Material Dispositioned for Scrap Positively Controlled - AS9100 Clause 8.3

Big Jim

Relative to AS9100 requirements, let's say you have product dispositiond as scrap, but all accounting paperwork/documentation is not completed, so it is locked in your MRB room. Is that positive control? If it is there for up to 6 months is it a problem?

Assuming that your MRB room is truly secure that would be appropriate positive control.


This still doesn't fly. Red paint is not permanent. It can be helpful but certainly isn't adequate. This IS serious stuff.
Per the clarifications table:

Please explain what conspicuously and permanently marked includes.

The scrap product shall be marked to be clearly visible that it is scrap material. The marking shall be permanent given the product storage environment (e.g. parts stored outside, subject to rain and sunshine, should be marked with water resistant, non-fade markings) such that it will not be rubbed off inadvertently or become removed during handling. Remember that this is a temporary step in the process until the part is rendered unusable. The intent of this requirement is to differentiate scrap parts from good parts to avoid parts being used unintentionally.

All scrap has to be physically rendered unusable. If red paint is their way of doing that then I'd agree it's not adequate. If they're using it to identify the parts dispositioned as scrapped (but not yet physically rendered unusable) then that's fine.

YES. This isn't adequate.

Per the clarifications table:

Our organization makes parts from foam, plastics and fiberglass and as such it is impossible to permanently mark the scrap (scrap is normally the excess material from die cutting, water jet cutting or routing). We had special bins made that had “Scrap/Trash” on the sides. These bins are emptied into a trash compactor as they fill up. Is putting this type material in a marked bin adequate or does each piece require marking?

It is important to remember that clause 8.7 is for product that does not conform to product requirements. Therefore, if the materials are conforming and there is material excess from die cutting, water jet cutting or routing operations (or other splitting operations for distributors); your excess material does not fall within the scope of scrap control in this clause

I'm not even sure how you could consider excess material as nonconforming product.

For the situation in the first post, I'd say it seems like a nonconformity but it needs further investigation. While their process for controlling nonconforming outputs seems adequate for the parts in question, there's a potential gap with parts that are not serialized. But there is no requirement that you have to include what positive control is in your procedure. You would have to interview additional personnel to see what the process is and how the non-serialized parts would be positively controlled.
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