AS131000 General Questions

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AESQ™ standards address problem solving, inspection frequency, measurement systems, PFMEA, and process control.

AESQ Supplier Forum - AS13100 Overview (Questions by Section)

Section

Question

Answer

1.0 Scope Can you clarify whether the requirements of AS13100 will be retroactive to existing parts/product or whether the requirements stated will be for new parts/product at the time of implementation? I realize that the standard will be applicable for new part introduction or changes to existing parts/product, but what is not clear is if at the time of implementation if existing parts/products will need to be compliant. If there is a part/product that has been made for years and the customer PO now flows down the requirement, should I assume that the requirements would then be retroactive?

AESQ has agreed that the standard is not retroactive for existing parts and products.

AESQ Member companies all agreed that they will be flowing AS13100 well before the compliance date of Dec 31, 2022. They also expect product to be received at that date that is compliant to AS13100. Over the next year and a half the suppliers will have time to build compliance. They should be using this time to train their people, conduct the gap analysis and then work towards full compliance. There will be exceptions at the Dec 31, 2022 date but those should be documented with a plan to close. 

1.0 Scope

I have attended both the Supplier Forum on the release of AS13100 a few weeks ago, as well as the SAE Mobilus presentation that occurred earlier today.  I am interested in continuing to learn more about AS13100 and am planning to attend the online training through SAE, but I have additional questions about applicability that I am having difficulty explaining to my organization and would appreciate any assistance that you could provide.

My company supplies product to about half of the engine organizations affiliated with AESQ, but our product lines are mostly not supplied to the engine-specific groups within those companies.  Therefore since we do not directly interact with these engine groups, we’re not sure if we’re going to be receiving updated flow-downs that will require compliance with AS13100.  Is there any guidance that you could provide as to how we can determine the applicability of the enforcement for this new specification for my organization?  We would like to be as proactive as possible (like working to the suggested timelines), but we also don’t want to exert excessive effort and energy complying with requirements that will never be required. 

Many companies will face the same issue i.e. some customers will flow down AS13100 and others will not.

When you look at the requirements of AS13100 some are easy to make ‘customer specific’. For example APQP & PPAP in section B can be switched on for customers who require it and not for others. Similarly with requirements such as Problem Solving using 8D, DPRV training, record retention, Design FMEA, etc.

However there are other requirements where an organisation will find it harder to only apply to certain customers. For example Quality Audit, Human Factors, certification requirements, mandated training, etc.

The expectation is that such requirements are built into the organisations management system, defining how they do business. 

Most of these requirements already exist today and have been flowed down by the engine manufacturers for many years. They represent our shared best practice and we strongly believe that they will add value to any organisation and produce a cost benefit.

The key approach to selling this to an organisation’s leadership is to link the defect prevention approaches of AS13100 to the cost of non quality of the business. 

1.0 Scope
  1. In our segment of the aerospace industry, we are totally a job shop with our sites processing 50 new orders a day and not seeing repeat orders for months or years.  We have thousands of part numbers.  Resources to perform advanced quality planning to support this would be counterproductive.  AS-13100 must be flowed down by the PO and confined to high volume components.
  2. I hear AS-13100 is a “higher” level document than AS-9100.  I understand that implementing AS-13100 requires a paradigm shift, but APQP and other statistical tools are only a part of a Quality System.  This seems to be backwards in my mind.
I would like to clarify one point you made. AS13100 is not a higher level document than AS9100. AS9100 is the baseline accreditation standard for the aerospace industry. The Aero Engines industry feels there are additional controls needed considering the complexity and safety considerations of the engine hardware; thus, there have always been unique customer specific requirements to address these needs. The vison of AS13100 is to replace the unique customer requirements and the initial release accomplished that to a large extent. More work to do but a great first step. 
1.0 Scope

I have a question pertaining to the applicability of AS13100 when it is fully implemented.

Once AS13100 is fully implemented, will the requirements related to APQP and the associated documentation be only applicable to new orders/part numbers?  Or will these requirements be retroactive and apply to legacy part numbers that have already been in continuous production?

Here is the AESQ position on the compliance to AS13100 question: 

Q. “Compliance to AS13100”, do we intend to have all new PO compliant and flowing by December 31, 2022, or do we intend that product being received will all be compliant by the December 31st date?” 

