Flowdown of Aerospace record retention requirements (AS9100)

WCHorn

Rubber, Too Glamorous?
Trusted Information Resource
#1
Let’s say you’re making aerospace cookies. You have a proprietary formulation for the cookies. The customer buys the cookies to their specification, which deals primarily with size, texture, taste, and packaging, and does not specify any raw materials to use.

The customer mandates 7 year record retention for their orders. You flow the requirement down to your suppliers: eggs, milk, butter, sugar, chocolate chips and the like. They notify you that they keep records for 3 years only and ask for relief from the requirement.

First, are you required to pass the requirement down to your suppliers? The basis for a “no” response might be that the cookies are “created” at your cookie plant, the raw materials used are not specified by the aerospace customer and yours are the only requirements for the raw materials. A “yes” response might be the “down to the dirt” apothegm. That seems unwarranted to me, since the aerospace company is buying cookies you created from proprietary raw materials. None of the raw materials were specified by the customer, just the cookies. As long as you have all your records and meet the customer’s requirements, to me that should be sufficient in this case and it is unnecessary to flow down the record retention requirement.

Second, are you justified in granting a waiver to the suppliers without customer approval (a burdensome requirement since you sell your cookies to many different aerospace customers)?

What say you?
 
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Michael_M

Trusted Information Resource
#2
Did the (Aerospace) Customer Purchase order specify the requirement? Did contract review find the requirement? In reality, I would probably just ask my supplier for the records and maintain them at my plant but if the customer PO specified the requirement, to me you have no leg to stand on since you accepted the PO.
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#3
First, are you required to pass the requirement down to your suppliers?

What say you?
AS9100 Rev.C, 7.4.2 h) requires you to flow down the requirements, unless your customer grants YOU the exemption. Alternatively, you could keep the records from the suppliers for the minimum retention time.

The question would be: WHAT records from the suppliers would be required to be retained; after all, they also have incoming inspection, in-process and final inspection and test records...would you require ALL of those records to be retained?
 

WCHorn

Rubber, Too Glamorous?
Trusted Information Resource
#4
AS9100 Rev.C, 7.4.2 h) requires you to flow down the requirements, unless your customer grants YOU the exemption. Alternatively, you could keep the records from the suppliers for the minimum retention time.

The question would be: WHAT records from the suppliers would be required to be retained; after all, they also have incoming inspection, in-process and final inspection and test records...would you require ALL of those records to be retained?
One of our aerospace customers requires retention of "all records pertaining to material/mfg process, special processes, test and inspection." Another cites "process, inspection and conformance records regarding the product." Yet another cites "all quality and certification records." Another just cites "quality records."

So yes, given our customers' varied and a few somewhat vague requirements, I believe all would need retention.
 

dsanabria

Quite Involved in Discussions
#5
Let’s say you’re making aerospace cookies. You have a proprietary formulation for the cookies. The customer buys the cookies to their specification, which deals primarily with size, texture, taste, and packaging, and does not specify any raw materials to use.

The customer mandates 7 year record retention for their orders. You flow the requirement down to your suppliers: eggs, milk, butter, sugar, chocolate chips and the like. They notify you that they keep records for 3 years only and ask for relief from the requirement.

First, are you required to pass the requirement down to your suppliers? The basis for a “no” response might be that the cookies are “created” at your cookie plant, the raw materials used are not specified by the aerospace customer and yours are the only requirements for the raw materials. A “yes” response might be the “down to the dirt” apothegm. That seems unwarranted to me, since the aerospace company is buying cookies you created from proprietary raw materials. None of the raw materials were specified by the customer, just the cookies. As long as you have all your records and meet the customer’s requirements, to me that should be sufficient in this case and it is unnecessary to flow down the record retention requirement.

Second, are you justified in granting a waiver to the suppliers without customer approval (a burdensome requirement since you sell your cookies to many different aerospace customers)?

What say you?
From another perspective ...

think of retention of records from a legal point of view!

CASE: an accident happens and there is an investigation and it really comes down to your company making the product. Part of the process is that you need to heat treat the material and you send it out to a heat treated. The investigator comes to your companies and inquires about the records of the heat treatment supplier (Oven calibration, training of personnel, time etc...) you then take them to the heat treater and they tell you that you never told them to retain records and they got destroyed last week.

Guess who is liable.....


Contract review and risk management should have been involved in this process.

Bottom line - when in doubt share the requirements and trace ability to your suppliers.
 
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