Traceability on Unmarked Parts - AS9100 requirements

[Ralba]

Hello all,

I work in an SMT PCB manufacturing CM, and I am new to AS9100 as a standard. I am being told by a few fellows that the traceability requirements of AS9100 are that for any board we have ever made, we must be able to show exactly what purchase order and shipment from our supply the parts came from. As such, we need to mark our boards with a serialization in order to find when it was made after it has been released. We have some concern that a few of our customers may have a complaint with us marking the board in any way, even to serialize it. Is there a best practice for this?

Also, some is it required to show where the parts came from all the way to the original manufacturer? Do we personally need to have the information on where our supplier obtained it from, and therefore must communicate with the supplier to find that information through a Certificate of Conformance or something of the sort?

Thank you all

 

[Ron Rompen]

Just a couple of comments on this.
First: Check what the requirements are - just because 'a few fellows' think something is a requirement doesn't always mean that it is. The standards are pretty straightforward with the SHALL statements.

Second: As for customer concerns, the best idea is to communicate with them. If this is a requirement, then it will also be in their best interests to have the correct traceability information available. Between yourself and your customer, you can agree on a location and method. My personal choice is a 2D matrix - you can put a LOT of information into a (relatively) small space.

 

[Ralba]

Well that's that is just it. In both the counter fit section of 8.1.4, it is referenced in the notes with "should consider":
"requirements for assuring traceability of parts and components to their original or authorized
manufacturers;"


traceability section of 8.5.2, it says it "can include":
"the ability to trace all products manufactured from the same batch of raw material, or from the same
manufacturing batch, to the destination (e.g., delivery, scrap);"

Neither of these are strict requirements with a "shall", but I am worried that it would be difficult to show it as sufficient to an auditor without such the ability to trace it all the way back to manufacturer.

 

[NickV....]

Well some of that may actually be true. My place of employment (small manufacturing shop) is AS9100 certified and we are required to trace material from the time it comes in the door to the time it arrives at the customers door. This is done by part serialization with customer supplied codes or serial numbers that have to be applied using various methods (laser etching, stamping or scribing). So that being said yes you are required to trace all products throughout the manufacturing process with part marking and any applicable MTR's or special processing certs that are applicable to that job. From my experience this is a critical area of attention by auditors as well, CFSI is major item of interest so you're best to tackle it with all parties in mind. Hope this helps some.

 

[Sidney Vianna]

Neither of these are strict requirements with a "shall",

Are these boards installed in commercial aircraft? If so, FAA regulations apply.

Title 14 → Chapter I → Subchapter C → Part 45

(c) Critical parts. Each person who manufactures a part for which a replacement time, inspection interval, or related procedure is specified in the Airworthiness Limitations section of a manufacturer's maintenance manual or Instructions for Continued Airworthiness must permanently and legibly mark that part with a serial number (or equivalent) unique to that part in addition to the other applicable requirements of this section.

Remember that compliance with (product) Legal requirements is mandated by the Standard. Federal Aviation Administration (FAA) Code of Federal Regulations (CFR) 14 - Part 21 is applicable to products in commercial aviation.

We don't know if your products end up in commercial aircraft or not, but since you are giving us AS9100 as part of the context, be aware.

 

[Ralba]

We don't know if your products end up in commercial aircraft or not, but since you are giving us AS9100 as part of the context, be aware.

Thank you for the heads up. We may take on FAA regulated customers in the future, but the current customer asking us to become AS9100/AS5553 is not planning to use the parts for airplanes, to our knowledge. They have mentioned they might give us other work that would require us to obtain some NADCAP compliances depending on how things go, but have not mentioned anything about FAA requirements.

However, for our own benefit and future capability, it might be work pulling the trigger on etching capabilities. I imagine that would give us considerable more control internally, as well as allowing us to swim in the water with the big fish, so to speak.

Thank you all for your input!

 

[Al Rosen]

You can have the PCB identified with a unique lot number when it's fabricated. ICs and other semiconductor parts usually have a date code. You can assign lot numbers to parts and material when received and maintain records in your work order files of the lots that were used. Your system should be designed for two way traceability.

 

[outdoorsNW]

If you find the right PCB supplier, you can get unique markings on each board. You may already have unique markings on a board and not know it.

These days it is easier because many to most companies use laser and inkjet technology to mark boards, allowing each PCB to have a unique marking. Companies with old technology can not have unique markings because the markings are use film and silkscreen tech that puts the same markings on each board.

When I worked in bare PCBs, unless specifically not allowed by the customer, each board had a unique set of markings. (For those who don't know, PCBs are manufactured from standard sized panels and then routed out near the end of the manufacturing process.) Sometimes all panels of a part number would have a problem in a particular panel location. The numbers were also used internally for reporting scrap and product in need of further investigation.

A customer wanting to these marks would have to ask what each number meant and where it was located. There was the part number, the lot code (never repeated for a part number), a panel code (not repeated for a lot code), and a position on the panel code (not repeated on the panel). Put all of these together and you have an identifier that will not repeat.