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SCMH Section 3.3.

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Revision Letter: D
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Control of Nonconforming Outputs Guidance

1. Introduction and Purpose


1.1. This guidance material provides recommendations and explanatory content to the
supply chain of aviation, space and defense products and services to support
implementation and compliance to the IAQG standard AS/EN/JISQ 9100 ‘Control
of Nonconforming Outputs’ and its associated standards (in particular
AS/ES/SJAC9131) and recommended practices.
1.2. This material was developed by a team composed of Original Equipment
Manufacturers (OEMs) and suppliers chartered by the International Aerospace
Quality Group (IAQG).
1.3. Every attempt was made by the team to ensure that this guidance supports
regulatory authorities’ requirements and guidance and is consistent with general
OEM and supplier Quality Management System (QMS) practices. The published
requirements and guidance consulted are listed in the References section of this
document.
1.4. In addition to supporting regulatory compliance this guidance aids in the
development of cost-effective business practices for the proper control of
nonconforming articles while helping maintain the integrity and quality reputation
of both the customer and the supplier.
1.5. The requirements specified in this guidance are complementary (not alternative)
to contractual and applicable statutory and regulatory requirements. Should there
be a conflict between the requirements of this standard and applicable contract,
statutory or regulatory requirements, the applicable contract, statutory or
regulatory requirements shall take precedence.

2. Scope
2.1. Guidance for the nonconformity management process elements of root cause
corrective action and counterfeit parts are not addressed within this document.
Those topics are addressed separately in other sections of the SCMH.
2.2. Use of the term “articles” can be extended to mean materials, products,
processes or services.
2.3. This guidance is intended only for production articles, not for articles intended for
modification or replacement of in-service articles.

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3. Document Content
3.1. The content of this document in Sections 5 – 14 is structured around (10) themes
contained within AS/EN/JISQ 9100:2016 Section 8.7. These themes are all
elements pertaining to the control of nonconforming articles and have been
identified as:
• Identification of Nonconforming Articles
• Segregation of Nonconforming Articles
• Containment of Nonconforming Articles
• Records of Nonconforming Articles
• Disposition of Nonconforming Articles
• Customer Approvals of Nonconforming Articles
• Execution of Nonconforming Article Dispositions
• Verification of Corrected Nonconforming Articles
• Customer Notification of Escaped Nonconforming Articles
• Scrap of Nonconforming Articles
3.2. This key icon identifies content that provides clarification of specific content
of AS/EN/JISQ 9100:2016 or of new approaches associated with the control of
nonconforming articles.
3.3. While every attempt has been made to state this guidance in a manner that
makes it applicable to the aviation, space and defense industries, any industry
unique guidance is clearly noted.
3.4. To complement this guidance, examples of nonconforming article control “Best
Practices” that support the implementation of the requirements of AS/EN/JISQ
9100:2016 are available at http://www.iaqg.org/scmh.

4. Terms and Definitions:


The following terms are defined in the IAQG Dictionary www.iaqg.org/dictionary and some
are expanded below as the term relates to control of nonconforming outputs;

• classification of nonconformity – (as it relates to nonconforming product) the


determination of whether a nonconformity has an appreciable effect upon
regulatory requirements of an article after the final disposition is implemented;
nonconformity classifications include the following:
o critical: a nonconformity affecting safety, health or environmental
conditions (defense program terminology)
o major: a condition that can result in the failure or reduce the usability of
the product or service and its intended purpose [9101 IAQG definition:].
as specifically related to nonconforming outputs: a nonconformity that has

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an appreciable effect on weight, balance, structural strength, reliability,


