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AS9100D 8.1.4 Prevention of Counterfeit Parts

Alfredo43

Starting to get Involved
#1
I am extremely new to this (you may possibly have seen my original post that explained), my company is currently transitioning from ISO9001 to AS9100. I knew we had something in our manual explaining that we had counterfeit prevention but it only referenced another document we have.
(The document references AS6174A, AS6081, AS6496, AS5553)
My question is, since AS9100 actually requires the counterfeit prevention, do I need to take everything from that document and put it on our new manual or am I still able to just reference the other document explaining all of the processes.
 
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outdoorsNW

Quite Involved in Discussions
#2
I think counterfeit prevention should be a stand alone procedure referenced in your quality manual. Not being familiar with AS6174A, I can't tell you if this standard will work as a stand alone procedure without creating supporting documentation to implement the standard at your company.
 

John Predmore

Trusted Information Resource
#3
The goal is not to have something in your manual, the goal is to have activities to "plan, implement and control processes, appropriate to the organization and its product" (quoting AS9100 8.1.4). I recommend a multi-faceted approach which includes risk assessment of where your particular operations are most at-risk, ongoing employee awareness and vigilance (which touches on training and communication policy), procurement policy (limit supply chain to reputable channels), participate in a forum to alert us to suspected discoveries in the industry, and rolling down counterfeit prevention policy to your external providers (per 8.4.3). My company wrote a Counterfeit Prevention procedure so we can point to, and audit ourselves to, a single document highlighting our interpretation of 8.1.4 and specific actions and assigned responsibilities to plan, implement and control. You may be able to document your implementation in a different way. One important step to prepare for an audit is make sure you do more than lip service, but are conversant to point to specific activities and resources related to your company's efforts.
 

Alfredo43

Starting to get Involved
#4
The goal is not to have something in your manual, the goal is to have activities to "plan, implement and control processes, appropriate to the organization and its product" (quoting AS9100 8.1.4). I recommend a multi-faceted approach which includes risk assessment of where your particular operations are most at-risk, ongoing employee awareness and vigilance (which touches on training and communication policy), procurement policy (limit supply chain to reputable channels), participate in a forum to alert us to suspected discoveries in the industry, and rolling down counterfeit prevention policy to your external providers (per 8.4.3). My company wrote a Counterfeit Prevention procedure so we can point to, and audit ourselves to, a single document highlighting our interpretation of 8.1.4 and specific actions and assigned responsibilities to plan, implement and control. You may be able to document your implementation in a different way. One important step to prepare for an audit is make sure you do more than lip service, but are conversant to point to specific activities and resources related to your company's efforts.
Ok this is perfect, I think really this is what we already have written out. I looked over AS9100 8.1.4 and our Counterfeit Prevention document seems to cover everything that 8.1.4 asks for. I think we should be good referencing it.
 

Cari Spears

Super Moderator
Staff member
Super Moderator
#5
Hi, Alfredo -

What does your company make? What risks are there in contributing to counterfeit product in the supply chain?
 

Big Jim

Super Moderator
#6
You are not required to have a manual and whatever you put into a manual is of your choosing. If you think it is useful to include it or reference it in a manual please do so. If it is not useful, don't. This is also a topic that doesn't require a written procedure. Have one if you think it is of value.
 

Cari Spears

Super Moderator
Staff member
Super Moderator
#7
AS9100 doesn't require a documented counterfeit prevention process; however, the majority of our customers do, so we have one.

Alfredo, I would look into your aerospace customers' requirements, and if required, document it as it applies to your products and the risks that your organization has in contributing to counterfeit product in the supply chain. We wrote a short procedure so that it is easy to reference in customer surveys/audits and easy to send out; it is not part of our Quality Policy Manual.

This is a good thread: AS9100 D Counterfeit Prevention Program - We just service parts
 

outdoorsNW

Quite Involved in Discussions
#8
If I was your customer, I would expect to see counterfeit controls documented, regardless of what any quality standard requires. They do not have to be in a single procedure. I only suggested a single document because that seemed to be what you already had. Something written in a purchasing document and something in the incoming inspection document would work. Other areas may need instructions as well. Depending on the risks of what you purchase and the type of suppliers, the controls could be as short as a sentence or two or require many pages.
 
#9
Yes, I would make sure counterfeit controls are documented, implemented and your team is ready to address any questions related to it. I've noticed this is a significant topic of concern for prospective customers.
 
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