  • All AESQ Voting Members have agreed that they will be flowing AS13100 well before the compliance date of Dec 31, 2022. 
  • Supplier’s Quality Management System (QMS) must be updated to meet all the requirements of AS13100 and member company specific requirements prior to the December 31, 2022 deadline. Full compliance to Advanced Product Quality Planning (APQP) is required for all New Product Introductions (NPI) started after December 31, 2022. 
  • Suppliers are expected to use the next year+ to train their people, conduct the gap analysis and work towards full compliance. 
  • There may be exceptions at the December 31, 2022, deadline, but those exceptions shall be documented with a plan to close. 
3.0 (There is no definition in AS13100 for ALTERNATE INSPECTION FREQUENCY PLAN) Please consider adding the definition since the term is unique to the AESQ, and there already are definitions for the two types of Alternate Inspection Frequency Plans in AS13100. Also there is already a definition for this in RM13002. AS13100 Concerns/Comments
  1. Process Control (including inspection frequency) SMIG covers RM13002 and RM13006
  2. The proposed definitions (alternate inspection frequency plan, 100% inspection) were not included in AS13100 since they are addressed separately in the supporting documentation. 

3.0

(There is no definition in AS13100 for 100% INSPECTION) Please consider adding a definition since the term is unique to the AESQ, and it is already a definition in RM13002.
  1. Regarding the items related to reduced inspection and sample inspection, I will need to caucus with the relevant SMEs and provide you a response unless someone on this message thread provides a response sooner.
3.0

REDUCED INSPECTION
One of several levels of inspection connected by switching rules, which involves a lower fraction inspected than one or more of the others.
NOTE:  In such a system the quality parameter is usually the Average Outgoing Quality Limit (AOQL) and that AOQL is maintained, despite the lower fraction inspected, by the fact that the process generally only gets to that level when the quality is as good as or better than the AOQL for some period of time.
Where does this definition come from? I think it may be from AS9138 but I do not have access to this standard. Regardless, the term “reduced inspection” is used three times in AS13100 and this definition would not be appropriate for any of the three usages. 

Furthermore, para. 9.1.1.2, which contains the Alternate Inspection Frequency Plan Supplemental Requirements, does not even mention Reduced Inspection even though it clearly is one type of Alternate Inspection Frequency Plan. 

Also the definition of Reduced Inspection in RM13002 is very different than this one and it is the definition that I would expect (however I do not agree that the last sentence “Simply put its sampling within a part.” is either appropriate or accurate as I’m not sure what it adds but it conflicts with Table 3 Reduced Inspection of Variables. In the case of Reduced Inspection, only specific characteristics are allowed to not be inspected, and they are the same characteristics for all parts being produced – these specific characteristics are only those that are a sub-set of product characteristics that have a direct relationship to the conformance of the whole group, e.g., features created within the same operation such as a group of holes, drilled together where the first and last hole are used as controlling characteristics for the rest of the holes. – so there is clearly no “sampling” here). 

So is this definition a mistake and we should be telling students if the question comes up that they should refer to the definition in RM13002?

  1. Regarding the items related to reduced inspection and sample inspection, I will need to caucus with the relevant SMEs and provide you a response unless someone on this message thread provides a response sooner.

Regarding 9.1.1.2, I believe your summation statement is correct and I have added this item to the list of proposed changes for the next revision.

3.0 SAMPLE INSPECTION
A type of alternate frequency inspection plan. The inspection of selected characteristics on sampled parts from which the conformity of the same characteristics on other parts is inferred.
While I believe that this is an acceptable definition (the IAQG dictionary does not have the term defined, the closest would be Acceptance Sampling from AS9138), it says that it is a “type of alternate frequency inspection plan.” These words are in the wrong order, I believe it should read “A type of alternate inspection frequency plan.” Will this be corrected in the next revision?
  1. Regarding the items related to reduced inspection and sample inspection, I will need to caucus with the relevant SMEs and provide you a response unless someone on this message thread provides a response sooner.
     
4.2.1

I have a question about the requirements of AS13100_ 8.4.2.1  Type and Extent of Control - Supplemental Requirements ; 
"The organization shall develop a risk analysis and mitigation plan to be implemented between the supplier and the organization to deal with any restrictions to right of access to the supplier's facility. " 

Please provide specific examples of situations where a risk analysis and mitigation plan must be developed to deal with restrictions to right of access to the supplier's facilities. 
Should a risk analysis and mitigation plan be developed to deal with restrictions to the rights of access to the supplier's facilities???? 
 

Section 4.2.1 refers to the prime supplier who is receiving the AS13100 flow-down (typically from an OEM); this organization is responsible to ensure customers and regulators are able to fulfill their responsibilities for oversight

Section 8.4.2.1 refers to a prime supplier and their sub-tier suppliers and is intended to ensure the prime supplier has the necessary access to provide oversight.
 