operational characteristics, or other characteristics affecting article
airworthiness or other regulatory requirements.
o minor: a single system failure or lapse in conformity to meet a 9100-
series standard requirement, customer QMS requirement, or documented
information defined by the organization [9101 IAQG definition]. as
specifically related to nonconforming outputs: a nonconformity not
categorized as critical or major [SCMH 3.3]
• customer –Organization, legal entity, or person that receives a product or
service (e.g., consumer, client, end-user, retailer, beneficiary, purchaser) [9145-
IAQG Dictionary].
o as specifically related to nonconforming outputs: the organization that
receives an article or service via contract and additionally has the
authority to establish article and process requirements [SCMH 3.3].
• design approval holder - the organization responsible for the design of articles
or for changes thereto. This is the holder of a design approval granted by a
regulatory authority or as specified in the prime contract for defense and space
articles. In civil aviation it is the holder of a Type Certificate (TC), Supplemental
Type Certificate (STC), Technical Standard Order (TSO), Joint TSO/European
TSO etc. [SCMH 3.3]
• interim disposition – a disposition requiring further processing to obtain
information to enable a final disposition [SCMH 3.3].
• material review – The process of determining the disposition of nonconforming
material [9138 IAQG definition].
o as specifically related to nonconforming outputs: an evaluation and
subsequent disposition of use-as-is or repair by authorized engineering
individuals and concurred with authorized quality individuals that allows
the nonconforming article to fulfill the intended usage requirements
although it does not conform to the contract, specifications, drawing or
other applicable design data [SCMH 3.3].
• material review board (MRB) - technically qualified and authorized individuals
necessary for the proper dispositioning of nonconforming material. The board
typically includes representatives from Quality and Engineering [SCMH 3.3].
• nonconformity –A specific occurrence of a condition that does not conform to a
specification or other inspection standard [9013 IAQG definition:].
o as specifically related to nonconforming outputs: the failure of an article
characteristic or functional test to conform to the requirements specified
in the contract, specifications, drawing or other applicable design data
[SCMH 3.3].

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• nonconformity management – an element within a quality management


system that provides for the control of nonconforming articles [SCMH 3.3].
• preliminary review – an evaluation and subsequent disposition by authorized
individuals that removes a nonconforming condition from an article to return the
article completely to the contract, specifications, drawing or other applicable
design data; preliminary review dispositions can also be scrap or return to
supplier [SCMH 3.3].
• regulatory authority – an organization with the responsibility to define and
implement regulations with legal enforcement authority such as the FAA, EASA,
DCMA, NASA, CAAC, GCAA, JCAB, ANAC, IAC, etc. [SCMH 3.3].
• repair –: Used when the nonconforming article, material or service can be
corrected to a usable condition, although its condition will not be identical with
drawing/specification requirements [9009 IAQG definition].
o as specifically related to nonconforming outputs: processing of a
nonconforming article using an approved and documented instruction or
process for a one-time or stated limited production which reduces the
nonconformity to a usable condition to fulfil the intended purpose,
although it does not conform to requirements originally specified in the
contract, specifications, drawing or other applicable design data [SCMH
3.3].
• rework – processing of a nonconforming article using an approved and
documented instruction or process applied to a nonconformance that will
completely eliminate the nonconformance which results in the article completely
conforming to the original contract, specifications, drawing or other applicable
design data [SCMH 3.3].
• standard repair - processing of a nonconforming article using an approved,
documented and controlled repair process which authorizes recurrent use to
process a nonconforming article so that it will fulfill the intended usage
requirements, although it does not conform to requirements originally specified
in the contract, specifications, drawing or other applicable design data [SCMH
3.3].
• use-as-is – an authorized disposition of an article with one or more
nonconformities determined to be usable to fulfil its intended purpose in its
existing condition, although it does not conform to requirements originally
specified in the contract, specifications, drawing or other applicable design data
[SCMH 3.3].
• work authorization document – an approved document that authorizes work to
be performed (e.g. production planning, manufacturing work instructions, work
order, traveler) [SCMH 3.3].

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5. Identification of Nonconforming Articles


Expectation: Provide methods to recognize and identify nonconforming articles to
distinguish them from conforming articles.

5.1. Utilize proper inspection points, tests, inspection standards, applicable design
data and competent operators in the production process to recognize
nonconforming articles.
5.2. Identify the nonconforming articles to clearly distinguish them from conforming
articles. Identification is typically done with paper or metal tags, stickers or tape
that does not damage or contaminate the article. When physical identification of
the nonconforming article is not practical, it should be possible to locate the
nonconforming condition utilizing the nonconformity record or work authorization
document. A clearly described location of the nonconformity on the
nonconformity record greatly aids in identification.
5.3. Identify where the nonconforming article is within the sequence of production
operations in order to continue processing upon resolution of the nonconformity
or for proper sequencing of rework or repair work instructions.
5.4. Ensure that the nonconformity management system, including organizational or
individual roles, responsibilities and nonconformity processing requirements, is
documented in the quality management system.
5.5. Identify articles that are potentially nonconforming while an investigation
proceeds to determine if they are actually nonconforming. In situations where
potential nonconforming articles are being investigated, identify those articles in
an interim manner until a determination is made whether a nonconformity is
present.
5.6. Identify articles being shipped to customers with unresolved (open)
nonconformities with tagging or marking of the nonconforming article as specified
by contract. Shipping containers may also be appropriately tagged or marked.
5.7. Review process and approval of noncompliance issues such as unqualified
processors, loss of Nadcap accreditation, quality system failures/suspension, etc.
to determine whether nonconforming articles resulted from these noncompliance
issues.

