Not Design Responsible - Can we exclude all or parts of AS9100 clause 8.3

#1
Hello, I am transitioning to AS9100D.

I am trying to understand if I can exclude all or parts of the clause 8.3

We extrude shapes for the aerospace industry, but do not design finished product. All the parts we produce is near net shape and will be machined completely to the finished product.

We do on some occasions design the near net shape but they have to be approved by the customer.

With that being said, are we design responsible?

and if not can 8.3 be excluded completely?
 
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#2
Hello, I am transitioning to AS9100D.

I am trying to understand if I can exclude all or parts of the clause 8.3

We extrude shapes for the aerospace industry, but do not design finished product. All the parts we produce is near net shape and will be machined completely to the finished product.

We do on some occasions design the near net shape but they have to be approved by the customer.

With that being said, are we design responsible?

and if not can 8.3 be excluded completely?
Although you need customer approval, you still are responsible to control it. Customer approval would be addressed in 8.3.2g.
 

dsanabria

Quite Involved in Discussions
#3
Hello, I am transitioning to AS9100D.

I am trying to understand if I can exclude all or parts of the clause 8.3

We extrude shapes for the aerospace industry, but do not design finished product. All the parts we produce is near net shape and will be machined completely to the finished product.

We do on some occasions design the near net shape but they have to be approved by the customer.

With that being said, are we design responsible?

and if not can 8.3 be excluded completely?
Yes you can excluded make Clause 8.3 Not applicable if:

9100 requirements is for design and development of products
and services, not of processes.

and you make products to customers prints and requirements.

Please clarify your function on "occasions design the near net shape"

SO you provide technical assistance to the customer to enhance process?

if you design it - who is the holder of the print?
 
Last edited:
#4
Hello, I am transitioning to AS9100D.

I am trying to understand if I can exclude all or parts of the clause 8.3

We extrude shapes for the aerospace industry, but do not design finished product. All the parts we produce is near net shape and will be machined completely to the finished product.

We do on some occasions design the near net shape but they have to be approved by the customer.

With that being said, are we design responsible?

and if not can 8.3 be excluded completely?
It's not applicable to your scope.
 
#5
Sorry for the late response I had a customer audit this week.

I want to make sure everyone is getting the true picture and asked my engineering manager to describe our process more clearly. please read below.


Hello, I am transitioning to AS9100D. I am trying to understand if I can exclude all or parts of the clause 8.3.
We extrude shapes for the aerospace industry, but do not design the finished product. All parts that are extruded will have sufficient envelope of material around the finished product that will be machined to the finished product by our customer.
The material stock (or envelope) around the customer’s finished part is developed as a part of our process development. This excess material envelope may vary, as dictated by the customer’s requirement, the finished product geometry and our process limitations. As a part of continuous improvement, we are working with customers to try and reduce this material envelope around the finished product, so there is less waste and savings in terms of machining time and tooling for customer.
With that being said, are we design responsible?
And, if not, can 8.3 excluded partially?
 

dsanabria

Quite Involved in Discussions
#6
Sorry for the late response I had a customer audit this week.

I want to make sure everyone is getting the true picture and asked my engineering manager to describe our process more clearly. please read below.


Hello, I am transitioning to AS9100D. I am trying to understand if I can exclude all or parts of the clause 8.3.
We extrude shapes for the aerospace industry, but do not design the finished product. All parts that are extruded will have sufficient envelope of material around the finished product that will be machined to the finished product by our customer.
The material stock (or envelope) around the customer’s finished part is developed as a part of our process development. This excess material envelope may vary, as dictated by the customer’s requirement, the finished product geometry and our process limitations. As a part of continuous improvement, we are working with customers to try and reduce this material envelope around the finished product, so there is less waste and savings in terms of machining time and tooling for customer.
With that being said, are we design responsible?
And, if not, can 8.3 excluded partially?
Yes - based on the description above - you do not have design & development ownership. Your customer does - exclude 8.3
 
#7
Auditor last year for AS9100C stated we need to develop a Plan to implement the clause after a few hours of conversation

How would I explain to the auditor it is not necessary.
 
#8
Auditor last year for AS9100C stated we need to develop a Plan to implement the clause after a few hours of conversation

How would I explain to the auditor it is not necessary.
I hope you weren't paying for those hours of discussion! So, the simple answer is: You don't! Defining the scope etc is part of your application and on-going contract with your CB. It's NOT for the auditor to determine. Yes, they verify it's applicable/non-applicable (you can't make claims of scope if they're bogus) but your auditor should not be dictating things like this to you.
 
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