AS9100D 8.4.2 Note 2 Significant Operational Risk

#1
"When a customer or organization has identified raw material as a significant operational risk (e.g., critical items), the organization shall implement a process to validate the accuracy of test reports"

2 questions on this.
We are a material distributor/supplier moving from AS9120 to AS9100. How is "Significant Operational Risk" understood?
My understanding as a material provider is that the customer would identify this as "Critical" or "High Risk" etc in the purchase order.
Otherwise it seems this is more applicable to a machine shop that is making components to print, where the raw material is called out as a critical characteristic on the drawing. Does this sound about right?

Also, what would a "Process to validate accuracy of test reports" look like? I would think it would mean sending material to an independent lab to be tested to show that the chemical and mechanical properties meet the requirements as stated on the suppliers test report or C of C.

Am I understanding these requirements correctly?
 
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#2
This is not part of Note 2. This is a continuation of 8.4.2 AFTER the note. The reason that is important is that notes contain no shalls and are not auditable. They provide illumination and help with understanding.

This last portion of the last paragraph has some interesting history. The concept was part of AS9100B, was removed in AS9100C with some controversy. Reported was removed because it wasn't well understood and wasn't well applied. Typically a company would select a few samples each year and send them to a lab to confirm the material matched the material certs provided by the mill. Basically it was a waste of time and money.

Boeing wasn't happy with removing it but went along with it say that if they wanted material validation they would say so in their purchase orders. A few months later Boeing added it to their terms and conditions anyway.

It came back in AS9100D, but with a twist. This time instead of periodically sending off samples the determination to do so is based on risk. Significant risk is defined here as critical items. What is a critical item can be identified by either the customer and you, the organization. When significant operation risk (determined that something is a critical item).

As to how this would apply to a material distributor, I suspect that it would seldom apply, but you need to be aware that it could.

As for the first sentence (I wish they would have been separate paragraphs so they would not so easily mixed up), that entails checking certs on incoming material to confirm that you got what you asked for, something that should be routine anyway.

Also be aware that with the upcoming changes to enforcement of determination of which standard you can get registered to, a distributorship may not be able to move to AS9100.
 
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