6. Segregation of Nonconforming Articles


Expectation: Provide a means to separate or distinguish nonconforming articles from
conforming articles to prevent unintended use or delivery.

6.1. Document the process for separating or distinguishing nonconforming articles


from conforming articles to prevent unintended use or delivery. The controls

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developed for segregation are not intended as a countermeasure to “criminal


intent”.
6.2. Articles may be segregated in place using the capabilities of a production control
system rather than taken out of production to a physical segregation area.
6.3. Protect segregated articles from further physical or environmental damage
resulting from handling or storage.
6.4. For articles in production, provide two-way traceability by cross-referencing the
nonconformity record and work authorization document. Prevent closure of the
work authorization document until the nonconformity has been addressed.
6.5. Segregate articles returned from customers for rework, repair or disposal in a
manner which prevents them from being co-mingled with production parts.
6.6. Continued processing of an assembly that contains nonconforming parts or
material is permissible until the final disposition can be provided and executed as
long as the nonconformity will not be altered or covered up by further processing.

7. Containment of Nonconforming Articles


Expectation: Take prompt action to determine the magnitude of a detected
nonconformity or other undesirable situation, and to minimize the impact and prevent
growth. Investigate the effect of the nonconforming outputs on other processes,
articles, or services.
Note: ARP/EN/SJAC 9136 contains expanded discussion on containment.

7.1. Perform an investigation to discover and contain all in-process or completed


nonconforming articles currently within the QMS, including other upstream and
downstream production facilities, warehouses, and suppliers. Articles are
considered contained when identified on a nonconformity record.
7.2. Expand the scope of containment to include any other articles that are
discovered during the containment action. A nonconformity traced to a
processing failure is an example of a nonconformity that may affect other articles
of a differing part number.
7.3. Determine the scope of the nonconforming articles delivered to customers. See
Customer Notification of Escaped Nonconforming Articles section 13 for further
guidance.
7.4. When an investigation of a nonconformity determines that additional articles are
potentially nonconforming, ideally this situation would result in stopping
production, however this is often not practical or possible. In order to continue
production while an investigation proceeds or a disposition is under development,
a risk assessment of the effects and impact of the nonconformity should be
performed to determine if continued production is appropriate.

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7.5. To support the containment of an identical nonconforming condition on multiple


article quantities of the same part number in multiple locations (e.g. in production
and in stores), a single nonconformity record may be utilized.

8. Records of Nonconforming Articles


Expectation: Document the nonconforming article, clearly describe the nonconforming
condition, obtain a disposition by authorized individuals, provide record linkage to the
corrected article, and provide linkage to root cause corrective action.

8.1. Document the nonconformity on a nonconformity record. AS/EN/SJAC 9131


provides standardized industry guidance for nonconformity data definition and
documentation and the standard is a requirement when contractually invoked.
Document any additional contractually required customer requirements.
8.1.1. Provide a means to trace nonconforming articles to the end use customer.
8.2. AS/EN/SJAC 9131 provides details for these high-level expectations:
8.2.1. Record Identification
• Assign the record a unique reference number.
• Provide revision control to the record.
8.2.2. Notation of Affected Articles
• Document nonconforming part numbers and part name.
• Note part serial number, lot number, batch number or other unique part
identifier. If multiple part quantity is nonconforming, note unique part
identifiers for all parts when applicable.
• Records of processing nonconformities such as autoclave or heat treat
loads affecting multiple part numbers may be documented on a single
nonconformity record. In such cases where all parts cannot be
addressed with the same disposition, separate nonconformity records
should be used.
8.2.3. Nonconformity Description
• All information should be in the language that matches the applicable
design data. Records may also include bilingual content in the local
language.
• Provide a detailed description of the “should be” condition and “as is”
condition that clearly describes the nonconformity and the departure
from the requirements specified in the contract, specifications, drawing
or other applicable design data. Provide dimensions and tolerances,
specification limits, test results, measurements, etc. Units of measure
should be the same as that specified in the applicable design data and
any abbreviations utilized should be common and recognized.

