Rendering Scrap Unusable before Disposal (AS9100D, Section 8.7)

[WCHorn]

Reference: AS9100D, Section 8.7

The referenced section stipulates that "Product dispositioned for scrap shall be conspicuously and permanently marked, or positively controlled, until physically rendered unusable." I see that a similar statement occurs in ITAF 16949, Section 8.7.1.7 (which was not in ISO/TS 16949:2009).

We make product for aerospace, automotive and a host of other commodities. We render product unusable, regardless of commodity, and it's a bit burdensome.

Is it permissible for an organization to render unusable only the aerospace and automotive product, and just scrap other product, as long as the aerospace and automotive product is controlled prior to rendering it unusable?

 

[Sidney Vianna]

Is it permissible for an organization to render unusable only the aerospace and automotive product, and just scrap other product, as long as the aerospace and automotive product is controlled prior to rendering it unusable?

Yes, in my estimation. Augmented requirements (above and beyond 9001:2015) are expected to be complied with, within the scope of the system, as you lined up, provided the scope of certification does not misrepresent that the AS9100 certification also includes "commercial" products. If your AS9100 certificate scope includes commercial products, in addition to the aerospace ones, then AS9100 should apply also to the commercial products.

The other day I saw an AS9100:2016 certificate that included aerospace, commercial and medical products. That's the recipe for a disaster in my experience. On the other hand, many auditors don't pay attention to the scope of certification and it's implication onto the scope of an audit.

 

[normzone]

Wow, that's a wild one, [Sidney].

Related war story, outfit I worked with way back in the previous century that made early generation digital cameras had some circuit boards that periodically failed test. I acquired some via nonconforming material process, marked them with the NMR number, and when it was time to scrap them put them in the dumpster while employees were on break.

The employees knew these boards could be difficult to get, so they fished them out of the dumpster, saved them until there was a component shortage and put them into products in build.

They failed test, of course, and came back to me on NMR again. I looked at them, saw the old NMR numbers and went WTF? When I learned the tale, next time I scrapped them I did it while the employees were out there on break where they could witness this, but hit them with a hammer first.

So you may want to consider rendering ALL components unfit for use. Some of that stuff may feed the counterfeit food chain as well. I have a peer who saw an aerospace aircraft part he was familiar with being used as a truck bumper in his town.

 

[howste]

Yes, in my estimation. Augmented requirements (above and beyond 9001:2015) are expected to be complied with, within the scope of the system, as you lined up, provided the scope of certification does not misrepresent that the AS9100 certification also includes "commercial" products. If your AS9100 certificate scope includes commercial products, in addition to the aerospace ones, then AS9100 should apply also to the commercial products.

I agree that the certification scope is key to what needs to be rendered unusable. Let's look at some actual AS9100 scopes taken from the OASIS database. Do you agree with my interpretations here?

The Manufacture and Distribution of Custom Molded Rubber Products, Seals, Gaskets and Packings for Aerospace and Commercial Industries
Clearly with this scope, they would have to render scrap unusable from all of the commercial products in addition to the aerospace ones.

Manufacture, testing and inspection of precision molded elastometric products for the aerospace, oil exploration, medical, and commercial industries.
It looks like pretty much all of their scrap would need to be rendered unusable unless they also provide product for the pet chew toy industry. :mg:

The manufacture of machined plastics for the Aerospace Industry; and the distribution and sales of industrial plastics and laminates
For this one, only manufactured aerospace parts and commercial purchased parts for distribution would need to be rendered unusable.

The Manufacture and Distribution of Rubber O-Rings and Custom-Shaped Seals, including Rubber-to-Metal Bonded Seals
This one doesn't specify aerospace or commercial. My interpretation is that since the industry is not specified that all scrap rubber products would need to be rendered unusable regardless of what industry it is for.

 

[howste]

I have a peer who saw an aerospace aircraft part he was familiar with being used as a truck bumper in his town.

How did he know it wasn't an automotive aircraft part?

 

[Michael_M]

For our scrap, we just keep all 'scrap' in a locked bin by material type (machine shop). Our recycler has given us a letter of verification that any material (including parts) are melted down.

 

[howste]

For our scrap, we just keep all 'scrap' in a locked bin by material type (machine shop). Our recycler has given us a letter of verification that any material (including parts) are melted down.

Devil's advocate asks: Do you have positive control until they melt it down? How does your company know that the other company didn't take some parts out before they melted the rest?