Counterfeit parts prevention - Audit Nonconformance - AS9100 8.2.2

[Golfman25]

Thanks to everyone for your observations and input.



- Golfman25 - This particular customer states "...using Industry Standard AS6174 as guidance ... " for development of a control plan. I'm not trying to manipulate words, but I think that may afford some latitude in the content of the documented plan, as opposed to "...in accordance with..." which would require strict adherence?



The original post was directed more towards the proper response (CA) for the finding. It seems like you folks are indicating that the response should include the Counterfeit Control Plan, I'll plan to do that, but shouldn't the root cause be more like "Ineffective customer requirements review" (I think this is supported by the auditor citing 8.2.2 rather than 8.1.4? I realize that the RC that I mentioned above may be just restating the finding but I'm not sure what to add unless I try to attribute it to our AS9100 QMS being relatively new so we're still learning and improving, and then CA would include training to 8.2?

Once again, your input is sincerely appreciated, I'll never cease to be amazed (and grateful) for the giving and sharing of the Quality community.

I highlighted "guidance" because that isn't really a "shall" word. You indicated you had some type of training that hit all the important points without identifying the standard -- which is probably sufficient.

As for your real question, I think it would have to do with the specific wording of the finding. Did he say "contract review not effective" and use the counter fit parts issue as evidence? Or is he in fact concerned about the counter fit parts requirements?

 

[Kirby]

Cari Spears,
We understand it to mean a general plan / procedure, that's the approach that we are taking.

We make, upgrade, and install one-off, process specific products (control panels) to support our customers' (or their customers') aerospace / aviation manufacturing. We do not conduct production runs of multiple fly-away parts (or any parts for that matter).

We have reviewed contracts / P.O.s and feel that we have captured all other relevant requirements. As part of our CA we plan to create a list of "typical" requirements, including statutory and regulatory requirements found in our customers' contracts and supplier requirements that we can use a a tool to ensure that we respond to any that are not typical and that we need to research. We have a very mature, experienced group conducting contract review and they are familiar with the typical requirements, I just think that with the counterfeit control issue, it was taken for granted that we had documented controls in place. And we did ... sort of. We have verbiage in out Control of NC Outputs, Supplier Control, and Control of Production and Service Provisions that references counterfeit control, unfortunately it was the specific reference to AS6174, and our lack of organizational knowledge thereof that got us in trouble. (We actually had a copy of that standard in our library!)

So far we identified multiple corrective actions including training to 8.2 of the standard and to our (slightly revised) Customer Requirements (contract review) procedure, development of a counterfeit control plan / procedure, with training to follow, and revision of our supplier flow down requirements to mimic our customers' supplier requirements.

Once again, thank you for your input, any additional insight would certainly be welcomed.

 

[Kirby]

I highlighted "guidance" because that isn't really a "shall" word. You indicated you had some type of training that hit all the important points without identifying the standard -- which is probably sufficient.

As for your real question, I think it would have to do with the specific wording of the finding. Did he say "contract review not effective" and use the counter fit parts issue as evidence? Or is he in fact concerned about the counter fit parts requirements?

His statement was "The Organization's Management Confirms that an accepted Customer Purchase Order includes a Requirement for the Organization to "establish and maintain a Counterfeit Parts Prevention and Control Plan using Industry Standard AS6174 as guidance", but that the Organization lacks awareness as to requirements included in SAE AS6174.” and he referenced 8.2.2. I know, it really is plain enough but I would rather his statement included "contract review not effective", just to remove all doubt, but I think the reference to 8.2.2 indicates that this is what he was saying.

Thank you for your interest and for taking the time to reply. Any other insight would be sincerely appreciated.

 

[Sidney Vianna]

Any other insight would be sincerely appreciated.

Attached, you will find the current version of a Counterfeit Parts Prevention Guidance document developed by the IAQG and available @ the IAQG Supply Chain Management Handbook website

 

[Golfman25]

His statement was "The Organization's Management Confirms that an accepted Customer Purchase Order includes a Requirement for the Organization to "establish and maintain a Counterfeit Parts Prevention and Control Plan using Industry Standard AS6174 as guidance", but that the Organization lacks awareness as to requirements included in SAE AS6174.” and he referenced 8.2.2. I know, it really is plain enough but I would rather his statement included "contract review not effective", just to remove all doubt, but I think the reference to 8.2.2 indicates that this is what he was saying.