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• Write defect description at a level of detail that allows visualization of


the nonconformity without the need to see the article.
• Identify the drawing number or specification and revision level utilized to
inspect the part. Provide drawing sheet number and drawing zone or
other identifying features of the applicable design data to document
location of the nonconformity.
• Include graphics such as marked up drawings or photographs to aid in
nonconformity description.
• Provide reference to any prior dispositions on the same article part
number for the same nonconformity.
• Provide any recommendations for article disposition including any
proposed repairs.
8.2.4. Description or Linkage to Defect Cause and Corrective Action
• Provide information regarding the cause of the nonconformity such as
defect coding that allows for process improvement activity
• Provide immediate and/or long-term corrective action or linkage to other
documentation providing this information.
8.2.5. Disposition of Nonconformity
• Provide preliminary or material review disposition for each documented
nonconformity.
8.2.6. Record Initiator, Approval and Concurrence
• Document the initiator of the record including supplier or department
name or code.
• Document the identification (name or code) of the authorized individual
that provided the disposition and their function or department.
• Record the dates of initiation and approval.
• When required, indicate customer approval or concurrence of
disposition.
8.3. Retain nonconformity records, in electronic or paper form, in accordance with
customer record retention requirements.
8.4. Retain nonconformity records associated with a design error to design data
retention requirements when the revised design data configuration does not
match the nonconforming article configuration. This provides configuration
definition for articles whose only definition is defined on the nonconformity
record.

9. Disposition of Nonconforming Articles


Expectation: Establish the responsibility and authority for the review and disposition of

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nonconforming articles and the process for approving persons making these
decisions. Ensure that any requirements, restrictions, or limitations imposed by the
customer are met.

9.1. Preliminary Review Disposition of Nonconforming Articles


Expectation: Establish the responsibility and authority for the review and
disposition of nonconforming articles that return the articles to a conforming
condition or removes the nonconforming articles from the quality management
system.
9.1.1. Document the responsibility and authority for, and the process for
approving, the individuals providing preliminary review dispositions.
9.1.2. Preliminary review (PR) dispositions are typically provided by Quality
personnel or Quality authorized personnel. PR dispositions return the
nonconforming articles to a condition that conforms completely to the
contract, specifications, drawing or other applicable design data with
disposition types of rework, regrade, or retest.
9.1.3. Preliminary review dispositions can also remove the nonconforming
articles from the QMS with disposition types of scrap or return to supplier.
9.1.4. The preliminary review authorized individual may direct the issue to the
Material Review Board (MRB) for a disposition.
9.1.5. Preliminary review dispositions do not require customer delegation.
9.1.6. Preapproved standard repairs for usage with specific repetitive
nonconformities can be invoked by a preliminary review rework
disposition.
9.1.7. Nonconformities resolved by a standard repair disposition must fall within
the scope, restrictions and limitations defined within the standard repair.
These restrictions are to ensure that the standard repair falls within the
existing design allowables and thereby eliminates the need for further
analysis of the nonconformity.
9.1.8. Documented repair procedures that are not released as applicable design
data must be invoked by a material review repair disposition.

9.2. Material Review Disposition of Nonconforming Articles


Expectation: When explicitly delegated by the customer, establish the
responsibility and authority for the review and material review disposition of
nonconforming articles by authorized engineering personnel. Ensure that any
requirements, restrictions, or limitations imposed by the customer are met.

9.2.1. Document the responsibility and authority for the review and disposition of
nonconforming articles with dispositions of use-as-is or repair, and the

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process for approving individuals making these decisions. Customers


provide material review dispositions of repair or use-as-is for suppliers
unless the supplier has obtained an explicit delegation from their
customer. Customers define material review delegation requirements,
restrictions, and limitations. (See Delegation of Authority for Material
Review Disposition of Nonconforming Articles section 9.3).
9.2.2. Material review dispositions may be controlled by a Material Review Board
(MRB) that is typically comprised of qualified and authorized individuals
from Quality Assurance and Engineering. When required, usually on
defense or space contracts, customers may be a member of the MRB.
9.2.3. It is the responsibility of the MRB to obtain agreement upon the final
disposition. If disposition agreement cannot be obtained, then the matter
may be elevated to higher level members of the MRB.
9.2.4. The engineering member of the MRB may have both preliminary and
material review authorities.
9.2.5. The role of the engineering member of the MRB is to provide
nonconformity dispositions that authorize departures from applicable
design data and ensure that the article meets all design requirements.
9.2.6. The role of the Quality Assurance member of the MRB is to ensure that all
material review documentation is complete, accurate and compliant to
requirements; concur with material review dispositions for cost
effectiveness; and confirm that dispositions maintain article quality and the
integrity of the company.
9.2.7. Individuals authorized to provide use-as-is or repair dispositions:
1. Need access to design and/or analysis data or to experts as necessary
to evaluate and disposition the nonconformity.
2. Evaluate the impact of the nonconformity upon the article’s design, and
performance requirements such as ultimate strength, fatigue, damage
tolerance, interchangeability, acoustical and vibrational environment
requirements, aerodynamic requirements, flammability, safety, etc.
3. Evaluate the nonconformity for major, minor and critical nonconformity
classification.
4. Will be able to provide a rationale for the disposition.
5. Will either retain the supporting data (analysis records, laboratory test
results, etc.) or be able to recreate the supporting data if needed.
6. Ensure that production has the capability to perform the repair and the
repair is economically feasible.
7. Ensure that materials are available to execute the repair.
8. Consider customer impacts for future maintenance and in-service
repair.

