SUPPLIER QUALITY
Why a complete certificate does not prove a part is genuine
A material certificate is evidence that someone issued a document. It is not, by itself, evidence that the material is what the document says. Recent aerospace supply-chain investigations have repeatedly involved parts and materials whose paperwork looked complete. Clause 8.1.4 exists because document review alone cannot stop a document that is itself false.
A process, not a checklist
AS9100D adds four aerospace-specific processes under 8.1: operational risk, configuration management, product safety and counterfeit part prevention. Each is phrased the same way: the organization plans, implements and controls a process. An auditor will therefore not stop at a policy or a form. They will ask where the process starts, who owns each step and what record it leaves.
For 8.1.4, the purpose is to prevent the use of counterfeit or suspect counterfeit parts and to stop them from reaching delivered product. AS9100D defines a counterfeit part as an unauthorized copy, imitation, substitute or modified part knowingly misrepresented as a genuine part of an original or authorized manufacturer.
Seven practices, each with an owner and a record
The note to 8.1.4 lists practices to consider. A useful test is to map each one to a named control and the record it produces. The example below is from a fictional precision machining company, ABC Aerospace.
| Practice in the 8.1.4 note | Example control | Record |
|---|---|---|
| Awareness and prevention training | Purchasing, receiving and stores staff trained yearly, using recent alerts as cases | Training records |
| Obsolescence monitoring | Quarterly check with suppliers of single-source materials and standard parts | Obsolescence watch list |
| Buying from original or authorized sources | Approved supplier list marks each source as original, authorized distributor or other | Approved supplier list |
| Traceability to the original manufacturer | Material certificates must trace to the mill heat; distributors supply the original certificate | Receiving inspection records |
| Verification and test methods | Chemical analysis on a sample of every lot of high-risk material | Material test reports |
| Monitoring external alerts | Monthly review of customer, authority and industry alerts against part numbers and suppliers | Alert review log |
| Quarantine and reporting | Suspect parts segregated, tagged and reported to the customer; never returned to the supplier | Suspect part report |
Three other clauses connect to this process. 8.4.2 expects inspection or periodic testing when the risk of nonconformity, including counterfeits, is high. 8.4.3 requires counterfeit prevention to be flowed down to external providers. 8.7.1 requires counterfeit or suspect parts to be controlled so they do not re-enter the supply chain.
Why suspect parts are not sent back
The most instructive line in a counterfeit procedure is often the one about returns. Returning a suspect part to the supplier feels like closing the problem. It may only move the part back into circulation through another channel. A sound procedure quarantines the part, marks it clearly, reports it to the customer promptly and waits for direction from the customer or authority.
A synthetic example: the day an alert arrives
This dialogue is fictional and simplified.
Auditor: Did last month's alert review find anything relevant to you?
Quality engineer: Yes. A customer forwarded an unapproved-parts alert involving a distributor. We had bought one lot of nuts from them last year.
Auditor: What happened next?
Quality engineer: The 200 pieces left in stock were quarantined and tagged as suspect. For pieces already installed, we listed the affected lots from traceability records and notified the customer the same day.
Auditor: How did you build that list?
Quality engineer: Receiving lot to ERP material issues, then to work orders and shipped serial numbers. It took about four hours.
The real test of counterfeit prevention is not whether training happened. It is whether, on the day an alert arrives, the organization can find every affected product within hours.
Questions an auditor may ask
- When did you last receive an external counterfeit or unapproved-parts alert, and what did you do with it?
- Which suppliers on your list are not original manufacturers or authorized distributors? What extra verification applies to them?
- Does your procedure allow suspect parts to be returned to the supplier?
- If a material certificate were found to be false tomorrow, how long would it take to identify every part made from that material?
Certificate exists ≠ material is genuine
Counterfeit prevention protects something whose value appears only after delivery. Whether a part is genuine may not be questioned until years into service. The evidence has to be ready for that question before the part ships.
About this guide
This article is adapted from a chapter of AS9100D in Practice: From Requirements to Objective Evidence. It refers to AS9100D by clause number and does not reproduce its text. It is not an official interpretation and does not replace the standard, customer requirements or your own procedures. Not affiliated with or endorsed by SAE, IAQG or ISO. Companies and events in the example are fictional.
FROM KNOWLEDGE TO PRACTICE
Read the full chapter: AS9100D in Practice covers configuration management, product safety and counterfeit prevention together, with procedure wording and a complete control table.
Check your evidence: AS9100D Internal Audit & Objective Evidence Master Toolkit
AS9100D in Practice is published in Traditional Chinese.
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