4.2.1 Where access is restricted due to export control technical requirements or organization intellectual property concerns, the organization shall facilitate to allow the customer or regulatory agency to fulfil their mandate.
Question for AESQ: Elements prior to 4.3.1 are not in table 1. Is there a reason? Make these not applicable?
This is an error. The writing team will address this in a future revision. Obviously, section 4.2.1 applies to eall sources of supply where AS13100 has been invoked by a customer.
4.3.1

We are a supplier of barstock to casting industry (raw material melted into barstoc to be remelted by our customers).  We are excluded from Design and Development as we only work to customer specifications. 
We do not produce FAIR, we do not have part numbers or batch ID (naturally we have equivalent traceability system for our products).  Bottom line is that our physical product – barstoc – gets remelted at customers sites.

With regards to Chapter B and Chapter C of AS13100, we are struggling to determine how are they applicable to our processes (if at all, partly or in full)?  We never had to comply to AS9145 so I’m not 100% sure on the requirements there. 

We had recently completed a PPAP for our OEM customer however, this was at their request, utilizing their procedures. The questions is, do we have to have internal PPAP and APQP processes?  With all that said, we are happy to purchase the standard (AS9145) and work on the compliance, I’m just not sure to what extend we would need to implement requirements.

Part of me thinks we are excluded from both B & C chapters as we are not involved with any design.  On the other hand, things like process FMEA can be applicable (and I can see how we would benefit from it). Looking at page 77, Chapter C of AS13100 (Figure 6) I would say we only be able to adapt Phase 3, 4, and 5? However, it does specifically mention “The quality planning Tools shall be applied at part number level…” 
Is it “black and white” part number or should I read this and apply to our products as “applicable to us for each alloy type per customer” ? 

Raw material spurces are considered Type 5 per Table 1; as such, section 8.5.1.5 which invokes APQP is not applicable to Type 5 suppliers.
4.3.1 Questions regarding Distributor qualifications.  AS13100 Table 2 QMS certification, requires Type 3 Distributors to be a minimum of 9120 registration. Is the ASA100 certification equivalent to AS9120 for Distributors of aviation parts, materials and fasteners? I read in the internet that IAQG has an MOU with ASA and ASA is also a CB listed by IAQG. If so, could you please clarify the same? Suppliers who are accredited to ASA100 must also be certified to AS9120 to comply with AS13100 requirements.
4.3.1 Can ASA100 or equivalent aviation certifications that are approved by FAA/EASA suffice and if they currently supply materials to aviation/airline companies? Can they also be included in AS13100 or RM13007 for reference?
 
Suppliers who are accredited to ASA100 must also be certified to AS9120 to comply with AS13100 requirements.
4.3.1 If a part is a Single Source supply or a Source Controlled part (Supplier with name and address mentioned in Customer Drawing), and the procurement documents are traced back to the Single Source control supplier, can the procurement be done with the distributor who is not 9120 certified?  No. All distributors musrt be certified to AS9120.
4.3.1 Can a part/material be procured from another aerospace company (competitor) with CoC and relevant traceability documents to Mill, when referenced by the customer OEM in lieu of 9120 distributor certification?  Parts can be bought from sources other than distributors as long as all traceabiltiy information is provided by the source.
4.3.1 Can you please expand a little on the first issue concerning whether Distributors should be accredited to AS9100 or AS9120? I would have thought that too is straight forward – AS9120 . As I recall, at P&W we used to accept distributors that were AS9100 but the latest version of AS9120 had some additional requirements that are specifically for distributors that were not in AS9100 so AS9120 became the necessary requirement. What exactly is the concern? At our last class it came up and we were at a loss at how to explain/respond. The issue is that some voices within AESQ feel that Distributors buying Make to Print parts need to be certified to AS9100. I do not personally feel this is correct or appropriate. I expect the AS13100 standard will stay the same requiring AS9120 certification for distributors.
4.3.1 I have a question regarding QMS certification requirements as spelled out in Table 2 of AS13100 (2021-03).  My question deals specifically with a raw material distributor – say for instance, a company that procures large heat lots of raw bar stock and then resells that same bar stock at smaller quantities, etc.  Is a raw material distributor in this sense required to be AS9120 (as the table states for distributors in general), or are they required to be ISO 9001 as the table states for industry standard raw material manufacture?  Put another way, does an ISO 9001 requirement only apply to the original mill of the raw material, and any other purchase entering the aerospace industry would have to be from an AS9120 distributor, or an ‘end’ AS9100 manufacturer? Per AS13100, a distributor must be accredited to AS9120 regardless of the product being handled by the distributor UNLESS a customer requires a different accreditation for a distributor based on the product being handled by the distributor.
4.3.1 For “Production Shop Assist Only” organizations, the applicable elements of AS13100 requirements shall be as defined by the customer, based upon the scope of the work undertaken.
For Supplier types not listed in Table 1 refer to specific Customer requirements. Question for AESQ: Ask question about scope of suppliers and whether organization or customer detetermines sub-tier requirements.
Per the AS13100 definitions and stated requirements, the customer would determine the sub-tier requirements.
6.1.3

