Rendering Product unusable... if it's owned by the Customer?

A

adirondackman

We've had a question come up regarding the clause that product dispositioned as scrap must be rendered unusable. We have a customer that we machine die castings for (not aerospace... automotive, actually). These castings are purchased by the customer and shipped to our location. If we find casting defects after machining, we scrap the parts and ship them to the customer or back to the customer's supplier for evaluation. We need customer permission to "render the parts unusable". What would an auditor think of a situation where the customer owns the castings and wants them back as we find them? I guess we can leave our mark or tag on them, but that's not a positive control... someone could remove them and use the parts. Has anyone run into this sort of situation and have a good solution? :thanks:
 
B

Boscoeee

We've had a question come up regarding the clause that product dispositioned as scrap must be rendered unusable. We have a customer that we machine die castings for (not aerospace... automotive, actually). These castings are purchased by the customer and shipped to our location. If we find casting defects after machining, we scrap the parts and ship them to the customer or back to the customer's supplier for evaluation. We need customer permission to "render the parts unusable". What would an auditor think of a situation where the customer owns the castings and wants them back as we find them? I guess we can leave our mark or tag on them, but that's not a positive control... someone could remove them and use the parts. Has anyone run into this sort of situation and have a good solution? :thanks:

Yes, you end up treating the material as customer property and send the material to the customer under their direction by the PO or Contract agreement.
 
B

Bob Bonville

I agree completel with Boscoeee, It is their property. Unless they give you permission to dispose of the property you must send it back to them.

Bob
 

Wes Bucey

Prophet of Profit
We've had a question come up regarding the clause that product dispositioned as scrap must be rendered unusable. We have a customer that we machine die castings for (not aerospace... automotive, actually). These castings are purchased by the customer and shipped to our location. If we find casting defects after machining, we scrap the parts and ship them to the customer or back to the customer's supplier for evaluation. We need customer permission to "render the parts unusable". What would an auditor think of a situation where the customer owns the castings and wants them back as we find them? I guess we can leave our mark or tag on them, but that's not a positive control... someone could remove them and use the parts. Has anyone run into this sort of situation and have a good solution? :thanks:
In the first place:
You've answered your own question ((not aerospace... automotive, actually)). The Standard relates to equipment associated with aircraft (It's a really big deal in FAA FIS!) (FIS = Fabrication Inspection System)

Secondly, the product is only "suspected" nonconforming (scrap), since you state the material is shipped back to your customer for "evaluation." The evaluation may be for root cause or to determine it is NOT scrap, after all. In any regard, since you are not the final arbiter [of whether it is scrap], you do not have the responsibility (or even the right) to render the material unusable even if it were for use on, or associated with, a aircraft.
 
A

adirondackman

Thanks everyone for your input. To clarify a bit, we actually are empowered to disposition these parts. Unless otherwise directed, we send them back to the (customer's) supplier and they get remelted. In that case, I don't think the customer is going to care if we render them unusable. Although they haven't given us a definitive answer yet. Regarding the fact that they aren't aerospace parts, we've been advised to have one procedure and follow it, regardless of the customer.
 
B

Bob the QE

I would like to add an additional need for information on this subject to adirondackman original post on this subject. This situation is one I am addressing as we are moving from ISO to AS. I have team members that feel we should look at two different procedures for rendering parts unusable. Their major point is that some parts we machine are quite large and very heavy and to move these to an operation that would render parts unusable would be timely and take time away from a production machine (milling, turning, grinding, etc..). I can't seem to put my arms around how we would meet the requirement without this type of process except to take the parts from the point of disposition at the time of disposition to the dumpster outside the palnt or would identifying these parts with paint of a specific color be acceptable?

I appreciate any help you may be able to provide.
 

Wes Bucey

Prophet of Profit
Thanks everyone for your input. To clarify a bit, we actually are empowered to disposition these parts. Unless otherwise directed, we send them back to the (customer's) supplier and they get remelted. In that case, I don't think the customer is going to care if we render them unusable. Although they haven't given us a definitive answer yet. Regarding the fact that they aren't aerospace parts, we've been advised to have one procedure and follow it, regardless of the customer.
As long as you have assurance (documented!) the material is remelted (affidavits might be acceptable), it does not matter whether you do the rendering unusable or outsource the process, the intent of the clause for aerospace and FAA is to assure the product cannot be salvaged from a scrap heap and made to APPEAR usable by ignorant or venal persons and then find is way onto an aircraft or be used to prepare an aircraft.

This brings us to:

I would like to add an additional need for information on this subject to adirondackman original post on this subject. This situation is one I am addressing as we are moving from ISO to AS. I have team members that feel we should look at two different procedures for rendering parts unusable. Their major point is that some parts we machine are quite large and very heavy and to move these to an operation that would render parts unusable would be timely and take time away from a production machine (milling, turning, grinding, etc..). I can't seem to put my arms around how we would meet the requirement without this type of process except to take the parts from the point of disposition at the time of disposition to the dumpster outside the palnt or would identifying these parts with paint of a specific color be acceptable?

I appreciate any help you may be able to provide.
Plainly, dumping as is or painting does NOT render the material unusable. I won't bore you with details, but the reason the clause exists is because "some" characters salvaged discrepant parts from a dumpster, cleaned them, and resold them as original equipment (ebay, anyone?) The parts failed in use!

The bottom line is the material must be rendered unusable for its original intent or purpose. Some organizations saw them into pieces, others smash them with sledge hammers, yet others burn or melt them.

In the case of large machined parts as described, the solution many use is simply to cut off a critical chunk with a cutting torch or to weld something into bores or shafts.
 
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A

adirondackman

Simply putting a bead of weld on a thread or critical fit -- or even gouging it sufficiently -- is all you need to make a part unusable.
 

Jim Wynne

Leader
Admin
As long as you have assurance (documented!) the material is remelted (affidavits might be acceptable), it does not matter whether you do the rendering unusable or outsource the process, the intent of the clause for aerospace and FAA is to assure the product cannot be salvaged from a scrap heap and made to APPEAR usable by ignorant or venal persons and then find is way onto an aircraft or be used to prepare an aircraft.

When you say "affidavits," do you mean sworn statements? What level of documentation is necessary?
 

Wes Bucey

Prophet of Profit
When you say "affidavits," do you mean sworn statements? What level of documentation is necessary?
Excellent question! Thanks for bring it up in this thread.

When I had to deal with the FAA on this matter, it was for some avionic circuit boards. The FAA official required us to have dated photos showing the destructed circuit boards with a list of the serial numbers. Each photo had to be signed by a person with authority to commit the organization and the photos had to be maintained in a file of "destructed material" for review at any time by FAA or its designee. The retention period for the photos in the file was seven years. Frankly, I don't remember the reasoning behind the seven year period (versus three, or five, or twenty.)

So, in effect, the signed photos were "sworn affidavits" by an authorized signatory of the organization, legally binding the organization, versus some John Doe who might not be available if or when the photos were needed as evidence.
 
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