IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition Compliance

[howste]

But that sounds like an assembly type of operation. If I am sending him the components, he just pulls them out of the box -- and they are all good. I have already scrapped the bad ones at my location.

Unless somebody pulled them out of the scrap bin and packaged them to ship. Yes, I've seen it happen.

This clause/requirement is ripe for a risk based analysis and some common sense imo.

I agree. But many companies don't realize the risk of internal personnel shooting the company in the foot with nonconforming product like this to meet production numbers. There has to be a reason that the writers of the standard added this requirement for ALL scrap product in the supply chain. They left no wiggle room in the words they used.

IMO when the IATF writers copied this requirement from AS9100 they should have included the whole thing: "Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled, until physically rendered unusable." There is likely more risk of insiders skirting the system than outsiders for some types of product. Maybe the IATF will add this to the standard later come up with a sanctioned interpretation.

BTW, product in IATF 16949 is "any intended output resulting from the product realization process." Choosing to call products "components" doesn't change the meaning of the requirement in the standard. Had an IATF witness auditor been there during Scanton's audit I sincerely doubt that they would have got the interpretation that they did from the auditor.

 

[Golfman25]

Unless somebody pulled them out of the scrap bin and packaged them to ship. Yes, I've seen it happen.


I agree. But many companies don't realize the risk of internal personnel shooting the company in the foot with nonconforming product like this to meet production numbers. There has to be a reason that the writers of the standard added this requirement for ALL scrap product in the supply chain. They left no wiggle room in the words they used.

IMO when the IATF writers copied this requirement from AS9100 they should have included the whole thing: "Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled, until physically rendered unusable." There is likely more risk of insiders skirting the system than outsiders for some types of product. Maybe the IATF will add this to the standard later come up with a sanctioned interpretation.

BTW, product in IATF 16949 is "any intended output resulting from the product realization process." Choosing to call products "components" doesn't change the meaning of the requirement in the standard. Had an IATF witness auditor been there during Scanton's audit I sincerely doubt that they would have got the interpretation that they did from the auditor.

Ok. So what does "unusable" mean? If the product is physically out of spec., is it unusable? I know my customer is sending it back to me.

 

[howste]

Ok. So what does "unusable" mean? If the product is physically out of spec., is it unusable? I know my customer is sending it back to me.

In the aerospace world it means visibly obvious that it's not usable. We'll have to wait and see what the IATF's stance will be (probably after they get a flood of requests for clarification).

 

[Marc]

In the aerospace world it means visibly obvious that it's not usable. <snip>

I can't speak to current requirements, but in my days in aerospace it also had to be physically deformed in a way which makes it impossible to use. Paint and/or a tag was not sufficient.

 

[howste]

I can't speak to current requirements, but in my days in aerospace it also had to be physically deformed in a way which makes it impossible to use. Paint and/or a tag was not sufficient.

True. Upthread I've posted the IAQG's latest guidance.

 

[Big Jim]

Thank you all for commenting on this thread, you replies are always enlightening. My working life in quality management has been heavily punctuated with knowledgeable people from the quality community, always willing to share what they know like no other working sector I have ever come into contact with, and for that I will always be grateful.

Today however I have learned that on this forum, if you believe someone completely misrepresents what you are saying and then criticises the results, don’t point that out, just let it pass and say nothing, because doing so will ensure you are accused of taking things personally, that you lack maturity and have a closed mind, even if you agree with what is being said about the misinterpretation.

I would also like to say a big thank you to Big Jim for being so articulate and patient with me, I now completely understand where you are coming from and can see that from your viewpoint that what I propose probably looks unnecessarily risky, and therefore unjustifiable. Unfortunately due to confidentiality I cannot fill you in on technical details, however please let me assure you that the chances of one of our nonconforming components finding its way onto a car is infinitesimally small.

We spent around six months looking at every method we could think of to meet this requirement however due to the small size of the components and the hardness of some of the materials everything we came up with was either way too resource hungry or came with health and safety concerns that couldn’t be justified. We also have the problem of material segregation and not being able to contaminate one waste material stream with another, so whatever we did we would have had to have done multiple times.

Just for your information, this justification has already been successfully made during our transition audit.

The next bit is definitely not aimed at Big Jim: Petty insults are definitely not my thing, I don’t use them and can’t see any real justification for them here. I was just trying to be understood, when I believed I wasn’t. That’s it, plain and simple. If you want to question my integrity, maturity, experience and/or closed mind then there are plenty of other forums where that is common place, this should not be one of them.

Thank you.

 

[Sebastian]

We make components that we send to our customer, who then welds/brazes them onto a sub assembly which they send to their customer who attaches them to their sub assembly who sends them to their customer who attaches them to an engine.

I have deemed what we produce as a component and not a product. It may seem like semantics, but you cannot take one of our "components" and use it in your car, as it is not a product like a switch or a spark plug.

Application of this requirement, same as whole IATF 16949 is not limited to Tier-1 suppliers only. Therefore your "components" are also "products" and you shall address this requirement in your system.

QUESTION 4:
Does nonconforming product disposition apply only to final product or does it also apply to component/interim sub-assembly?
ANSWER 4:
This requirement applies to the product that has gone through the part approval process and that the organization is shipping to the customer.

All you can get here.

 

[Golfman25]

All you can get here.

Ok, but there's more.

Start with intent (question 1): to ensure the product cannot find its way into the unofficial aftermarket, onto a road vehicle, or accidently shipped to the customer.

Then, move to question 3 which allows an organization to use a service provider to render the product unusable so long as they approve, and periodically verify, how the supplier is rendering the product unusable.

This would seem to allow component suppliers to "scrap" their bad parts and send them to the metal recycler who will then crush and bundle them for eventual melting and reuse as new material. Does not appear to require destruction on-site prior to throwing in the scrap bin.

 

[LUV-d-4UM]

A similar question here: IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unusable

Since this requirement was clearly "borrowed" directly from AS9100 it's possible that the IAQG's interpretation should be considered. Keep in mind that they are thinking about aerospace and defense applications, so they are trying to keep people from fishing nonconforming parts out of the recycle bin to put into an aircraft or a defense application. When looking at it from an automotive perspective it may be a little overkill, but it may not be if the product has special characteristics that are safety-related - YMMV.

In case of a fluid, it is rendered unusable by putting it as slop oil.