The organization shall implement a risk management process, e.g., ISO 31000, across their organization and put appropriate governance in place such that they:

  • Carry out a robust assessment of risks, in particular those that could threaten future performance, and detail these in a risk register.
  • Carry out a review of the effectiveness of their risk management system (including internal controls), at least annually.
  • Ensure appropriate risk mitigation is in place (including internal controls) that is appropriate to the risks identified.

Any input on this? Examples? One escape could be used by auditors to say the risk management process is not effective.

An escape would indicate the risk management process was not as effective as planned. The intent is to have a risk management process and ensure it includes the appropriate elements and is continually evolving to protect the organization and its customers
7.1.5.1.1

I have a question about clause 7.1.5.1.1 Measurement Systems Analysis (MSA) - Supplemental Requirements

What does "This should happen within the PFMEA" mean? 
Does it mean that the rationale for " MSA studies are not required " shall be stated in the PFMEA?
If yes, which column is more appropriate to write in?
If not, could you provide some concrete examples?

The clause being asked about is “The organization shall document the rationale where it has decided MSA studies are not required. This should happen within the PFMEA”

The reference to the PFMEA is to ensure that an organization that does not complete the MSA understands the risk of not understanding their measurement system.

Typically this would be its own failure mode, so would be a row on the PFMEA – the organization would then need to determine the Potential Failure Effects (of not doing an MSA), the Severity, Potential Causes, Occurrence scale, Current Controls and Detection.

7.2.1

Would you please find an expert to explain what does “agency personnel” mean? It is defined in paragraph 7.2.1 below?

Competence Achieved by On The Job Training - Supplemental Requirements
The organization shall provide on the job training in applicable requirements including customer, conformity to quality, internal, regulatory, or legislative requirements.
In addition to the organization employees, on the job training shall include contract, or agency personnel.

Agency personnel refers to employment agencies (usually referred as temporary) providing workers on a short-term basis; thus, the term temporary (or temp).
7.2.2

Regarding to the AS13100, para 7.2.2 and table 5. "The internal Lead auditor qualification"

Is there any training plan by AESQ or authorized training organisation could provide the training?

AESQ does not recommend a specific training source for AS131000, Table 5, Lead Auditor qualification.  However, there are many training sources available and, AESQ suggests searching online for a reputable training provider.
7.2.2

Regarding to the requirements inAS13100, para 7.2.2 & table 5. "The internal Lead auditor qualification"

Is there any training plan by AESQ or authorized training organization could provide the training? 

Since there is no authorized training organization in Taiwan, we got a quotation of training from Plexusin China, but not sure if the training meet the requirement of AS13100.

There are currently no plans for AESQ to conduct auditor training. This is consistent with previous input from Helen. I would expect this is on the FAQ list on the website.
7.2.4

As we explore compliance to AS13100 we are evaluating training programs. We are looking forward to participating in the SAE AS13100, course number PD532104. We are wanting to incorporate training for our organization and all the quality personnel. As you can imagine this will be quite the financial investment. One of the requirements under 7.2.4 of AS13100, states that equivalent training to the AESQ approved training, shall have an approved syllabi by AESQ. Specifically, “Equivalent training that meets the AESQ AS13100 Requirements and Quality Foundations course syllabi shall be approved by the AESQ.”. 

How would an organization proceed with getting their syllabi approved? 

AESQ has made the decision to NOT provide a training provider list outside of the AS13100 Requirements course and AS13100 Foundations course required by AS13100.
7.5.2.1

Where documented information contains reference to units of measure then they are to be recorded in the same units of measure as defined on the Product Definition.

Question for AESQ: defined on the Product Definition. Does this apply to all documents? Internal and external? Most common is metric to english conversions for internal documents/drawings.

