AS9100 Revision D adds a few new requirements that are confusing to some users. Here are some invaluable third-party sources of information and support which can help you address the more complicated and unusual AS9100 clauses.
Counterfeit Part Control
The Rev D standard introduces its most major change by adding requirements to prevent the use of counterfeit parts. The standard doesn’t explicitly specify what it’s talking about, but industry experts know that it means two things: counterfeit electronic components (resistors, ICs, capacitors, etc.) and counterfeit materiel (not a typo, “materiel” is a military term referring in broad terms to metals, plastics, raw material and hardware.) The following sources can help:
- Two Critical Standards: I recommend you purchase and download either (or both) of the following standards, depending on the scope of the materials you use and your industry:
- ERAI: this is the world’s number one source for news, information and updates on counterfeit parts, including reports on counterfeit parts found in the wild; it’s focus is electronic components. As a result, it’s a critical source of information for those monitoring their supply chain and internal inventory. ERAI now offers some fantastic, role-focused training on counterfeit part control through its new Intercept program; each course of which is short, web-based, and targeted at specific employee positions, helping them learn how to identify counterfeit parts in real life.
- Henry Livingston’s Blog: Henry regularly provides news on updates to FAR/DFARS and counterfeit product updates.
Organizational Knowledge
ISO 9001:2015 added a new clause on “organizational knowledge,” so users of both “vanilla” ISO 9001 and its aerospace neighbor AS9100 will get use out of these next suggestions. The clause is a diluted, reductive nod to “knowledge management” (or “KM”) which itself is a rich field of study on its own, and worth looking at in greater details. To learn more about KM and to get more value out of this otherwise confusing clause on organizational knowledge, try:
- RealKM – fantastic source for free articles and in-depth studies on the KM field and approaches you can use right now.
- KM Institute – they sell certifications, which is usually a red flag (do we really have to become certified in everything?), but do have some training programs and other materials you may find useful.
Configuration Management
“CM” is a complex discipline affecting product design, identification and technical documentation, and one which is often overlooked by anyone other than large aerospace companies with mature in-house engineering staff. But the AS9100 standard imposes it on everyone, including those tiny machine shops that may have a toe in the water of design. As a result, some third party training may be needed. Be careful, because the software engineering and CMMI worlds offer a lot of material on CM, but this isn’t always the same as what you would need for AS9100 compliance, especially if you’re a hardware manufacturer.
- CMStat offers some training courses that will get you up to speed on this concept, without offering 1,000 dubious “personal certifications” that so many other training providers throw at you. They also offer related CM consulting.
FOD – Foreign Object Debris/Detection/Damage Control
Blink and you’ll miss it, but clauses 8.1, 8.5.1 and 8.5.5 mention the need to control foreign objects. It doesn’t call out a need for a formal “FOD Program,” but nevertheless that’s essentially what AS9100 expects. The good news is that FOD programs can be scaled up or down, based on the complexity — or simplicity — of your QMS processes, so it’s not something to panic about.
- FOD News – this is the number one source for FOD news (if you’re into that sort of thing) but more importantly, they publish the absolutely fantastic “Ultimate FOD Prevention Program Manual.” I have a dogeared copy on my desk for 15 years or more, now, and it’s never let me down. They also offer training videos and the usual FOD posters.
ITAR / EAR / Export Controls
While ITAR is not named at all in the standard, AS9100 does require you to adhere to customer’s requirements and related statutory and regulatory requirements. As I’ve written, ITAR and EAR are being flowed down to the entire supply chain these days, and this can be a daunting and intimidating task. We’ve got you covered, however.
- Aerospace Exports Inc. – the export experts at AEI can help implement an ITAR/EAR and overall compliance control program in only a few days, if you’re willing to do the necessary study of the regs afterwards. They will help put the documentation and methods in place, and then offer support afterwards. Since failure to do so can be a felony, you’ll want to make sure your ITAR program is legit, and fully implemented. Best of all, AEI’s services are not expensive, and nearly any company will find room for this in its budget.
Christopher Paris is the founder and VP Operations of Oxebridge. He has over 35 years’ experience implementing ISO 9001 and AS9100 systems, and helps establish certification and accreditation bodies with the ISO 17000 series. He is a vocal advocate for the development and use of standards from the point of view of actual users. He is the writer and artist of THE AUDITOR comic strip, and is currently writing the DR. CUBA pulp novel series. Visit www.drcuba.world