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9.2.8. Material review dispositions on test, development and production


articles prior to the issuance of regulatory authority approval of the product
design data (e.g. Type Certificate in US civil aviation) may require
additional actions. A review of certification impacts is advised to ensure
that the dispositioned articles do not have an effect upon testing used for
validation of the product design to regulatory authority requirements or
tests supporting the validation of new analysis methods. Additionally,
when the results of developmental testing differ from the predicted results,
reevaluation of prior nonconformity dispositions may be necessary to
ensure that design requirements are met.
9.2.9. The nonconformity management system may be utilized to maintain
traceability and visibility of production articles that are pending
qualification in order to determine the acceptability of these articles upon
completion of qualification activities. Typically, an evaluation of the
previously built articles against the final qualified part is performed to
determine if any differences exist that effect the acceptability of the article.
9.2.10. The material review process may be utilized as a bridging action to
maintain production and to ensure configuration control while waiting for
engineering design changes under the following conditions:
9.2.10.1. Obtain concurrence from the design approval holder engineering
organization for those items that depart from the type design data to
assure a design change will be accomplished.
9.2.10.2. The material review process may not circumvent the established
design change process which includes major/minor classification and
design approval holder approval as specified by customer
requirements.
9.2.10.3. Traceability from the affected articles to the engineering design
change and vice-versa is ensured. This is usually done via the
material review record or associated corrective action.
9.2.10.4. Subsequent material review records for the same condition must
either reference the original material review record that initiated the
engineering design change or must reference the engineering design
change directly to ensure configuration control.
9.2.10.5. Notation on the material review record of the concurring design
approval holder engineer’s name is recommended when obtained.
9.2.10.6. The engineering design change must be completed in a timely
manner to avoid the utilization of the material review record for an
extended period of time.

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9.3. Delegation of Authority for Material Review Disposition of Nonconforming


Articles
Expectation: Delegation of material review disposition authority for dispositions of
use-as-is or repair for minor nonconformities may only be granted by the
organization that is responsible for design and that holds an approval to produce
the article from the relevant regulatory authority or when otherwise specifically
defined by defense contracts.

9.3.1. Suppliers that do not hold an article design approval (e.g. a TC, ATC,
STC or TSO/JTSO/ETSO or equivalent) from a regulatory authority must
receive an explicit delegation for material review disposition authority from
the design organization. Material review authority can only come from the
TC, ATC, STC or TSO/JTSO/ETSO holder for commercial programs and
from the defense or space contractor.
9.3.1.1. There is a common misunderstanding by suppliers performing
design of the following statement from AS9100D section 8.7:
“Dispositions of use-as-is or repair for the acceptance of
nonconforming products shall only be implemented after approval
by an authorized representative of the organization responsible
for design or by persons having delegated authority from the
design organization.” This confusion normally is caused by a
misunderstanding of who is the ‘organization responsible for
design’ and ‘design organization’ specified by AS/EN/JISQ
9100D.
9.3.1.2. The identity of the “design organization” is clarified by referring to
the IAQG Dictionary definition of design organization (DO) as “An
organization responsible for the design of articles or for changes
thereto that is the holder of a Design Approval granted by a
regulatory authority i.e. TC, STC, PMA, or TSO/JTSO/ETSO
Authorization, or equivalent.”
9.3.2. While material review is a component of both the customer and
supplier quality management systems which are generally a responsibility
of the quality organization, both the delegation of authority and execution
of material review dispositions are engineering-centric activities. The
customer’s engineering organization should have a role in the evaluation,
delegation and oversight of the supplier’s delegated engineering authority
with the focus being upon assuring the supplier is providing use-as-is and
repair dispositions that meet all design and regulatory technical
requirements. Correspondingly, since it is typical that the supplier
authorized individuals providing material review dispositions report to an

