FAI IAW AS9102 - First Article Inspection Documentation Question

[QA_Newbie2000]

I am new to the AS9102 requirements and FAI?s in general. My question is around the requirement to have C of C?s for items in the BOM.
Here is my situation/problem: We are bidding a job that requires an FAI IAW AS9102. The intention was to use some previously purchased inventory to build the item. My problem is that we purchased this material more than 7 years ago and we no longer have the CofC that the parts were received with.In our parts data base we have traceability to the original PO, supplier, batch, etc and it shows that we requested a CofC that the inspector that received the parts verified.The parts were put into a controlled storage area where they have been kept ever since. Unfortunately the Receiving Reports that would have the CofC were destroyed after 7 years (per our retention policy)
A colleague mentioned that we couldn?t use this material since we are required to provide CofC?s (if requested) for the material that is used to build the item. I have read the standard and I don?t see that implicitly stated, but my colleague has much more experience than I do
I would really appreciate the opinion of Cove as to whether or not I can use material that I don?t have the manufacture CofC
Thanks for your help

 

[Mike S.]

Ask your customer -- explain the situation to them and see if it is okay with them. Based on 5.6 I'd say if it is okay with the customer, it is okay.

 

[Kronos147]

I think you are going to need the certs.

Any chance your supplier can provide copies?

 

[QA_Newbie2000]

Not Likely. We are planning to see if the supplier has copies, but like I said the parts were purchased 7+ years ago.
Just so I don't confuse the situation the parts in question are predominately COTS items

 

[QA_Newbie2000]

For Evaluation Activities the Standard states:

4.5 Evaluation Activities​

The organization shall conduct the following activities during product realization, when applicable, in support of FAI to ensure​

conformance with design characteristics:​

a. Review documentation for the manufacturing process (e.g., routing sheets, manufacturing or quality plans,​

manufacturing work instructions) to ensure all operations are complete as planned and call out the correct specification,​

material types, conditions, and approvals.​

b. Review supporting documentation in the FAI (e.g., inspection data, test data, Acceptance Test Procedures, special​

process approvals and certifications) for completeness.​

c. Verify that the raw material and special process certifications call out the correct specification, material types, conditions,​

and approvals.​

d. Verify that required customer approved sources are utilized.​

e. Review nonconformance documentation included in the FAIR for completeness.​

f. Verify that required designed tooling (e.g., part specific gauges) are used and appropriately documented on Form 3.​

g. Verify that every design characteristic requirement is accounted for, uniquely identified, and has inspection results​

traceable to each unique identifier.​

h. Verify the design characteristics that are the output of the manufacturing process are measured, inspected, tested, or​

verified to determine conformance, including DPD characteristics as required per 4.3.b.​

i. Verify part marking is legible, correct in content and size, and properly located per applicable specifications.

The only part that may call out the requirement for CofC's is:​

b. Review supporting documentation in the FAI (e.g., inspection data, test data, Acceptance Test Procedures, special​

process approvals and certifications) for completeness​

Is that were the tie in to requiring CofC's comes from?
I don't mean to come across as challenging the answers provided, since that is definitely not the case (I greatly appreciate the opinions of the Cove), I just need to understand the basis for the answer
Thanks for your help

 

[tlonkey]

My experience with the FAI process has been that the CofC's are required by the customer. My company supplies to the major aircraft customers. I think your best option would be as another cover (Mike S.) suggested; get with your customer QA and ask.

 

[Kronos147]

My experience with the FAI process has been that the CofC's are required by the customer.

I would add that I would wager up to $5 it says so in your procedures somewhere too that you used the C of C for COTS as part of the receiving inspection process. If so, you have obligated yourself.

Eric

 

[QA_Newbie2000]

it says so in your procedures somewhere too that you used the C of C for COTS as part of the receiving inspection process. If so, you have obligated yourself.

What do you mean by this? If I request a CofC from a vendor then I'm obligated to have that as part of my FAI package?

I'm sorry to keep going back to this, but where in the standard is that stated? I don't see the link in the standard to the requirement.
I get, and can see the need, for certifications for special processes or of raw material certs, but not COTS items

 

[Mike S.]

Here is why I think you need the C of C:

5.2 Evaluation Activities:
The Organization should conduct the following activities in support of FAI.

4. Review material certifications for compliance, as applicable.


5.6 Control of Records:
All FAI documentation required by this Standard shall be considered as a quality record and the Organization shall retain it according to Customer or regulatory requirements.

I'm not an FAI expert, it's just how I read it, FWIW.

 

[Kronos147]

What do you mean by this? If I request a CofC from a vendor then I'm obligated to have that as part of my FAI package?

IF your organization states anywhere (Quality Manual, Purchasing Procedure, Receiving Inspection documentation) that one of the criteria for purchased product acceptance (including COTS) is to obtain, validate, and file the C of C, then by extension, the FAIR will only be valid with that data.

If the organization does not state that, all my concerns are invalid.

It is up to you, your organization, and your auditors to discover if you have obligated yourself.

Then there is the other point made prior that it may be a requirement of the customer anyway.

Cheers,
Eric