Is Configuration Management Mandatory? AS9100 Clause 7.1.3

S

speck

#1
I posted this question yesterday but it seems to have vanished into the abyss somewhere. Not sure what I did wrong posting. :confused: We are a design exempt commercial heat-treater and the question I have is, is mandatory configuration management required? I searched for the better part of the day yesterday on the cove (incidentally I learned way more than I was planning to and it turned into a very educational surfing morning – thanks to all) and could not find a topic covering it. Only about 1% of work done here is aerospace quality work, and none require a FAI as we are 3rd, 4th or 5th tier and things are pretty watered down by the time it gets to us. I always get as much information as I can from our customer but sometimes they have no clue where the parts end up. Our “Configuration packet” consists of every piece of paper that was used to make the part from contract review to invoicing. Our requirements are usually surface hardness, effective case depth and core hardness only. We develop a process document it on the shop router and steps are bought off by employees in order. We do not purchase anything for the parts except instrument grade gasses used for carburizing, which is handled appropriately, and rust preventative spray for shipping which have COC of each batch. Many times we run a lot and never see the part number again. We have a configuration and FAI procedure but don’t really use it. 7.1.3 of AS9100 C says The organization must implement and maintain a configuration management process that includes, AS APPROPRIATE to the product…. I have always maintained that as we do not have FAI or other req’s our “Appropriate” CM is a control plan outlining every aspect or step involved in the product realization that allows at any time to determine the configuration of the product. A distilled version of my question is, Do I need a separate configuration file folder in my office for every aerospace part we do if there is no requirement for FAI and we have, or may only run the parts 1 or 2 times? Relatively speaking our process is so simple as it applies to the standard. We take the customers parts, heat treat them and ship them back to them. The last thing I want to do is complicate things for us. We have survived 4 years of AS9100 audits and 2 years of NADCAP audits without a scratch. Have all the auditors given me enough rope to hang myself? The more I read about CM here, the more it sounds like everyone just has CM files for every part regardless of circumstances. Again sorry if my first post on this is lost somewhere in the other parts of the cove and thanks a ton for helping me out over the years.
 
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B

Boscoeee

#2
I posted this question yesterday but it seems to have vanished into the abyss somewhere. Not sure what I did wrong posting. :confused: We are a design exempt commercial heat-treater and the question I have is, is mandatory configuration management required? I searched for the better part of the day yesterday on the cove (incidentally I learned way more than I was planning to and it turned into a very educational surfing morning – thanks to all) and could not find a topic covering it. Only about 1% of work done here is aerospace quality work, and none require a FAI as we are 3rd, 4th or 5th tier and things are pretty watered down by the time it gets to us. I always get as much information as I can from our customer but sometimes they have no clue where the parts end up. Our “Configuration packet” consists of every piece of paper that was used to make the part from contract review to invoicing. Our requirements are usually surface hardness, effective case depth and core hardness only. We develop a process document it on the shop router and steps are bought off by employees in order. We do not purchase anything for the parts except instrument grade gasses used for carburizing, which is handled appropriately, and rust preventative spray for shipping which have COC of each batch. Many times we run a lot and never see the part number again. We have a configuration and FAI procedure but don’t really use it. 7.1.3 of AS9100 C says The organization must implement and maintain a configuration management process that includes, AS APPROPRIATE to the product…. I have always maintained that as we do not have FAI or other req’s our “Appropriate” CM is a control plan outlining every aspect or step involved in the product realization that allows at any time to determine the configuration of the product. A distilled version of my question is, Do I need a separate configuration file folder in my office for every aerospace part we do if there is no requirement for FAI and we have, or may only run the parts 1 or 2 times? Relatively speaking our process is so simple as it applies to the standard. We take the customers parts, heat treat them and ship them back to them. The last thing I want to do is complicate things for us. We have survived 4 years of AS9100 audits and 2 years of NADCAP audits without a scratch. Have all the auditors given me enough rope to hang myself? The more I read about CM here, the more it sounds like everyone just has CM files for every part regardless of circumstances. Again sorry if my first post on this is lost somewhere in the other parts of the cove and thanks a ton for helping me out over the years.
Try not to over think this. The question is how do you control the configuration of the product that you heat treat. The fact is you do not, it is controlled by your customers. However, you still have to show that you have configuration management of the drawings and specifications that are used to ensure compliance.

