IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unusable

[John C. Abnet]

Re: IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unus

Thanks for the additional information @woody.
Based on your OP, I infer that the auditor had no concern with how this "to be scrapped" product was identified/controlled within your facility., (which, I would argue is the highest priority). I infer that the auditor only had concern with the "render unusable" method you are using (i.e. send to outside recycle source).
If my understandings listed are correct, then it appears (sadly) that you have an auditor whom is unrealistic / less than pragmatic regarding this. I have heard horror stories about organizations actually sending associates "with" scrap trucks and visually verifying destruction/recycling of products. Neither safe nor wise. I would suggest a complaint to your registrar. Short of their support/cooperation, best of luck until the IATF team determines their error in verbiage and updates the SI.

 

[morteza]

Re: IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unus

Hi all,

In FAQ#11 published by IATF, there is a great question an I think a strange answer as follows:

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.

As you know, during PPAP process the final product is sent to customer for approval and the organization ships the final product to customer. For example an Actuator (an assembled product which is used for locking automotive doors) is sent to customer for approval. This product consists of several modules/components which covered by two plastic covers welded by ultra-sonic technology.
If the final product would not pass the required specification such minimum force test, the company rendered the product by breaking the plastic cover of the product.

My questions are:

1- Based on above answer, Is not necessary to rendered the interim non-conforming components such as nonconforming blades or connectors of an actuator? It may these components return to production line and escape from the organization and make problems to customer.

2- Does the scope of the requirements of clause 8.7.1.7 only are limited to final product (which is shipped to customer after part approval) not interim sub-assembly?

I believe that all components which can affect on final product specification should be rendered, for example a single gear in an automotive gearbox which can cause the gearbox has noise, should be rendered.

Thanks in advance for your explanations.

 

[Woody]

Re: IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unus

morteza,

It is what you PPAP to your Customer. We stamp body panels - some we apply primer through eCoat, some we don't.

If we scrap a part we PPAP with eCoat BEFORE the eCoat process, then we do not need to render it unusable. Crazy as that sounds - because I don't believe that meets the intent of the standard - those are the rules.

I heard the managing director of the IAOB speaking yesterday. This requirement is due to the auto makers finding product with their logos offered up for sale on eBay and similar sites. Therefore, we all must pay. The other point is that on page 8 of the standard are the email addresses for the oversight offices. Use them. IAOB is committed to reviewing all questions and recommendations - just be specific with the problem you are experiencing.

 

[Judy Hubbard]

Re: IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unus

Further thoughts are appreciated as well as solutions which are applied to high volume batch processes of Section 8.7.1.7: Nonconforming product disposition:

If the clause applies to disposition outside the manufacturing batch process, which our organization terms as MRB (Material Review Board), then meeting the clause seems reasonable. A reject is already dispositioned as part of the manufacturing process and thus not awaiting a disposition through a formal MRB process. For our organization, rendering rejects (start-up and troubleshooting) unusable from a batch process would be costly, as methods would need to be defined as well as additional equipment and labor added to the process flow.

If I read from an AIAG upload (pasted below), would a robust procedure defining manufacturing rejects as a separate process from which disposition as scrap are made through the formal MRB process meet the intent of the clause? We would also demonstrate we contain and do not pass rejects on within the manufacturing process.

Section 8.7.1.7: Nonconforming product disposition
• Strengthen the requirement of disposition of nonconforming product by clarifying that organizations must also have a documented process for disposition of nonconforming product not subject to rework or repair.
• Planned activities need to be managed and the results considered to improve this process.
• Contamination control practices should be applied to avoid any risk of unintended use of this type of nonconforming products.
• Customer approval is required before nonconforming products in this category can be diverted for service or any other use.

Thanks,
Carl

Need some guidance on when a Rework -Work Instruction is needed:
Rework

Example 1 – if a part makes it from operation 10 to the final operation 50 and the end of line tester finds that the heat failed and the part is given to the Team Leader and it is found that one of the wires was not seated in the connector, and then she pushes it back in and sends it back thru the end of line tester and it now passes, is that considered rework or repair? If yes, does there have to be a work instruction for this or how would you handle this?

We consider REWORK as a part that either has an appearance issue or a broken wire on the inside, then it goes to the rework area offline and it is broken down and bad parts are scrapped and good parts go back to the material bins at the line. We have this process.

 

[John Predmore]

Re: IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unus

How do companies address the following requirement?

"the organization shall verify that the product to be scrapped is rendered unusable prior to disposal."

How would you do this without cutting up / destroying the part?
Example would be bearing supplier. Would they be required to cut the raceways?
Example would be a shaft supplier. Would they be required to melt or cut the shafts prior to disposal?

Any suggestions other than buy a saw to cut the parts?

The bearing supplier could fill the raceway with epoxy (which might be easier than cutting the raceway). The shaft supplier might be able to bend the shaft, which would be easier than melting the shaft. If the shaft has a threaded end, the function of the shaft can be rendered unusable by simply ruining the thread (for example).

 

[Golfman25]

Re: IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unus

morteza,

I heard the managing director of the IAOB speaking yesterday. This requirement is due to the auto makers finding product with their logos offered up for sale on eBay and similar sites. Therefore, we all must pay. The other point is that on page 8 of the standard are the email addresses for the oversight offices. Use them. IAOB is committed to reviewing all questions and recommendations - just be specific with the problem you are experiencing.

No question this is the intent behind the requirement. The problem is they have taken it to is illogical conclusion. Making the washer guy destroy his washers before he scraps them is silly. It's not identifiable to it's end use.

 

[IvanHF]

Re: IATF 16949 Clause 8.7.1.7 Nonconforming Product Disposition - Scrap Rendered Unus

No question this is the intent behind the requirement. The problem is they have taken it to is illogical conclusion. Making the washer guy destroy his washers before he scraps them is silly. It's not identifiable to it's end use.

I know this is an old topic, but we are literally your example case here. We make washers and every setup, every material coil change, and every time we stop the press we clean out and scrap parts to avoid contamination reaching the customer. These parts are considered "process scrap" and documented but immediately scrapped by the operator, not handled through our standard nonconforming product process. When we have a nonconformance, which we define as more than 250 lbs of parts affected, we quarantine, create a nonconformance record, and disposition. This means the absolute minimum number of parts we would even consider a nonconformance is more than 10,000 pcs.

The idea of rendering unusable via any method other than certified destruction is laughable, and we can't even use the method of auditing our scrapper because it passes through other hands before it reaches a mill to be melted down. We will most likely have to pay to have bad parts destroyed by a company that offers certified destruction services and at this point I have no idea how much that would cost as we probably produce more than 1,000 lbs of "process scrap" a week not even factoring in actual nonconformances.

This requirement was annoying enough when we had to deal with it for machined aerospace components, but at least in that situation it makes sense. Applying it to washers serves no purpose and will constitute a substantial cost which we will probably have to find a way to pass on to our customers.

 

[AndyN]

In many cases, the nature of the non-conformity renders the item unusable... No action needed.

 

[Marc]

rendering unusable via any method other than certified destruction is laughable, and we can't even use the method of auditing our scrapper because it passes through other hands before it reaches a mill to be melted down.

Have you spoken to your registrar about this? This is one of those automotive "you have to be kidding!" issues. Then again I guess it could be a use case aspect. How is the washer used? Is a failure critical, and if so in what way? I bring this up because I have seen registrars back off on a few things where the requirement was obviously stupid.

A reply from a curernt IATF 16949 auditor here would be appreciated.

 

[Marc]

Making the washer guy destroy his washers before he scraps them is silly. It's not identifiable to it's end use.

Excellent point.