What constitutes 'design'? We remanufacture products to OEM specifications.

I

Ingeniero1

#1
What constitutes 'design'?

We remanufacture products to OEM specifications. When completed, we calibrate and test the products to the same specifications as the OEM published specifications, and we offer the same warranty period or, in most cases, twice the length of said warranty period.

In our Quality Manual, we have stated as follows, (accepted by our registrar, BTW):
--------------------------------------
“7.3 Design and Development
Our organization is exempt from this clause. We are not involved in the design and development of products, as these activities are outside of the organization’s scope.”
--------------------------------------

As a rule, we use mostly the parts from salvaged products. We clean them, paint them, have them plated, etc. Occasionally, we make a part from raw material if the salvaged part is FUBAR. These normally are brackets, mounting flanges, and similar machined parts. We measure an original that we know to be correct, make a drawing, and duplicate the part. We do not design anything from scratch.

Definitely, this is not development; but does making a drawing to manufacture a replacement part constitute ‘design’ or could it be perceived as such by an auditor?

Thanks!

Alex
 
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C

ccochran

#2
Alex,

This sounds like engineering drawing to me, not design. You never know how an auditor might view something, though. You might have to perform some education on the auditor (i.e., knock him upside the head).

Craig

~~~~~~~~~~~~~~~~~~~~~~~~~~~
Craig Cochran
Center for International Standards & Quality
Georgia Institute of Technology
 

liuyy

Involved In Discussions
#3
Alex,
Sure you design something.But your design process is simple.So the design procedure would be simple whether documented or not.

Liuyy
 
C

celso klitzke

#4
Ingeniero1 said:
We measure an original that we know to be correct, make a drawing, and duplicate the part. We do not design anything from scratch.

Definitely, this is not development; but does making a drawing to manufacture a replacement part constitute ‘design’ or could it be perceived as such by an auditor?

Thanks!

Alex
We have the same problem. But our registrar (DNV) and all auditors that visited us talked the same : "When you make a product using an existing part as your model, you HAVE DESIGN AND DEVELOPMENT". It can be very simple, but you HAVE.

Well, they say it´s simple, we think it´s stupid.

Celso
 
I

Ingeniero1

#5
ccochran,
Yes, perhaps more of an 'engineering' or even an 'inspection' drawing. As a matter of fact, we also make drawings NOT to make a part, but simply for the operators to check the salvaged parts against, and determine whether they are usable. (I can see how this can really be a grey area subject to different interpretations.)

liuyy,
Wouldn't 'that' procedure fall under 7.3?

Celso,
So, did you have to meet clause 7.3 or parts of it?

Thanks!

Alex
 

Al Rosen

Staff member
Super Moderator
#6
Ingeniero1 said:
Occasionally, we make a part from raw material if the salvaged part is FUBAR. These normally are brackets, mounting flanges, and similar machined parts. We measure an original that we know to be correct, make a drawing, and duplicate the part. We do not design anything from scratch.
How do you account for characteristics you can't measure? Material, heat treat etc.
 
I

Ingeniero1

#8
Al,
Over the past 50 years or so, the company has 'gathered' a tremendous amount of parts and information. I have been here for a little over a year, but I have never seen or have even heard of any occasion where there was a part that we did not have one like it at one time or another.

Usually, it is a question of providing more products than we have ready-to-use parts for. Say that we need to ship five XYZ products - we may have salvaged enough parts to make 20 such products, except for perhaps one specific part, of which we may be down to the last few. In such a case, we may fix one of the parts that had been rejected and was not part of the ready-to-use stock, or we may have to make one from scratch based on another like-part that we have and is known to be correct.

In every case, we have identified the materials, heat-treat required, etc. In many cases, we are able to get this information directly from the OEM. We don't get drawings, other than if these are readily available to anyone, but we do get a lot of 'verbal' information. Funny, the relationships we have with the OEMs range from some that consider us as their independent repair-station and even tell their customers about us, to others that won't give us the time of day and do everything they can to destroy any product that may be remanufactured.

Oops - I'm way too long...

Celso – That’s what was afraid of – but we can do it.

Alex
 
C

ccochran

#9
Alex,

Good luck with your "design" process. I honestly do not believe what you're doing constitutes design. By definition, design means the product and its specifications and performance requirements do not exist yet. In your case, the product and all its specifications, functional attributes, and performance requirements already exist. All you're doing is making a drawing of something that already exists. The discipline that applies is document control, not design.

In my way of thinking, here are guidelines for design:
• If you are producing a unique good or service for which your customer has not provided specifications, then you're probably doing design and development.
• If your customer has only given you vague performance requirements and asked you to come up with a good or service that will meet those requirements, then you're probably doing design and development.
• If your product is driven by your organization’s powers of pure creativity and innovation, then you're probably doing design and development.
• If one or more of your products is protected by patents, then you're doing design.

I'd love to hear more perspectives on this.

Craig
 

liuyy

Involved In Discussions
#10
Ingeniero1 said:
ccochran,
Yes, perhaps more of an 'engineering' or even an 'inspection' drawing. As a matter of fact, we also make drawings NOT to make a part, but simply for the operators to check the salvaged parts against, and determine whether they are usable. (I can see how this can really be a grey area subject to different interpretations.)

liuyy,
Wouldn't 'that' procedure fall under 7.3?

Celso,
So, did you have to meet clause 7.3 or parts of it?

Thanks!

Alex
Alex,
7.3 is for design and development of product,i.e to specify its specification(intended uses,functions and performances etc.).Engineering or inspection drawing may be considered as 7.1c) and 7.5.

liuyy
 
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