I am in a machine shop with no design authority, our configuration management process is simple and direct, we handle the customers documents and specifications and call it a day.:2cents:
 
S

speck

#3
Thanks Boscoeee - So you don't have configuration management at all, you have document control over customers drawings, specs etc. Is this common among companies that are design exempt? :confused:It seams to me that instead of product configuration management, we have process configuration management and still need some sort of configuration management plan IF and when required by our customers to at least distinguish between the finished configuration and in-process configuration. As usual I am probably over thinking things.:frust: I just don't like gray areas. They result in findings sooner or later.
 
J
#4
I have a good news for you:).Configuration management is now moved and it is under section 7 in AS9100 Rev.C.So exclusion is possible.Sure,you know the conditions of exclusions,if not it is here for easy reference
Where exclusions are made,claims of conformity to this international standard are not acceptable unless these exclusions are limited to requirements within clause 7, and such xclusions do not affect the organisations's ability, or responsibility, to provide product that meets customer and applicale statutory and regulatory requirements
.

If yoy are with AS9100 Rev.B, and not planning for a transition soon,you have to live with it for some more time and the best way to do it may be what our friend suggested already.
 
#5
Since configuration management has expanded requirements with AS9100C, I'm sure that we are going to see more questions similar to this.

In my mind, one of the more significant comments about configuration management is not contained in 7.1.3 which is titled "configuration management", it is found in 7.5.3 "identification and traceability". "The organization shall maintain the identification of the configuration of the product in order to identify any difference between the actual configuration and the agreed configuration."

Isn't that what you do? Isn't that why you confirm that you are working to the specifications that the customer requires?

If you think of configuration management as "revision level control", you will probably find that you either already do everything in 7.1.3, or that it would be easy to do so.

a) planning -- do you not plan a job as part of the development of a traveler? Does not the router show the revision level of the specs you are following (drawing revision level, ANSI spec revision level, or the like).

b) identification -- does not the traveler provide configuration identification (revision level identification) during production?

c) change control -- stopping work when the customer changes the revision level during production until the changes can be reconciled and controlled.

d) status accounting -- does not the accumulation of records (completion of a stage, the sign off of a test or inspection, and production control records [oven charts and the like]), demonstrate that the configuration process is efficient?

e) audit -- does not the review of the production paperwork at the end of production provide an audit of the configuration management for that project? Do you not check such things as confirming that all production steps were completed, all certifications have correct process revisions, and all documents supporting its configuration are present.

If you do all those things, you are likely to be meeting the requirements of 7.1.3, configuration management.
 
S

speck

#6
Thanks Big Jim. I wish the standard was written by people like you so people like me could understand it.:):thanx:
 
S

sfalciani

#8
So, in being that you are a build to print machine shop you don't need a procedure to go along with this section of the quality manual? I, like the other individual am probably over thinking this issue. I am coming down from a big organization, which had no exemptions to a mom-n-pop organization that is exempt from designing and I am puzzled:confused: So should I put the following statement in section 7.1.3:

"Configuration Management has not been nor is anticipated to be a specified requirement for any contract. If COnfiguration Management becomes a specified requirement, documented procedures for performing, verifying and reporting that the configuration management meets the specified requirements will be established and maintained as required by AS9100, customer specifications and regulatory requirements."

Help me please?:bonk:
 
#9
So, in being that you are a build to print machine shop you don't need a procedure to go along with this section of the quality manual? I, like the other individual am probably over thinking this issue. I am coming down from a big organization, which had no exemptions to a mom-n-pop organization that is exempt from designing and I am puzzled:confused: So should I put the following statement in section 7.1.3:

"Configuration Management has not been nor is anticipated to be a specified requirement for any contract. If COnfiguration Management becomes a specified requirement, documented procedures for performing, verifying and reporting that the configuration management meets the specified requirements will be established and maintained as required by AS9100, customer specifications and regulatory requirements."

Help me please?:bonk:
I would not make such a statement. There is no need for it. That statement includes some traps that could cause problems. In particular, you undoubtedly do some configuration management, particularly in the realm of traceability as I commented on four posts above this one.

Also, there is no requirement for a documented procedure for configuration management, so there is no need to explain why you don't have one.

If you do choose to have a written procedure, use what I posted four post above this one as a guide. Read that post again.

When the configuration management question comes up, you simply explain how you handle traceability of the drawings against the traveler to show that the required revision level (configuration) matches the actual revision level (configuration) of the final product.
 
J

Jeff Frost

#10
Big Jim you have hit the mark on this one. I have already had a conversation about this with a CRB and 2nd party auditor who both believed that a specific documented procedure was required. In both cases I had the auditor review the requirement and then lead them through our Clause 7.5.3 process
 
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