COTS Items CoC for FAI Documentation

NDesouza

Involved In Discussions
#1
Hello All,.
Does anyone know how a supplier could provide CoCs for COTS items when a sub tier vender refuses or cannot provide one? I have a case where my supplier was issued a SCAR for not providing a CoC for a COTS item after being directed by the customer that we did not need to provide a CoC for a COTS item as long as a packing slip was provided.

I am new to this supplier but I am aware that there is variation in the customer's requirements on COTS items. It kind of depends on who is receiving the material and the FAI documentation as to whether they will write a QN or a SCAR. This is pretty troublesome. Instead of relying on the current punitive system, I think it is best to come of with a CYOA process that is effective and prevents any further confusion on this issue.

1. Couldn't we provide our own internal CoC for the COTS item?
or
2. Could we provide a template for our sub tier venders to write in the information they do have on the item and say why they could not provide a CoC?

kind of grasping at straws here :blowup:

thanks for any help or ideas you can provide.
 
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yodon

Staff member
Super Moderator
#2
I'm not in aerospace so maybe this isn't applicable. What aspect of conformance are you needing? Raw materials, production process? Obviously, you couldn't attest to those aspects.

Who issued the SCAR (and where does the requirement for the CoC come from)?
 

outdoorsNW

Quite Involved in Discussions
#3
I am not sure I understand the problem. The original post says "I have a case where my supplier was issued a SCAR for not providing a CoC for a COTS item after being directed by the customer that we did not need to provide a CoC for a COTS item as long as a packing slip was provided." The part I bolded in the quote seems to negate any need for a COTS CoC as long as you have a packing slip. Right now it sounds like one person at the supplier is not aware of what someone else at the supplier has said.
 

NDesouza

Involved In Discussions
#4
I am not sure I understand the problem. The original post says "I have a case where my supplier was issued a SCAR for not providing a CoC for a COTS item after being directed by the customer that we did not need to provide a CoC for a COTS item as long as a packing slip was provided." The part I bolded in the quote seems to negate any need for a COTS CoC as long as you have a packing slip. Right now it sounds like one person at the supplier is not aware of what someone else at the supplier has said.
The problem is that although the supplier was given the directive that no CoC was needed, they did not get it in writing. Now we have a SCAR. I want to prevent this type of thing from happening again. My thought is that if we institute a plan of action for COTS items, we won't run into this again.
 

Ninja

Looking for Reality
Trusted Information Resource
#5
In my experience (mainly auto, a little aero...NOT AS9100)...
COTS and CoC/CoA rarely go hand in hand. COTS negates the availability of CoC in most cases I've seen.

That said, consider all aspects of making your own CoC, including assumption of liability.
I buy from Home Depot, the part is defective, the CoC was made by me...I'm on the hook, not Home Depot.
Same situation, with no CoC...I still have the Home Depot's fault open to me...though I'm still on the hook with them for using it.

Making your own CoC fills the gap generating SCARs...but can have other baggage attached. Look all the way around it.

Another aspect: If the supplier was told "don't send CoC", and they don't have it in writing...how do you know they were actually told that?
"Some guy named Paul told me not to bother back in 1991" doesn't fly very far.

If it isn't in writing, it doesn't exist.
Verify whether or not needed, put/get it in writing both for you and the supplier...then the pain stops.

HTH
 

NDesouza

Involved In Discussions
#6
I'm not in aerospace so maybe this isn't applicable. What aspect of conformance are you needing? Raw materials, production process? Obviously, you couldn't attest to those aspects.

Who issued the SCAR (and where does the requirement for the CoC come from)?
In my experience (mainly auto, a little aero...NOT AS9100)...
COTS and CoC/CoA rarely go hand in hand. COTS negates the availability of CoC in most cases I've seen.

That said, consider all aspects of making your own CoC, including assumption of liability.
I buy from Home Depot, the part is defective, the CoC was made by me...I'm on the hook, not Home Depot.
Same situation, with no CoC...I still have the Home Depot's fault open to me...though I'm still on the hook with them for using it.

Making your own CoC fills the gap generating SCARs...but can have other baggage attached. Look all the way around it.

Another aspect: If the supplier was told "don't send CoC", and they don't have it in writing...how do you know they were actually told that?
"Some guy named Paul told me not to bother back in 1991" doesn't fly very far.

If it isn't in writing, it doesn't exist.
Verify whether or not needed, put/get it in writing both for you and the supplier...then the pain stops.

HTH
Thanks very much :)
 

Tagin

Trusted Information Resource
#7
The problem is that although the supplier was given the directive that no CoC was needed, they did not get it in writing. Now we have a SCAR. I want to prevent this type of thing from happening again. My thought is that if we institute a plan of action for COTS items, we won't run into this again.
I would think that you need to have some plan to provide written direction to suppliers for all your requirements. Somehow, you are informing them to provide CoCs. Can't you use the same mechanism to inform them:
  • If component is COTS, provide CoC or a packing slip at minimum
  • Otherwise, provide CoC and packing slip
Can this be placed on each PO? On supplier agreement? Etc.?
 

Ninja

Looking for Reality
Trusted Information Resource
#8
@Tagin 's idea is the right direction.... but consider also the liklihood that the supplier will comply.

From the description above, it seems like they could send a CoC, but were told not to bother...tell them otherwise.
Most (all for me) COTS suppliers will just say "No" in my experience and you'd have to find another way.
 

John Predmore

Trusted Information Resource
#9
Does anyone know how a supplier could provide CoCs for COTS items
The traditional CoC states words to the effect that the supplier "certifies" that the furnished material meets all customer specifications. With a commercial-off-the-shelf item, the immediate supplier may be a distributor, not the manufacturer. I can understand reluctance to certify a statement with no first-hand knowledge or evidence of customer requirements or test results.

I do know the aerospace industry is rightfully concerned about the huge risk of counterfeit parts in the supply chain. Maybe the analogy of a packing slip suggests an acceptable compromise which would work in your situation.

Would it be acceptable to the customer for the distributor of a COTS part to offer a "certificate of conformity" stating only that the furnished part was
- procured from a known reputable source,
- the part number provided is an exact match for the p/n on the purchase order, and
- to the supplier's knowledge, the part provided is of virgin quality (no salvaged or re-manufactured parts).
I think those 3 items are assertions that the distributor could realistically attest to and might serve as an acceptable document to the customer.
 

Johnnymo62

Haste Makes Waste
#10
I have recent experience providing a defense customer with assemblies using COTS hardware.

My customer required the COC to list all of the requirements from the drawing to be listed on the COC, whether it is from the sub-supplier or my company. The distributors could not get anything near adequate, mainly because most of the hardware originated in foreign countries.

This required my company to pay for all of the testing listed on the hardware drawings and specs.

Fortunately, I PPAPed every thing before my customer changed their drawing and listed all of the properties for Loctite.
 
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