Heading dies as "tooling" and AS9100

#1
Backstory, I just got hired here about 4 months ago but have a long history of working in aerospace manufacturing facilities (purchasing).
OK, so we are a "heading" manufacturer of socket head screws etc... I have a few questions about the tooling and it's applicability to any AS or ISO requirements.

The Quality Dept. and most everyone else treats the dies, punches, and other tooling required to "head" fasteners as nothing important. Like other cutting tools we buy from MSC let's say.. (This tooling is creating the shape of the fasteners, how could it NOT be important?)

For each tool (die, punch, hammer, knock out pin), we create it's own drawing with revisions, etc.. and supply those to the vendor with each new PO.
The fact that we created a drawing with revisions, doesn't that mean we need to be inspecting every new lot or item to that drawing? Checking if it's got the RC required per that drawing? Was the correct material used as per the drawing? (Management thinking is "the suppliers know what we want, and we trust them to make as per the print so we don't need to check it..) OMG !!! Really??

These items do not get "inspected" by the Quality Dept. like the coil wire (raw material) does. They have the tool crib people just doing some simple caliper checks of dimensions when they come in from our suppliers. (Doesn't that mean they should be "trained" to do this task? Shouldn't it be in their job description?)

I've also seen some "rejections" to the suppliers for not meeting the dimensions on our print. (Why are we NCRing something that "isn't important" - When we do, aren't we now saying "it's important"?) I'm new to this company and it smells like a potential finding but I can't seem to get anyone to agree with me. What part of which standard proves my point? Or I am concerned about things I shouldn't be? Thank you for your input!
 
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#2
This is a difficult question to respond to based on the information you provided.

From what I understand:
  • You are concerned about the acceptance procedure your company has in place for custom tooling.
  • The tooling is designed in house and records are kept of drawings and revisions made to said drawings.
  • The tooling is manufactured for you by an outside supplier.
  • Raw material orders are inspected by your quality department on arrival to ensure that correct item was ordered, and that it meats specification.
  • The custom tools in question are not inspected by your quality department.
  • The custom tools are inspected by the people who work with the tools. (who presumably know what they are looking for as they are the people who have the most hands on experience working with the tooling in question)
  • The inspection process in place has detected non conforming tools and rejected them appropriately.
  • The inspection is some how documented at the very least in the case of rejection in the form of a returned tool and a NCR.
Unless I have misunderstood something. it sounds to me like the established process works. and the most qualified people are already assigned to the task of inspection. Non conforming tooling is being detected and corrected before they affect your output product conformity. I don't see a problem. In fact it seems that AS9100 is being effectively applied. The risk of the tooling ordered is being considered (I would probably classify these tools as low to moderate risk). As the risk is not zero a procedure is established to prevent non conformities as a result of the tooling (having the persons who use the tools check key characteristics against the drawing). Presumably each batch or lot of product is tested before being released for sale to a customer, also presumably this testing would reveal any potential nonconformity caused by non conforming tooling, and allow for non conforming batches or lots of product to be quarantined and reviewed before being released or destroyed (dependent on the results of the review).

Has this process allowed nonconforming product to be sold? Has it caused increased costs or on time delivery as a result of the need to dispose of non conforming product? Has it impacted product quality or customer satisfaction? If the answer is yes to any of those questions then you absolutely have an issue that needs to be addressed. If the answer is no then it sounds like management is right in their assessment that no further action is needed.

To address your other questions:

Should the tool crib people be trained to do this? (Again I'm assuming the tool crib people are the ones who are directly working with the tools the most)
Yes they absolutely should. However there is no need for formal training in every single thing. excessive documentation is the reason AS9100 gets a bad wrap. Does a certificate requiring recurring certification and training in how to use a dial caliper to measure a tool help anyone? Further Does your company employ anyone who works with these tools who is not capable of doing so without specific formal training? If so maybe think about replacing those employees because that should be a task anyone working with aviation tooling should be able to do in their sleep.

Should it be in their job description?
Maybe, but probably not, but also it probably already is. I don't think I have ore ever will have a job where every single thing I do is explicitly lined out in the job description. The job description they have likely lists the need to be able to measure parts and tooling (implying familiarity and competence with shop measurement tools and equipment), and the need to be able to read and understand engineering drawings. Those two abilities cover the inspection task being performed on this tooling in its entirety. You said that when an tool is found to be non conforming it is rejected, returned to the supplier, and an NCR is issued. That leads me to assume that some form of documentation exists for the inspection process, which I again assume includes an identifier for the person or persons who performed the inspection.

As an additional question, do these people need to be certified and/or registered as inspectors?
Probably not. They are inspecting the tooling not the final parts.

Now a separate question that could be an issue is the fact that tooling is being changed at all. If these are revised tools (and therefore constitute "tooling change" 8.5.1.3) then a FAI needs to performed to validate that the revision still produces a conforming part. A FAI does not need to be performed on the tool, because it is a tool and not your product.

Another separate question would be is the change in tooling being controlled per 8.5.6 which it sounds like it is, via drawing revision and presumably approval.

I think this is mostly a miscommunication issue. Management said something to indicate that the tooling is not important, when what they meant was the tooling is low risk. The tooling is obviously important, it's critical to what you do, but it is also usually correct, easily inspected, and should have several layers of redundant inspection after it that would catch non conforming product. An inspection process is in place for the tooling which is performed by qualified personnel.

I don't see anything here that could result in a nonconformity unless my assumptions were way off base. I hope that helps.
 
#3
Wow ! Are you here in the building somewhere? LOL You are spot on !! Thank you so very much for your detailed response. You are correct on every point. I will relax about this issue and see if I can help somewhere else.
Have a great day.
 
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