Interpretation of AS9100 wording

[QCBOB]

Good morning,

I am having a back and forth with others in management about the interpretation of a section of the AS9100D standard.

Our customer has in their terms and conditions call out AS9100D 8.4.3 K, which states "

The organization shall communicate to external providers its requirements for: ...
k. the need to:

- implement a quality management system;

- use customer-designated or approved external providers, including process sources (e.g., special processes);

- notify the organization of nonconforming processes, products, or services and obtain approval for their disposition;

- prevent the use of counterfeit parts (see 8.1.4);

- notify the organization of changes to processes, products, or services, including changes of their external providers or location of manufacture, and obtain the organization’s approval;

- flow down to external providers applicable requirements including customer requirements; - provide test specimens for design approval, inspection/verification, investigation, or auditing; - retain documented information, including retention periods and disposition requirements;"

The back and forth is based on the section I highlighted in red. Production/top management wants to change the machine that this is manufactured on (the original machine and requested new machine are not identical and are two different machines but perform a similar function) a and I interpret this section of the standard that we need to notify our customer of this change and obtain their approval. but production/top management is saying that we do not need to notify them./ Can someone please weigh in on their thoughts?

My hesitation is based on how things will look if there is an escape or there is an issue and they ask if anything has changed to the process. These questions do not land on their desk, it lands on mine.

 

[Bev D]

This is an age old issue. Suppliers simply don't want to do it because they feel that is takes away their autonomy. But the interpretation is clear, unambiguous and straightforward: you must report changes to processes…a different machine that behaves differently must be validated (at least a first article) reported and approved. Period. Full stop.
As a customer who has been victimized by the lack of reporting from suppliers I can tell you this clause is probably one of the most important clauses in any supplier agreement. Especially in aerospace and defense. As a supplier I’ve had the guys in uniforms and chest bling visit and shut us down for a ‘quality stand down’. This is not negotiable.

 

[Mike S.]

You have the exact customer requirement in front of you. If it says you shall do "X" and someone else higher-up than you says "we're not going to do "X" and that's final" I suggest you clearly document this in an email, BCC yourself in your personal email (to CYA), and tell the higher-up that they can sign off the C of C or whatever, but you and none of your subordinates are going to do so.

This will either cause them to back down or give you protection when the poop hits the oscillator.

 

[Bev D]

What Mike S said. This is the contract. There is no room for alternative interpretations. If your management didn’t want to do this they shouldn’t have taken the business.

Just to paint the picture for you: one of the organizations I worked for (and there were several in the aerospace realm) was suspected of having produced a part that was suspected of causing several inflight shutdowns that resulted in grounding Marine One. We were investigated (“audited”). One of the first things they looked at was our change control/first article process and records as well as our SPC and final inspection process (sample size, calibration, data records…). Fortunately I was able to conclusively prove that we were not responsible nor was our part. However, the investigation was like having a colonoscopy without the prep or the anesthesia and instead of that little camera doohicky they used an extra large roto rooter tool.

 

[Golfman25]

Good morning,

I am having a back and forth with others in management about the interpretation of a section of the AS9100D standard.

Our customer has in their terms and conditions call out AS9100D 8.4.3 K, which states "

The organization shall communicate to external providers its requirements for: ...
k. the need to:

- implement a quality management system;

- use customer-designated or approved external providers, including process sources (e.g., special processes);

- notify the organization of nonconforming processes, products, or services and obtain approval for their disposition;

- prevent the use of counterfeit parts (see 8.1.4);

- notify the organization of changes to processes, products, or services, including changes of their external providers or location of manufacture, and obtain the organization’s approval;

- flow down to external providers applicable requirements including customer requirements; - provide test specimens for design approval, inspection/verification, investigation, or auditing; - retain documented information, including retention periods and disposition requirements;"

The back and forth is based on the section I highlighted in red. Production/top management wants to change the machine that this is manufactured on (the original machine and requested new machine are not identical and are two different machines but perform a similar function) a and I interpret this section of the standard that we need to notify our customer of this change and obtain their approval. but production/top management is saying that we do not need to notify them./ Can someone please weigh in on their thoughts?

My hesitation is based on how things will look if there is an escape or there is an issue and they ask if anything has changed to the process. These questions do not land on their desk, it lands on mine.

As others have said, change in process includes change in equipment. Depending on your process, that may or may not be realistic -- I guess it's how far you take it, such as down to replacement of perishable tooling. Only you can determine the risks involved.

I would default to notification, but that could go into the great abyss. Automotive has a similar requirement. I notified a customer that we where upgrading a lathe that faced a single dimension on a single part. We also needed an answer right away as the old lathe was dead and the new lathe was ready to go. Something like two years later I got a "rejection" of our change request. I sure hope aerospace is better than that.

 

[Mike S.]

It's all fun and games until the investigation/audit starts.

 

[Big Jim]

If it is part of your customer's terms and conditions, you have no alternative but to adhere. Well, actually, you do have an alternative, and that is to not accept the contract.

If it is not included in their terms and conditions but they think you are obligated, tell them to read the second line in 8.4.3 again. Then ask them for a definition of "its".

 

[Bev D]

Our customer has in their terms and conditions call out AS9100D 8.4.3 K, which states "

Literally the third line in the OP’s post…

 

[Sidney Vianna]

Good morning,
I am having a back and forth with others in management about the interpretation of a section of the AS9100D standard.
Our customer has in their terms and conditions call out AS9100D 8.4.3 K, which states "

SNIP

- notify the organization of changes to processes, products, or services, including changes of their external providers or location of manufacture, and obtain the organization’s approval;

SNIP

The back and forth is based on the section I highlighted in red. Production/top management wants to change the machine that this is manufactured on (the original machine and requested new machine are not identical and are two different machines but perform a similar function) a and I interpret this section of the standard that we need to notify our customer of this change and obtain their approval. but production/top management is saying that we do not need to notify them./ Can someone please weigh in on their thoughts?

My hesitation is based on how things will look if there is an escape or there is an issue and they ask if anything has changed to the process. These questions do not land on their desk, it lands on mine.

A point of clarification. 8.4.3 in AS9100 relates to requirements you have to flow down to your supply chain, as applicable.

The scenario you provided for feedback, interpreted through the 9100 prism as it applies to you falls under 8.5.1.3., especially the bit that reads: "...The organization shall use a representative item from the first production run of a new part or assembly to verify that the production processes, production documentation, and tooling are able to produce parts and assemblies that meet requirements. This activity shall be repeated when changes occur that invalidate the original results (e.g., engineering changes, production process changes, tooling changes..."

So, I agree that the best policy is to notify the customer, followed by a (partial?) FAI as it relates to the manufacturing steps being performed in the new equipment.

Good luck.

 

[Jen Kirley]

Many thanks to Sidney for a clear and concise explanation.

SQE here, though not for aerospace. Still, consider the customer please. Changing the process, as in substituting material, hardware, moving operations to a new site or how something is made (for example, 3D printing versus plastic injection molding) is extremely important to us OEMs. So much so that we write it into our Quality Requirements and issue SCARs if we find out such a change was made without notifying us. Check your customer requirements, I expect you will find language about this in there in addition to the standard.