting a rep

Sydney said it best.

It depends on how you set up your system, specifically on your scope statement.

I often see a dual scope statement with wording similar to this:

AS9100C requirements apply for all work performed for customers who require AS9100C by contract. ISO 9001:2008 requirements apply to all other work.

If you didn't set up your scope with this flexibility, you will need to apply AS9100C requirements for everything.