This would apply to all documented information regardless if it is used internally or provided externally. The intent is to ensure there are no errors in measuring and reporting attributable to conversion.
7.5.3.5.2

I am working through the implementation of AS13100 and am having some difficulty in understanding the requirements of the clause.

“Original non-destructive evaluation/testing process related records including, but not limited to, radiographic film must be maintained, in accordance with the retention period specified in Table 8, by the source responsible for the final quality certification of the product, unless the source performing the non-destructive evaluation/testing activity is shipping direct to the customer on behalf of supplier.”

Our company is the final quality certification and shipment of the products we manufacture, upstream in our process parts are sub contracted for NDT. We as an organisation are not set up to store radiographic film and our sub-contractor will not release original records to us for retention as then they would be in breach of requirements.

I am struggling to resolve this clause and would appreciate any help and support that is available in understanding and moving forwards.

Unless otherwise specified by Customer requirements, the source shipping to an OEM is required to maintain the records related to nondestructive inspection/testing. Assuming the customer is an OEM, this should not be a problem for the source performing the nondestructive inspection/testing since they have adopted the AS13100 requirements. 
7.5.3.5.2 Would the Certificate of Conformity be classified as a suitable record related to non-destructive inspection/testing? The Certificate of Conformity (CofC) is a record requiring retention as specified along with other applicable non-destructive inspection/testing records (film, results, processing documentation, etc.).
8.2.3.3 My team had a question specifically on what new/additional requirements were added from the Contract/Contract review perspective. AS13100 section 8.2.3.3 was added to AS9100 contract review process requirements.
8.3.3.2

Purposed rewording for AS13100A Pg 42 Sec. 8.3.3.2:  

Current state: 
8.3.3.2 Design Risk Analysis - Supplemental Requirements 
When APQP has been required by the customer the organization shall conduct Design FMEA on the product design, see AS13100 - Chapter C (21), and RM13004. 

Since AS13100 is published, we cannot make any changes to it without doing a revision.  

I don’t think we want to go through that process for a minor clarification?

8.4.1.2

The supplier evaluation shall include the following topics, as applicable:

  • Engineering and manufacturing capabilities - capability to manufacture the product to be contracted and control changes to design and processes.
  • Quality control capabilities - capability to meet quality requirements and deliver conforming product.
  • Purchasing, planning and capacity - ability to meet current and future requirements considering all resources as well as management of the supply chain.
  • Commercial, legal, and environmental - ability to meet commercial, regulatory business and customer requirements.

NOTE: The Supplier Selection Capability Assessment Model (SSCAM) from IAQG provides a reference for supplier
evaluation.

Question to AEQS: This can't apply to every single supplier. We need clarification so we can keep activities minimal where supplier scope has no impact on product conformity or safety 

This does apply to all suppliers keeping in mind the significant risk introduced by the use of sub-tier suppliers.  While the standard is applicable to all suppliers, the level of evaluation and the scope of evaluation can, and may, vary as permitted by the standard based on the risks, product or process criticality, and expectations.
8.4.2.1

I have a question about the requirements of AS13100_ 8.4.2.1  Type and Extent of Control - Supplemental Requirements ; 
"The organization shall develop a risk analysis and mitigation plan to be implemented between the supplier and the organization to deal with any restrictions to right of access to the supplier's facility. " 

Please provide specific examples of situations where a risk analysis and mitigation plan must be developed to deal with restrictions to right of access to the supplier's facilities. 
Should a risk analysis and mitigation plan be developed to deal with restrictions to the rights of access to the supplier's facilities???? 

On the other hand, Section 4.2.1 states 
"Where access is restricted due to export control technical requirements or organization intellectual property concerns, the organization shall facilitate to allow the customer or regulatory agency to fulfil their mandate", and the word "facilitate to allow" is used. 

Why is there a difference between "develope a risk analysis and mitigation plan" and "facilitate to allow" in the "organization-customer" and "organization-supplier" relationships as a response to access restrictions? 

Does a mitigation plan mean a condition to enter the restricted area or to view(see,check, inspect) the restricted area without entering it? 

Section 4.2.1 refers to the prime supplier who is receiving the AS13100 flow-down (typically from an OEM); this organization is responsible to ensure customers and regulators are able to fulfill their responsibilities for oversight

Section 8.4.2.1 refers to a prime supplier and their sub-tier suppliers and is intended to ensure the prime supplier has the necessary access to provide oversight.

8.4.2.3

The requirement in 8.4.2.3 have a header “Material and Special Process”
But in table 2, the requirement is not applicable for a type 4 supplier (Special process)
This seems strange.