Thank you for your interest and for taking the time to reply. Any other insight would be sincerely appreciated.

I am no expert in aviation or AS, so I am just throwing stuff against the wall for thought. Frankly, I think this is a stretch. First, it is a guidance document, not a required document. Second, you mentioned that what you had does comply with the requirements, although "unknowing." You even had a copy of the document which you could reference if needed. There is no requirement to know the doc verbatim.

But you now indicated you don't make "parts." But rather control panels for manufacturing processes? It's unclear to me -- do your panels get installed in planes? If not, how do counterfeit parts even come into play?

 

[Al Rosen]

I am no expert in aviation or AS, so I am just throwing stuff against the wall for thought. Frankly, I think this is a stretch. First, it is a guidance document, not a required document. Second, you mentioned that what you had does comply with the requirements, although "unknowing." You even had a copy of the document which you could reference if needed. There is no requirement to know the doc verbatim.

But you now indicated you don't make "parts." But rather control panels for manufacturing processes? It's unclear to me -- do your panels get installed in planes? If not, how do counterfeit parts even come into play?

AS6174 Title is Counterfeit Materiel; Assuring Acquisition of Authentic and Conforming Materiel
It addresses more than parts. If it wasn't applicable I think the contract review process should have resolved the issue wth the customer.

 

[Kirby]

I am no expert in aviation or AS, so I am just throwing stuff against the wall for thought. Frankly, I think this is a stretch. First, it is a guidance document, not a required document. Second, you mentioned that what you had does comply with the requirements, although "unknowing." You even had a copy of the document which you could reference if needed. There is no requirement to know the doc verbatim.

But you now indicated you don't make "parts." But rather control panels for manufacturing processes? It's unclear to me -- do your panels get installed in planes? If not, how do counterfeit parts even come into play?

I think that since our customers ( who have customers that flowed down the requirement) states in their supplier requirements document and / or T&Cs that we develop a control plan for counterfeit parts we are bound to comply, whether we see value or not. I can understand the danger of counterfeit parts, even in the equipment used to manufacture the airplanes. These programs are very high-dollar operations so there would be financial / schedule risk due to equipment failure. Also, when they are moving or assembling some of the huge parts ( think airliner wings and fuselages ) there could be safety concerns created by equipment failure . The truth is most (maybe all) of the parts that we purchase are basic electrical, electronic or hardware parts and are purchased from big regional or national, distributors. Very minute chance of receiving counterfeit. To be candid, I think the auditor could have found more relevant findings but chose to issue this one, perhaps I should be happy it wasn't worse, and technically speaking we were indeed guilty of not complying with the customer requirements in their entirety (Lack of anything called "control plan" that we could point to as proof of compliance.) It's true that, after the fact, we discovered that a combination of documents and activities pretty much covered the "guidance" of the standard, our lack of awareness of this prior to the audit was a problem. I don't like to do work just for the sake of AS, or because an auditor wants it, where there is no real value to the internal processes, but I have learned that sometimes it may make things easier on all concerned to have clear objective evidence rather than trying to piece together a line from this document and a paragraph form another in in order to demonstrate compliance to a given requirement.

 

[Kirby]

AS6174 Title is Counterfeit Materiel; Assuring Acquisition of Authentic and Conforming Materiel
It addresses more than parts. If it wasn't applicable I think the contract review process should have resolved the issue wth the customer.

I agree, Al, however I'm not sure that the case for it not being applicable is 100% defensible. We do use some pretty common electrical and electronic and hardware items (No cutting edge or ultra precision level stuff) procured from the big "Box stores" of this industry, so the risk is minimal, but I can't say that it does not exist.

 

[Big Jim]

I agree it is a contract review problem. Someone didn't make sure that they understood the Terms and Conditions. Or maybe they didn't even read them.

 

[al40]

I know from my experience working within the PCB industry that you have to write the procedure tailored to your organization. I can send you a copy of mine if you PM me.
Best,
Al40