AS9102 FAI - What makes a COTS modified? (PCB assemblies)

#1
Hello there,

First of all, before asking this question, I would like to say that I have examined many sources (iaqq faq) including those written in this forum and the guideline of companies operating in aviation sector. If the answer to the question I asked is already given, I apologize in advance.

The company I work with produces PCB assemblies.
PCB designs are made by the firm, the production is made by different companies.

Other processes such as cleaning, coating and soldering of SDMs are performed here. My question is, should "cots surface mount components" be written to form 1 and should not be given any c of c references?

My personal opinion is that the PCB should be written to Form 2 and refer to the "c of c" from the supplier and write the other SMDs to Form 1.

A simple summary of the BOM is as follows.

1. PCB Assy​
1.1 PCB​
1.2 SMD Component (Cots)​
1.3 SMD Component (Cots)​
1.4 coating material etc.​

If we do coating on a COTS "com module" , will it make it a modified cots?
In this case, I think I need to write this card and processes to Form 2.

Thank you in advance for your help.
E.G.
 
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#3
Howdy,

First of all, I would follow Sidney's advice and get it from the "horses mouth".

Second, I am not in aviation, but have a fair bit of experience with electronics assemblies.

If you mount SMD's to a COTS board, everyone I've ever worked with would consider it modified (auto, medical)...so many things can go wrong with forces, heat (point solder, solder reflow) and stresses from coating, not even to go into material compatibility, diffusion or leaching. Get the answer from someone in authority, and please share your experience here.
I will be shocked if the board is not considered "modified", but I'll learn if you share...
 

dsanabria

Quite Involved in Discussions
#4
Hello there,

First of all, before asking this question, I would like to say that I have examined many sources (iaqq faq) including those written in this forum and the guideline of companies operating in aviation sector. If the answer to the question I asked is already given, I apologize in advance.

The company I work with produces PCB assemblies.
PCB designs are made by the firm, the production is made by different companies.

Other processes such as cleaning, coating and soldering of SDMs are performed here. My question is, should "cots surface mount components" be written to form 1 and should not be given any c of c references?

My personal opinion is that the PCB should be written to Form 2 and refer to the "c of c" from the supplier and write the other SMDs to Form 1.

A simple summary of the BOM is as follows.

1. PCB Assy​
1.1 PCB​
1.2 SMD Component (Cots)​
1.3 SMD Component (Cots)​
1.4 coating material etc.​

If we do coating on a COTS "com module" , will it make it a modified cots?
In this case, I think I need to write this card and processes to Form 2.

Thank you in advance for your help.
E.G.
COTS belong on form 2

In addition - have you looked at the Supply Chain Management Handbook section 3.2 - FAI Training module
 
#5
If I were you, I would ask the AS9102 IDR. His name and contact information are available from the IAQG Standards Register Matrix. Or, you can also trigger a request for clarification using the IAQG OASIS feedback feature as below.
Good luck.
Hello,
I have created a feedback ticket on the subject. After waiting for a while I will reach the AS9102 IDR .
If I can get an answer, I will share it with you. Thanks for your suggestion.
 
#6
Howdy,

First of all, I would follow Sidney's advice and get it from the "horses mouth".

Second, I am not in aviation, but have a fair bit of experience with electronics assemblies.

If you mount SMD's to a COTS board, everyone I've ever worked with would consider it modified (auto, medical)...so many things can go wrong with forces, heat (point solder, solder reflow) and stresses from coating, not even to go into material compatibility, diffusion or leaching. Get the answer from someone in authority, and please share your experience here.
I will be shocked if the board is not considered "modified", but I'll learn if you share...
Hello,

I think we are on the same page about the board being a modified cots.

In "SCMH Section 3.2.2 First Article Inspection 9102B Updated FAQs" it is stated that:
"Standard Catalogue and Commercial-Off-The-Shelf (COTS) Items, when used as purchased, are entered on form 1. If Standard Catalogue or Commercial-Off-The-Shelf (COTS) Items (e.g., AN, MS fasteners) are modified, then list that Standard Catalogue or Commercial-Off-The-Shelf (COTS) Items on form 2, field 6."

According to this, I get the feeling that, the PCB and also the SMDs should be treated as modified cots and listed in Form2.
 
#7
COTS belong on form 2

In addition - have you looked at the Supply Chain Management Handbook section 3.2 - FAI Training module

Hello,

Yes I have, actually after looking at the SCMH I got pretty confused.
According to this, COTS belongs to Form 1, a CofC is not required. If "modified" Form 2.

"Standard Catalogue and Commercial-Off-The-Shelf (COTS) Items, when used as purchased, are entered on form 1. If Standard Catalogue or Commercial-Off-The-Shelf (COTS) Items (e.g., AN, MS fasteners) are modified, then list that Standard Catalogue or Commercial-Off-The-Shelf (COTS) Items on form 2, field 6."
 

Eredhel

Quality Manager
#8
Are you using the AS9102 forms because someone externally has asked you to or is it an internal requirement? I'll be curious to see this develop as whenever I've needed to do AS9102 it's been pretty straightforward components and assemblies (not modified assemblies.)
 
#9
Hello,

I got an answer from the IDR. I think 've had some difficulty explaining the situation, so I'm just skipping the unnecessary parts and cutting to the chase.

"...
We have a PCB Assembly which has passive/active COTS components on it, being soldered. And the assembly is coated later on.
Form 1 covers the BOM of the assembly, (Not giving reference to COTS components CofCs as "the CofC would not be required for supporting documentation.")
Form 2 covers the bare PCB, coating material etc. and the soldering process.
Am I correct?"

Response:
"Yes
Form 1 is for parts and assemblies, including COTS parts.
Form 2 is for materials and processes. A COTS parts can be a material when the COTS part is being modified."
 
#10
Are you using the AS9102 forms because someone externally has asked you to or is it an internal requirement? I'll be curious to see this develop as whenever I've needed to do AS9102 it's been pretty straightforward components and assemblies (not modified assemblies.)
Hello,

I'm really sorry for my late response, things have been hectic lately. I must have missed your reply.
It is actually a customer requirement.

Efe.
 
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