Need help understanding AS6174 clause 3.1.5.

Tyler

Involved In Discussions
#1
I am working on implementing AS6174 at my company. I came across the following clause which has me quite confused:

"3.1.5 - In Process Investigation
The documented processes shall address the detection, verification, and control of any in-process (post acceptance) and in-service suspect counterfeit material."


The reason this has me confused is because it seems to mandating that your processes have provisions in place for detecting counterfeit materials that have already passed inspection. If so, that is an unreasonable requirement. The whole point of inspection is to detect bad product (including counterfeit products). In theory, the inspection process should not allow bad products through. In reality, we know mistakes happen, but it is unreasonable to setup a second inspection just to "detect" counterfeit materials that erroneously passed inspection. Talk about waste. Furthermore, who is to say a mistake wouldn't be made in the second inspection? Should I then have a third? :rolleyes:

Given the absurdity of my first interpretation, I am led to believe that this clause does not mean what it appears to say. I think this clause is more about a company's process for the control of nonconforming products. If I am right, then what the writers of the standard are really trying to say is this: any time counterfeit materials are detected after inspection, regardless of how they are detected (e.g., by a worker on the line, a customer notification of escapement, industry alert, etc.), then the suspect counterfeit products need to be controlled and reviewed and any necessary activities for containment and correction must be performed.

If my interpretation is correct then this is just standard control of nonconforming products stuff.

Thoughts?
 
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Steve Prevette

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#2
There have been plenty of horror stories out there of counterfeit parts making their way into ready-use supply bins and then into service. I suppose the requirements you are questioning represent defense in depth. One famous case resulted in the the death of a number of sailors. Anatomy of a Catastrophic Boiler Accident (nationalboard.org) as one of many links to the saga. Consider that most receipt inspections are random, and for some high risk application a 100% at point-of-use is appropriate. Quoting from the link

Today, working for an insurance company and inspecting mostly low-pressure heating boilers, I still see the potential for many serious accidents. It's easy to think that this can never happen to you, but all of those involved in the catastrophic accident on board the USS Iwo Jima were professionals, and it happened to them.
 

Mike S.

Happy to be Alive
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#3
Tyler,

I think your 2nd interpretation is correct.

Example: you have accepted some IC's and they are in your stockroom. You later learn via GIDEP it is possibly counterfeit material. Do your processes cover what to do?
 

AEOS_QA

Involved In Discussions
#4
I also think it would be the 2nd interpretation. i.e us as a Maintenance organisation receive a warranty claim and find suspect parts. We would advise you and your process kicks in. Could also be via EASA / FAA defect reports concerning your equipment
 
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