Looking back in my notes, I see that in the applicability table from AS13100 draft N, 8.4.2.8 was applicable for type 4. I was working with this table at that time- that is why I have the old notes.

Table 1 is in error and will need to be corrected. We can discuss if this is important enough to warrant a revision but I don’t think so. I have captured the issue in a running list of proposed changes.
8.4.2.3

Material and Special Process Test results shall reflect all requirements of the drawing and/or specification and conform to drawing and/or specification limits. Documented evidence of this conformity including listing of each material element or test result in the applicable test report.

We need to find out from AESQ what all falls under "Special Process Test". We do internal tests/inspections and also send samples out for testing. Does this apply to both?

Any test required by a special process source would fall into this category. Examples include testing performed for a coating process or a thermal process.
8.5.1.1.1 Control of Equipment, Tools, and Software - Supplemental Requirements
Verification of software for automated inspection (e.g., CMM) by correlation of the test results with the results from an independent method of inspection.
Q1: If two individuals operate two separate CMMs to measure the same object (article or part) to verify the software of the automatic inspection equipment, can it be demonstrated that it meets the requirements of the clause 8.5.1.1.1 ?
Q2: For the "an independent method" described in the clause 8.5.1.1.1, could you able to provide other examples that can demonstrate compliance with the requirements ?
8.5.1.1.1 Control of Equipment, Tools, and Software - Supplemental Requirements
Verification of software for automated inspection (e.g., CMM) by correlation of the test results with the results from an independent method of inspection.
Q1: If two individuals operate two separate CMMs to measure the same object (article or part) to verify the software of the automatic inspection equipment, can it be demonstrated that it meets the requirements of the clause 8.5.1.1.1 ? LB response: your proposal meets the intent of this clause assuming the software on the two programs are independent.
Q2: For the "an independent method" described in the clause 8.5.1.1.1, could you able to provide other examples that can demonstrate compliance with the requirements ? LB response: another alternative to CMM would be a manual inspection method or other electronic gaging method (e.g., Faro).
8.5.1.1.1

We are an industry standard raw materials manufacturer (steel) in the UK and have a question about the applicability of a section from the upcoming AS13100 specification.

Regarding section 8.5.1.1.1 Control of Equipment, Tools, and Software - Supplemental Requirements, it states;
A Software Quality Assurance program for all nondeliverable software shall be implemented, documented, and maintained. (a list of items that must be included follows in the specification – please see pages 46-48)

Our IT department are unclear on the applicability of the clause in regards to internal software and have come back with the below response;
‘we considered that this is related to the control equipment (eg the equipment which Instron use on the tensile test machines, rather than our IT general IT infrastructure. We are not convinced this applies to tracking systems etc though’

Could we please be provided with clarification on the specifics of what level of software needs to be considered for this clause?

Thank you for your inquiry. Regarding AS13100 Section 8.5.1.1 requirements, the definition provided in the standard for nondeliverable software is: “software that directly relates to design, manufacture, inspection, test, or calibration of a deliverable product and directly affects the configuration, conformity, or quality of  deliverable product.”
 
Examples of nondeliverable software include machine and inspection computer programs, used in Coordinate Measuring Machines, CNC machines and other similar applications. The expectation is that the software (program) used to design, manufacture, inspect, test or calibrate is controlled and managed as required in the AS13100 standard.
8.5.1.4.1 I want clarification on the use of a spectrometer.  If I am reading it correctly,  we need to use a spectrometer of equivalent electronic material verifying device to verify material.  We can no longer use provided C of C’s from the material manufacturer? The intent of the material verification is to ensure the proper metallic raw material is pulled from inventory for production processing. The material verification is in addition to your typical receiving inspection function/tasks where certifications are reviewed and approved. The risk and impact to the industry is when suppliers put material in inventory and pull the wrong material. Thus, the verification requirement at the point of use.
8.5.1.4.1

How does 8.5.1.4.1 apply to customer supplied material? The material comes in either pre-machined or as castings. We have one site that does not get raw material. 

So when the material is customer supplied, we still need to verify that the material is as stated on the receiver, (or if the customer give the info another way) using a spectrometer or equivalent? (guessing yes).  

Regarding AS13100 section 8.5.1.4.1, the requirement does apply to pre-machined and castings unless each item is traceable to a unique identifier (serial number, lot number).

It would depend on the customer and if they had requirements for handling customer supplied material or not. For example, the GE requirement for customer supplied material states: “the supplier shall verify that the material arrived in good condition. No over inspection or certificates are required; however, evidence is required that the material was shipped from a GE facility, i.e., Shipping Document. 
I cannot speak for other potential customer’s requirements.

