That's not my specialty. I can comment based on a couple of year 'aside' I took doing quality support in our QS9000 subcontractors.
I think you have to have the capability to trace a particular product back to when it was made. If this is a QS9000 compliant part (I hate that word 'compliant'), then in the case of a field failure or latent defect, If the automotive customer traced it back to your part (perish the thought). How would you be able to do containment (as in
8D)? If there is not some sort of lot control or equivalent that would enable you to trace back to the date range that may be affected by the defect, how could a problem be contained?
Let's say there is you make a screw out and it is plated with Smith coating material. It is learned that some screws with Smith coating are failing prematurely due to Smith coating not working properly. You trace back into your product history and find that Screws from Date X to Date Y were produced with Smith Coating Lot Number B. You learn that Smith Coating Lot Number B was defective. You do a little further checking and find that Smith Coating Lot Numbers A and C are all good (due to your product samples, but further inspection of your product samples coated with Smith Lot B determines that Lot B isn't performing correctly. In your Root Cause Analysis, it is determined that the root cause of the screws manufactured between dates X and Y is that Smith Coating Lot B was bad. You would need to go back to Smith Coatings and get their root cause analysis as to why they shipped you bad coating materials to put into your 8D. Your corrective action is to get a better grip on that supplier of coating material (perhaps even change coating suppliers if they don't cooperate), improve sampling methodology for your inspections of the coating, increase incoming inspection frequency or tighten up incoming criteria on the coating material, improve final inspection method to be sure the defective coating problem can't escape. Etc..
After the long-winded example, it brings me back to lot traceability. I'm not familiar with your scenario, and I don't claim to be an expert in when lot traceability is or is not required in a QS9000 context. But it would seem that if there are any reliability requirements on your products, then if there is ever a reliability issue (which even in the best companies can occasionally occur), you have no way of tracking down and containing such issues without some at least minimal control of lots or datecodes or date ranges. I work in the semiconductor industry, and have done subcontractor support in those areas, and it gets downright nightmarish sometimes. But it is an expected matter of course that you have to be able to identify and cordone off production segments with some sort of lot/date of manufacture control.
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