AS9120B Clause 8.4.1.1 External Providers Scope of Approval

[QualityStandardsGirl]

We just went through our AS9120B upgrade audit and got a non-conformance on Clause 8.4.1.1 The organization has not fully maintained a register of external providers that includes the scope of approval.

We had our approved external providers listed as Supplier (distributors), Vendor (repair vendors), Both (Supplier & Repair Vendor) or Non-Aviation. The auditor said that didn't break it down far enough. We are wondering how far you need to break down the scope of approval. Would it be ok to say the vendor is approved for Engine repairs or airframe repairs or does it need to be more in depth than that?

I tried looking at some of our customer's AVL and I am finding all different things.

 

[Sidney Vianna]

Issue already discussed a few times here.

AS9120B Clause 8.4.1.1 External Providers Scope of Approval

Defining your Scope of Approval - AS 9100 7.4.1(a)

EDIT: Updated links.

 

[Perspicuity]

An AS9120 QMS system should have supplier categorizations that are second to none; after all, supply chain management and inventory control are undoubtedly your core competencies. This said, I would not look to my customers’ AVL’s for guidance since they are probably not AS9120.

Commodity/service type approval scopes are probably the most common; however, dependent upon the needs of your business you may opt for something different. Maybe you can expand upon what you already have (e.g. Surplus Distribution, ASA100 Distribution, AS9120 Distribution, FAA Repair, AS9110 Repair, Nadcap Processor, etc.).

Remember, an auditor may gig you for sending a flight control to a supplier you have approved for “Engine Repair” even if that supplier has an FAA approval for both propulsion and airframe.

I would stay away from scopes such as Full Approval, Conditional Approval, or the like. These pertain to approval status and not scope.

 

[doctall41]

We just went through our AS9120B upgrade audit and got a non-conformance on Clause 8.4.1.1 The organization has not fully maintained a register of external providers that includes the scope of approval.

We had our approved external providers listed as Supplier (distributors), Vendor (repair vendors), Both (Supplier & Repair Vendor) or Non-Aviation. The auditor said that didn't break it down far enough. We are wondering how far you need to break down the scope of approval. Would it be ok to say the vendor is approved for Engine repairs or airframe repairs or does it need to be more in depth than that?

I tried looking at some of our customer's AVL and I am finding all different things.

Full Disclosure, I think QualityStandardsGirl and I had the same auditor, a couple of weeks apart. My auditor also said the Scope of my External Providers was not broken down enough. I actually agree with her on that. For example, on my outside processors for Penetrant, anodize, prime, cad plate, topcoat, etc, I have them listed as Finishes.
For something like that, how do you guys have the scope listed for your outside processors? Do you list everything they are approved to do?
Thanks in advance for your help!
doctall41

 

[Perspicuity]

I think listing “everything they are approved to do” is not required, misleading, unmanageable and risky. It is important to step back and understand the dynamics of an ASL/AVL. Is it your list? Does it contain directed sources? Are you a prime? Do you build-to-print? Do you design? What about fixed processes?

Some of the biggest companies have it easy; they make a list of suppliers and include a basic listing of what these suppliers provide.

A build-to-print company (for example) must be attentive to their own suppliers, the suppliers of their customer(s), and suppliers unique to their industry. If customer A says you can use Acme Finish Inc for penetrant and anodize, while customer B says Acme Finish Inc can only be used for chem-film, whose supplier scope listing are you managing? Your own or your customers’? To me, this may be a “Special Process Source” or may be a “Directed Source”.

Requisitions, purchase orders, MRP systems (item master listings) are intended to control procurement (when coupled with competent buyers)! “Approval scopes” are rightfully intended to be abbreviated. To merely state a source is approved for penetrant inspection can be misleading? Are they approved for ASTM-E-1417, MIL-I-6866, BAC 5423, or another of the myriads of penetrant specs? Are they competent with titanium castings or do they just use visible dye on structural steel? Are they capable of pre-penetrant etch and if so will they scrap your expensive assembly because they don’t really understand when not to etch?

The key is to make your approval scope work for you and arguably effective without the introduction of misleading risk. Also, I stand by my original statement: An AS9120 system should have a procurement system second to none.

 

[Sidney Vianna]

An AS9120 system should have a procurement system second to none.

While I agree with the opinion in theory, the reality is: most pass-through aerospace distributors are small organizations without the resources and knowledge to perform in-depth supplier assessments.

If one were to expect a small aerospace distributor to have a robust supplier quality function to the level of an OEM, most AS9120 certificates would have to be revoked.