8.5.1.4.1

I have a question about a requirement in AS13100 below.  I am keen to understand where this requirement came from.  Can you forward to the handling team to question this requirement

If we could get some clarity on the requirement and the potential for cleaning up the language that would be great.

The capability of the equipment and the ability to use it to determine a specific alloy is definitely questionable outside of a lab.  The MSA is less of a concern to me than whether the equipment can really identify a specific alloy.

I haven’t responded to this, however, it would appear that the intent is to measure 100 of incoming raw material with handheld spectrometry devices, although it reads as if the 1st and second bullets are somewhat contradictory.  I don’t believe that this is standard practice, nor am I aware of any devices of this nature in use in our receipt inspection areas.   

What is your reaction to reading this based on GRR on hand held devices to measure material content. 

This requirement has been a long standing requirement for GE Aviation as a result of several significant escapes caused by mixed material or improper material.

The requirement was adopted by the AS13100 writing team and was socialized across all the voting member organizations and voted to accept. I’m confident Dr. Riggs socialized this to the necessary stakeholders within the Rolls-Royce organization as part of the vetting and voting processes.

The requirement applies to raw material which is placed in inventory and pulled at a time later than the material receipt. This chain of custody is the prime reason for mixed or improper material and, thus, the requirement.

It is not intended to be a replacement for the established receiving inspection process where material certification review occurs; although some sources use the equipment as part of their receiving inspection process as well depending on the equipment purchased and its capabilities. 
 

8.5.1.4.1

The organization shall have a process to verify the correct metallic raw material is used when issued for production or concurrent with the start of the first operational process step:

  • The intent of the requirement is not to measure or control the manufacture of raw material but to ensure the material input at the part manufacturer is correct:
    • Product with a unique identifier (e.g., serial number, lot number) are excluded from this requirement.
    • This requirement does not apply to hardware (fasteners, bolts, nuts) or standard components at the point of assembly.
  • Ensuring handheld spectrometry devices, or equivalent, are utilized to verify 100% of material. Industry sampling plans or equivalent zero-based acceptance sampling plans may only be used for high volume purchases of material.

Question: Is there a definition of high versus low volume?

The sampling plan is not intended to mean periodically re-verifying material. It is meant to address material that may be received in large lots.  The supplier should verify with a spectrometer, or equivalent, 100% of material, or an acceptable sample of that lot per an industry sampling plan.

The intent is for a high volume supplier to be able to apply a rational sampling plan to their situation. For example, a supplier gets 5,000 “pucks” for a part manufacture. It is unreasonable to expect they will inspect all 5,000. Thus, a rational sampling plan can be used and meet the intent . There is no black and white answer on the quantity break between 100 % and sampling. It would depend on the specific supplier, the lot integrity of the raw material, the control systems in play at the supplier, etc.

A typical metal manufacturer would need to account for 100% of material as required unless; for instance, they receive 500 pieces in one lot of bar stock, they would not have to inspect all 500 pieces with the spectrometer, but a sufficient sample of them per the industry standard.

The sampling plan would not require formal approval but it is a good practice for the supplier to review with their assigned PQE to ensure their approach is sound.

8.5.1.4.1 We have been working to meet the new requirement of AS13100 and have a question concerning APQP requirement. We are a contract manufacture and do not own design. The process map in the standard show phase 3 as having some area under the APQP line.

This requirement has been a long standing requirement for GE Aviation as a result of several significant escapes caused by mixed material or improper material. The requirement was adopted by the AS13100 writing team and was socialized across all the voting member organizations and voted to accept. 

The requirement applies to raw material which is placed in inventory and pulled at a time later than the material receipt. This chain of custody is the prime reason for mixed or improper material and, thus, the requirement.
It is not intended to be a replacement for the established receiving inspection process where material certification review occurs; although some sources use the equipment as part of their receiving inspection process as well depending on the equipment purchased and its capabilities.

8.5.1.4.2

The organization, when applicable shall have a documented process for managing the transfer of approved Product Definition from the Design Organization to the Production Organization, including prototypes. The documented process identifying the product definition is approved by the customer.

Question during the training session. What does this mean exactly?

