AS9102 - 3D printing a special tool required for assembly (counterfeit risk?)

[Bravo]

We are working with an aerospace client that requested a FAIR AS9102.
The drawing general notes state that a special tool (P/N and description) is required for the assembly.
My company is incline to 3D print that special tool to reduce lead time and costs.
Would copying and reproducing a special tool which is similatr to a fixture / insert tool be counterfeited material ?
Woulud this affect compliance with regulatory requirements ?
I believe I should baloon all the notes on drawing including that one, so how can I cope with this ?
If my company decide to proceed with reproducing the special tool, would it be a FAI failure ?

Thanks

 

[Randall Beck]

This is a good question and a gray area at best. I have no idea what tool or jig this is but a requirement is a requirement though.

Section 8.1.4 of AS9100 specifically states that the organization shall control processes to ensure that counterfeit part use and their inclusion in products delivered are controlled....

This would certainly be part of the FAIR and configuration management, and must be a controlled change, but I am not sure it would fall into clause 8.1.4 of counterfeit parts or represent the intent of the clause meaning.

I think the more relevant flow of this requirement, or audit trail, that you would have to show documentation of customer authorization to deviate from the use of the special tool would start in 8.2.2.c under special requirements of the products specified by the organization.

The Note under 8.5.1.d also requires suitable infrastructure including tools be used.

All these clauses lead into section 8.5.6 control of changes section which could be the direct compliance failure (also contract review could be an issue if this is overlooked I think).

All that said the added RISK needs to be mitigated. This would be handled at the customer authorization level by somehow ensuring that the tool you 3D print is fully interchangeable with the specified exact special tool. If you can document and clearly demonstrate this for your customer to have enough confidence you can meet this requirement by not using the specified tool then have them authorize this method in writing.

If you did not go this route, and I was performing an internal audit or 2nd party audit, I would personally find concern in the mentioned clauses, not with 8.1.4 Counterfeit parts so much. Even though it potentially could be grouped into that issue by some.

As Quality Manager of my company I would contact the customer to inform them of the added costs and delays and see if it is possible to go down the road you are asking about. Find out what they would require to show or prove compliance with the tool and then document everything clearly. Their end user may absolutely not allow this regardless what you do or say.

Bottom line - I would certainly not want to be responsible for airplanes in the sky found to be assembled without calibrated gauges or tools.

 

[Jim Wynne]

We are working with an aerospace client that requested a FAIR AS9102.
The drawing general notes state that a special tool (P/N and description) is required for the assembly.
My company is incline to 3D print that special tool to reduce lead time and costs.
Thanks

If not for 3D printing, how is the tool produced? How could the production method be classified as counterfeiting? This isn't something that's incorporated in the part, so as long as the 3D-printed version meets the original specifications what's the problem?

 

[Cari Spears]

Is the P/N and description from a catalog for a specific supplier/manufacturer?

 

[Bravo]

Is the P/N and description from a catalog for a specific supplier/manufacturer?

Yes it is a proprietary special tool which is the same manufacturer of the component that require this tool for its assembly.

 

[Bravo]

If not for 3D printing, how is the tool produced? How could the production method be classified as counterfeiting? This isn't something that's incorporated in the part, so as long as the 3D-printed version meets the original specifications what's the problem?

I agree with you sir the tool will not end in the final product but the requirement on the drawing general notes is still there, therefore if I accept that requirement on the FAIR is the same as I am making a false statement. This was assessed during contract review and the risk accepted. The customer is aware of it but they didn't remove it from drawing. I think I will follow the suggestions of the gentlemen above and ask for a clear authorization to reproduce the special tool with a 3D printer to both customer and end-customer (what about the manufacturer ???) I am here asking you experienced people to learn something.

 

[Jim Wynne]

I agree with you sir the tool will not end in the final product but the requirement on the drawing general notes is still there, therefore if I accept that requirement on the FAIR is the same as I am making a false statement. This was assessed during contract review and the risk accepted. The customer is aware of it but they didn't remove it from drawing. I think I will follow the suggestions of the gentlemen above and ask for a clear authorization to reproduce the special tool with a 3D printer to both customer and end-customer (what about the manufacturer ???) I am here asking you experienced people to learn something.

Please answer the first question I asked.

 

[Bravo]

Please answer the first question I asked.

The tool is made of metal machined parts (one main block and a glide) that have linear relative movement controlled by a knob (screw). I don't know because I only have a picture, no drawing, no dimensions, nothing. We made it using a "reverse engineering" I think.

 

[John Predmore]

I would need to know more specifics to properly answer your question given your particular circumstances. The person who should be answering your question is the quality engineer at your customer But I can think of risks where a 3D printed fixture is not functionally equivalent to a metal machined part made to the same print.

The mechanical design and the fixture drawing (I suspect) contains more information than mere dimensions. Commonly, there are specifications of the raw material (certain grade of steel), maybe heat-treatment, maybe surface treatment, maybe notes controlling surface roughness or the lay of machining marks, sometimes edge conditions (size of fillets, shape and angle of chamfers, or to limit the size or presence of burrs), etc. If the fixture is subjected to wear or impact loading, there are additional engineering considerations, because the surface of a cold-worked metal fixture is tougher than the parent material. A 3D printed part made of the identical parent material, wmight not exhibit the same toughness. and that could be a long-term concern (depending on your circumstances, which I do not know).

 

[Johnnymo62]

It seems to me that a statement on the FAIR for this note would be acceptable. like, read & understood or customer responsibility or customer provided, etc.