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engineering organization, that engineering organization, rather than the


quality organization, has the primary responsibility and accountability for
the various elements that support compliance to material review
requirements e.g. personnel qualifications, technical knowledge and
competency, technically compliant dispositions, etc.
9.3.3. The customer is to document requirements for material review delegation
including prerequisites, the method to request delegation, supplier and
personnel qualifications, material review requirements and limitations,
methods to review and approve delegation, and oversight methods that
ensure supplier controls for compliance to customer requirements are in
place. For some projects, particularly defense programs, customer
oversight may be performed by a Government Engineering or Quality
Assurance Representative (GQAR).
9.3.4. Customers should retain a list of supplier names and locations granted
delegated material review authority which includes the suppliers’ scope of
authority.
9.3.5. Customers may use risk assessments of suppliers to determine methods
of oversight. These assessments will generally yield a higher risk for build-
to-print suppliers vs suppliers with design responsibility because suppliers
with design responsibility: (a) have a greater level of involvement in the
design; (b) have greater access to design/test/analysis data; (c) may have
independent certifications such as an STC or TSO thereby having
increased certification knowledge; and (d) have a higher level of
qualification to determine dispositions based on direct article design
experience.
9.3.6. The individual responsible and accountable for ensuring adherence to the
customer’s material review delegation requirements at the supplier is to be
clearly identified.
9.3.7. Further delegations to sub-tier suppliers is not permitted unless specifically
allowed and authorized by the customer.
9.3.8. Customers and suppliers should develop a means to ensure that
delegated material review dispositions’ technical and procedural content
comply with customer requirements and limitations. Records of audits and
surveillance should be retained and available for customer and regulatory
authority review.
9.3.9. Customers should provide consultative support as needed to assist
suppliers in providing the proper disposition of nonconforming articles and
to ensure that warranties or other business-related responsibilities are
maintained.

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9.4. Guidance Applicable for All Disposition Types


9.4.1. Individuals authorized to provide nonconformity dispositions should be in
an organization structure that allows dispositions to be provided without
undue influence of cost and schedule pressures. Concerns of undue
pressure should have a means for immediate resolution such as an ethics
hotline, escalation process to management, third-party review, etc.
9.4.2. Authority should be granted based on a review of candidate experience,
education, demonstrated knowledge, satisfactory completion of required
nonconformity process training, examinations, etc. and the means of
granting this authority should be documented by the supplier.
9.4.3. Revision controlled lists of authorized individuals, noting date of
authorization and any limitations of authority are to be retained at the
company that authorizes the individuals to provide dispositions for
nonconforming articles.
9.4.4. Repair drawings, documents or specifications stated as an external
reference within a disposition need to be revision controlled and retained
for the same duration as nonconformity records.
9.4.5. Dispositions for the same part number with the same disposition of articles
that exist on multiple units may be extended upstream or downstream by
authorized individuals from the point of discovery within the supplier QMS.
Implementation of the disposition is typically done by revision to the
affected work authorization documents. Caution must be exercised to
maintain effectivity or accountability of affected articles when extending or
cancelling multi-unit dispositions. If the multi-unit disposition cannot be
executed on an article, the nonconforming condition must be documented
on a new nonconformity record and dispositioned.
9.4.6. When further information is required to process a nonconformity, an
interim disposition may be provided. Interim disposition instructions must
be completed, and the results resubmitted in order for a final disposition to
be provided.
9.4.7. When the disposition is to be completed at a customer facility, an open
nonconformity record as specified by the customer may be required. Open
nonconformity records typically result when delivery schedules do not
allow for execution of the disposition, if further information is needed to
determine the final disposition or if the nonconformity disposition impacts
customer production operations.

10. Customer Approvals for Nonconforming Articles


Expectation: Obtain a disposition for nonconforming articles from the customer or if
the supplier has delegated material review authority, obtain acceptance from the

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customer when required by the customer.

10.1. Establish a means to identify the customer of the nonconforming article and
determine customer requirements for disposition or disposition approval.
10.2. Suppliers without delegated material review authority must obtain material
review dispositions from authorized individuals at the customer. This includes
reoccurring or similar nonconformities previously dispositioned by the customer.
10.3. Suppliers with delegated material review authority must contact the customer
for approval of dispositions when required by contract. Customers that are the
design approval holder or other authorized representatives (e.g. Government
Quality Assurance Representative – GQAR) reserve the right to reject a
supplier’s disposition.
10.4. Include proposed dispositions along with a detailed description of the
nonconformity in customer submittals.
10.5. Customer approval is not required for preliminary review dispositions; however,
notification may be required for scrap dispositions - typically on defense or
space programs or customer or other supplier-owned articles.
10.6. Suppliers of standards and raw material need to submit nonconformity records
to customers for disposition. Material review delegation is usually not offered to
these suppliers.
10.7. Submit nonconformities classified as major or critical to customer for
disposition.
10.8. Submit nonconformities to the customer per contractual requirements. Note:
violations of customer requirements classified as a “major” nonconformity by
the provider may be re-classified by the design approval holder.
10.9. When a supplier has a need to ship hardware to the customer with an open
nonconformity, a written authorization to ship must be coordinated and
processed through the customer for approval.
10.10. Following customer approval of a nonconformity disposition, any changes to the
disposition must be resubmitted for customer approval.

