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AS9100D -8.5.1j - Accountability For All Products Tiny Parts

#1
I tacked this on to an old thread, but it didn't gain traction so I thought I would start a new thread.

We are a build to print manufacturer that uses approximately 30 piece parts (many very small) in order to build an assembly.

We build in quantities up to 2500 and end up with ~2490 with a handful of piece parts due to weighing variation. There is little/no risk in our opinion for tracking every single part/process.

At the end of the order we count the number of good parts, the number of bad parts, and the number of parts missing or used in destructive testing (yield loss). This number always adds up to the order quantity.

We attempt to run single piece flow so tracking quantity good/bad by process is not feasible as in some cases you only scrap some parts (when in a sub-assembly level) or because it would take longer to count than it would to actually complete the process.

In 2018 we were given a finding for the count and added that a set % would be allowed to be off on the count before raising a red flag for review. The C/A was accepted but then the follow up audit wrote us back up for the same thing, declaring our C/A unacceptable. I have appealed but still cannot get a good answer on how companies that work with tiny piece parts (1/32" diameter balls and tiny stampings) could ever have 100% accountability on these items.
 
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#2
If the CA plan was rejected by the CB after being accepted, you are entitled to know why. The intent of this requirement is to prevent bogus (counterfeit) parts in the supply chain. The adequacy of the controls has to take into account the likelihood of bogus/counterfeit parts being introduced in to the market.

You can create a ticket in OASIS for the AS9100 Document Representative asking for clarification.
 
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