AS9120 to AS9100 due to value added activities

#1
I just joined a small company that has been AS9120. They provide barstock and coil and plate material for machine shops etc. Our last audit, the auditor suggested that we move to AS9100 since we are performing value added activities.
The value added activities we provide are mostly special processes provided by our vendors and some grinding to size. All of it is done by vendors and processors.
For example, Our customer will order 15-5 material to H1075. We will order the 15-5 material from a vendor and send it to a heat treater to be heat treated to H1075 and then ship to the customer. if they require a non standard diameter, we will send it to a grinder to be ground to size. All vendors are controlled per AS9120 External Provider requirements.
Our registrar is saying that this means we take control of the process and are therefore a manufacturer and need to go to AS9100. I tend to agree with this, but our upper management is in WTF mode.
My questions.
What differentiates a distributor from a manufacturer when it comes to value added activities.
Is our registrar correct in their evaluation that we should be AS9100?
 
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Sidney Vianna

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#2
Is our registrar correct in their evaluation that we should be AS9100?
I agree with your CB auditor's take. Your organization is performing value-added activities and the fact that they are outsourced is irrelevant, and your organization is still responsible for ensuring the special processes are properly validated and re-validated and the product conforms to requirements. In Rev. A of AS9120, the following paragraph applied:

Screenshot 2022-01-05 143354.jpg
Having said that, I know for a fact (as I was a member of the AAQG Leadership Team for a number of years) that some people within the IAQG would disagree with your auditor's stance and allow you to remain in the AS9120. If you want more than just "opinions", contact the IDR for AS9120 via IAQG/OASIS and post your question to the individual and s/he will provide you with an "authoritative" answer.

Also look at #19 of the AS9120:2016 FAQ Document

Screenshot 2022-01-05 144710.jpg

Good luck.
 
#3
I agree with your CB auditor's take. Your organization is performing value-added activities and the fact that they are outsourced is irrelevant, and your organization is still responsible for ensuring the special processes are properly validated and re-validated and the product conforms to requirements.

Having said that, I know for a fact (as I was a member of the AAQG Leadership Team for a number of years) that some people within the IAQG would disagree with your auditor's stance and allow you to remain in the AS9120. If you want more than just "opinions", contact the IDR for AS9120 via IAQG/OASIS and post your question to the individual and s/he will provide you with an "authoritative" answer.

Good luck.
Thanks for the quick and helpful reply
 

Randall Beck

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#4
Sidney is certainly more qualified than I am, but as a AS9100 and NADCAP commercial heat treater (we don't perform any manufacturing/machining processes) that performs both in house and outside heat treat services we take the same responsibility for both so I would certainly agree that AS9100 sounds applicable and proper for your organization.
 
#5
I think something was missed in the commentary about the application.

"This standard is intended for use by organizations that procure parts, materials, and assemblies and resell these products to a customer in the aviation, space, and defense industries. This includes organizations that procure products and split them into smaller quantities, including those that coordinate a customer or regulatory controlled process on the product."

It looks like this line opens the door for value added work as long as it is done under the direction of the customer.

I had a client that changed registrars from one that insisted that they had to move to 9100 because they were coordinating heat treating required by the customer. They move to a registrar that permitted them to be 9120 based on this line. I will not comment further on the customer or the registration bodies involved.
 
#6
I think something was missed in the commentary about the application.

"This standard is intended for use by organizations that procure parts, materials, and assemblies and resell these products to a customer in the aviation, space, and defense industries. This includes organizations that procure products and split them into smaller quantities, including those that coordinate a customer or regulatory controlled process on the product."

It looks like this line opens the door for value added work as long as it is done under the direction of the customer.

I had a client that changed registrars from one that insisted that they had to move to 9100 because they were coordinating heat treating required by the customer. They move to a registrar that permitted them to be 9120 based on this line. I will not comment further on the customer or the registration bodies involved.
Thanks Jim. This is where it gets confusing, and surprisingly, this hadn't come up in 5 years of previous audits before I arrived. I guess I'm just lucky.
In our case I don't think we are coordinating heat treating with the customer. Instead we are providing product that is heat treated.
If we were a distributor of stainless steel and a customer ordered a bar of 17-4 and added a HT requirement, then we would be coordinating, but if they just order 17-4 H900, and we purchase 17-4 and then send to a heat treater, we are not coordinating. Instead we are producing the product to the customer requirement.
Its a very subtle difference, but I think our (Current) auditor is correct in this case.

But i agree it's subject to interpretation and could change from auditor to auditor. Some creative wording on our companies part in regard to Order acknowledgement and requiring customer agreements that value added will be coordinated etc could help us, but that just gets complicated.
 
#7
It is a matter of semantics. It is subtle. It requires the sales force to understand what you can and can't do and present it to the customer accordingly. What you can't do is buy metal, send it out for heat treating, then keep it in stock until someone asks for it. What you can do is heat treat it for your customer according to their direction AFTER the order.
 
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