11. Execution of Nonconforming Article Dispositions


Expectation: Perform work according to disposition instructions. Request additional
direction if disposition instructions cannot be followed.

11.1. Ensure that personnel performing work are qualified and hold any necessary
certifications.
11.2. Perform the disposition according to the nonconformity record or work
authorization document.

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11.3. Provide evidence of disposition execution by documenting completion of


processing steps indicating work performed and the individual performing the
work.
11.4. Create any necessary data needed to verify proper correction of the
nonconforming article such as materials used, processing records, etc.
11.5. Request reevaluation of a nonconformity or disposition for the following types of
situations: an interim disposition was provided and additional instructions are
needed; the disposition cannot be completed as specified or an alternate
disposition is needed; additional disposition instructions are needed because
the condition of the nonconformity has changed or still exists; the completed
work does not conform to the disposition.

12. Verification of Corrected Nonconforming Articles


Expectation: Verify articles conform to the requirements when nonconforming articles
are corrected.

12.1. Document inspection results used to verify conformance to requirements for


preliminary review and material review dispositions.
12.2. Articles that fail the verification inspection require re-documentation, re-
disposition, and verification.
12.3. Verification may be documented on a work authorization document that records
inspection acceptance that is linked to the nonconformity disposition. Linkage of
the corrected article to the nonconformity record should be maintained. In some
cases, verification may be documented directly on the nonconformity record
when it is used as the work authorization document.
12.4. For incomplete execution of dispositions that will be submitted to the customer
on an open nonconformity record, verify customer requirements for transfer of
the open nonconformity to the customer’s QMS. Typically, the supplier
nonconformity record provides reference to the customer record number when
transferred. Perform activities such as proper packaging and identification,
attaching nonconformity record, customer authorization to ship, etc.

13. Customer Notification of Escaped Nonconforming Articles


Expectation: Perform a timely investigation to determine the scope of escaped
nonconforming articles, and report results to the customer. Immediately report
escaped articles that have safety concerns. Customers may delegate responsibility
for disposition of escaped articles with associated limitations.

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13.1. The scope of escaped nonconforming articles is typically an output from the
containment action.
13.2. Follow contract requirements for customer notification of escaped
nonconforming articles. Notify the customer that issued the purchase order,
which may be different than the ship-to company/location.
13.3. Customers may consider offering latitude in contract requirements for the timing
of notification to allow proper scoping and evaluation of the escapement unless
there is a safety concern. Customers should require immediate notification of
safety concerns.
13.4. Maintain a company policy for managing escapements including flow down of
requirements to sub-tier suppliers.
13.5. With customer approval and evaluation criteria, suppliers may be able to
evaluate escaped articles to differentiate articles that require recall versus
escaped articles that only require customer notification or may not require
customer notification due to no adverse impact on escaped article function (e.g.
use-as-is disposition). Escaped articles may be managed entirely within the
supplier’s QMS if there is no downstream impact.
13.5.1. Generally, articles that have left the supplier QMS are not to be
dispositioned by the supplier and require customer notification. With an
expanded authority granted by the customer, the ability to disposition
escaped articles within the supplier QMS rather than the customer QMS
for no impact (use-as-is) escapements is due to the supplier QMS,
when approved by the customer, becomes an extension of the
customer’s QMS. Explicit delegation specific to this authority including
any limitations or any communication requirements when exercising this
authority is needed.
13.5.2. Due to the sensitive nature and risk associated with escaped articles,
suppliers under consideration for expanded use-as-is disposition
authority for escapements should have a mature and stable QMS and
have demonstrated technical competency in material review decisions.
Additional supplier controls are advised such as mandatory customer
coordination by the supplier, immediate submittal of completed records
for customer review, etc.
13.5.3. Nonconforming articles that are determined to be use-as-is that have
been delivered by the customer and are in-service are beyond the
scope of the customer’s QMS and need to be addressed by a separate
means specified by the customer.
13.6. Reporting of in-service failures of products or articles is a responsibility of the
defense or space contractor or the design approval holder and is not delegated.

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14. Scrap of Nonconforming Articles


Expectation: Conspicuously and permanently mark, or positively control, articles
dispositioned as scrap until physically rendered unusable. Provide customer
notification when required.

14.1. Conspicuously and permanently mark, or positively control, articles


dispositioned as scrap to prevent re-entry into production including the
obliteration of part number identification. Articles may be marked or clearly
indicated as “not for production use” or “for display only” and may be used for
exhibits, training, etc. All other scrapped articles should be defaced, mutilated,
or destroyed before disposal.
14.2. Notify customer of scrapped articles when specified in the contract (typically
defense or space programs or for customer-owned articles). There may be a
value threshold specified for notification. Make note that specific contractual or
government guidelines may govern disposal of particular scrap articles, e.g.
ordnance.
14.3. Customer material review delegation is not required to provide scrap
dispositions and may be dispositioned by preliminary review. Some articles of
high value may be submitted for material review to validate the scrap
disposition is appropriate.
14.4. Provide oversight to third parties responsible for physically scrapping articles
through the deployment of contract requirements and audits.
Note: Additional guidance on the scrap of nonconforming articles may be found in
AS/EN/SJAC 9147 - Unsalvageable Item Management (currently in
development)

15. References
The following documents were consulted for the development of the nonconforming
article control guidance contained within this document.

Aviation

ARP/EN/SJAC 9136 - Aerospace Series - Root Cause Analysis and Problem Solving
AS9100 Section 7.4 - Communication
AS/EN/SJAC 9131C - Aerospace Series - Quality Management Systems -
Nonconformance Data Definition and Documentation
China Civil Aviation Administration AP21-AA-2010-04R4– Production Approval and

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Supervision Procedure Appendix I Section 5


CACC CCAR-21-R4 - Civil Aircraft Product and Components Compliance Approval
Regulation
CAR Article 35.(vi).e & f - Ordinance for Enforcement of the Civil Aeronautics Act
EASA 21A.139(b)1.(viii) - Certification of aircraft and related products, parts and
appliances, and of design and production organization
FAA 14CFR21.137(h) – Certification Procedures for Products and Articles –
Production Certificates – Quality System
FAA AC21-43A – Advisory Circular Production Under 14 CFR Part 21, Subparts F, G,
K, and O
GCAA CAR 21A.139(b)1.(viii) – Certification of Aircraft and Related Products,
Parts and Appliances and of Design and Production Organizations - Quality
System
Japan Civil Aviation Bureau (JCAB) Circular No. 1-003 Procedures for Type
Certification of Japanese Manufactured Aircraft
JCAB Circular 2-001 - General Policy for Approved Organizations
JCAB Circular No. 6-014 - Reporting of Suspected Unapproved Parts
Interstate Aviation Committee (IAC) Aviation Register 21.2E - Procedures of
certification and monitoring of civil aviation equipment manufacturers
National Civil Aviation Agency (ANAC) RBAC 21 Amendment 2 Section 21.137(h) -
Aeronautical Product Certification – Quality System

Space

European Cooperation for Space Standardization (ECSS) ECSS-A-ST-10-09C –


Space Product Assurance – Nonconformance Control System
NASA NPD 8730.5B Attachment A - NASA Quality Assurance Program Policy
NASA-SSC SPR8730.1 – NASA John C. Stennis Space Center Control of
Nonconforming Product
NASA-SSC SPR8730.5 – NASA John C. Stennis Space Center Material Review
Board Procedural Requirements

Defense

DCMA-INST-1207 – Department of Defense - Defense Contract Management


Agency - Effective Control of Nonconforming Material
Federal Acquisition Regulation FAR 46.407 - Government Contract Quality
Assurance – Nonconforming Supplies or Services
Ministry of Defense AQAP-2110 Edition D – NATO Quality Assurance Requirements
for Design, Development and Production

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NATO AQAP-2130-Edition 3 – NATO Quality Assurance Requirements for


Inspection and Test
16. Acronyms

ANAC: National Civil Aviation Agency of Brazil


CAAC: Civil Aviation Administration of China
CFR: Code of Federal Regulations
DCMA: Defense Contract Management Agency
EASA: European Aviation Safety Agency
FAA: Federal Aviation Administration (USA)
FAR: Federal Acquisition Regulation (USA)
GCAA: General Civil Aviation Authority (United Arab Emirates)
IAC: Interstate Aviation Committee (Russia)
JCAB: Japan Civil Aviation Bureau
NASA: National Aeronautics and Space Administration
NATO: North Atlantic Treaty Organization

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