The intent of thjs requirement is to ensure the product definiton is protected, controlled and managed through distribution of the supply chain.
8.5.1.4.3 2-    Para. 8.5.1.4.3 states: The organization shall:
Ensure 100% verification of all product characteristics in their final condition, i.e., at a stage where it is ensured that subsequent processing cannot affect the product characteristic verification result. This is not required for purchased standard catalogue hardware. Sample or reduced inspection being applied in accordance with alternative inspection infrequency plan requirements (9.1.1.2).
This paragraph is very clear, it requires 100% inspection unless there is an alternate frequency inspection plan, be it a sample inspection, or reduced inspection, or a combination of both sample and reduced inspection. However when we look at 9.1.1.2…..
Regarding 9.1.1.2, I believe your summation statement is correct and I have added this item to the list of proposed changes for the next revision.
8.5.1.5 I really appreciate the FAQ section pertaining to AS13100, I would like to ask a question but do not see the link or app.
Q1. As a contract manufacturer are we required to perform and formally document an APQP process?
Q2. Will the requirements including APQP be stated in the RFQ? 
Sources are required to meet AS3100 requirements including APQP elements as flowed down by your customers. 
8.5.1.8

The organization shall:
Ensure non-NDT personnel engaged in product verification and inspection activities are examined annually. Eyesight acuity requirements being a minimum of Curpax N5, Jaeger #2, or equivalent in at least one eye or when using both eyes together. These non-NDT inspectors shall also be required to pass a one-time color vision perception test.

Question for AESQ: Is this for final acceptance only or all in-process inspections?

This is required for all inspections performed.
8.5.1.8 This is required for all inspections performed. This requirement is to ensure individuals wearing vision correcting eyewear (glasses, contacts) are re-examined when their eyewear prescription changes.
The AS13100 writing team will review this requirement for clarity as part of the next revison draft.
8.5.1.9

I have a question about AS13100 section 8.5.1.9, bullet 3.  
“Have a documented Operator Self-Verification Program that conforms to 9162 requirements.”

Please correct me if I am wrong but this is a cancelled Spec, according to the SAE site here:

ARP9162A: Aerospace Operator Self-Verification Programs - SAE International

Please let me know as we are almost thru all of our gap assessments.

AS9162 is an active, valid specification. I found it in our subscription in IHS. 
8.5.1.9

Personnel responsible for the review of material and special process test reports shall be trained to read, interpret and evaluate test results for the purpose of assuring that all drawing and/or specification requirements of the final product are met.

Question for AESQ: What all falls under the definition "Special Process Test"?
We have internal special processes and send samples to external parties for expert testing and reporting.  

Any test required by a special process source would fall into this category. Examples include testing performed for a coating process or a thermal process.
8.5.1.9

The method employed to evaluate material and special process test report results shall be documented and provided for the review of each test, as required, per the applicable drawing and/or specification. The methodology to be employed may be subject to customer approval.

Question for AESQ: We do internal special processing inspection/test, but do not issue test reports.  Is this now required?

The intent of this requirement is to ensure the organization has provided training to the individuals who are responsible to review incoming documentation or internally created documentation (e.g., raw material and special process certifications, test reports).
8.5.2.1

The supplier shall establish and maintain an effective FOD prevention program that meets the requirements of 9146.

Question to AEQS: To what extent do the requirement apply to subtier suppliers?  These are many levels away from the finish product stage.  This will lead to increased cost and challenges to keep suppliers.

Foreign Object Debis (FOd) and Foreign Object Damage (FOD) is amjor concern in the Aero Engines industry. It is necessary for all levels of the organization's supply chain to ensure practices, policies and behavior are effctive to eliminate conditions that could contribute to FOd and FOD.
8.5.6.1

What changes/issues can come from a shift change or handover?  

What control is the spec looking for?

There are a number of concerns with shift change and handover of tasks including part traceability, status of job and parts actively being run, process performance, nonconforming material status, escalation routine and resource availability for issues that may arise.

Control of the process during shift changes and during off-shift activity. There have been many incidents where it wasn’t clear what the status of the parts were; issues with process documentation accuracy (part counts, sequence sign-off),  and control and identification of nonconforming material. In addition, it is challenging for off-shift personnel with limited support; thus, the need to ensure access to resources (people, equipment) and information along with a clear escalation and resolution process when issues arise.

8.6.1 Release of Products and Services - Supplemental Requirements  
“Controls to manage the risks associated with “releasing products and services at risk” shall be documented by the organization and define the key accountabilities to ensure that the required controls are implemented, including those of external
stakeholders.” & “Product subject to Risk Release shall be clearly identified as being subject to Risk Release with traceability to the approval document.”
Q1: What is the meaning of "releasing products and services at risk"? Is it a product that has its own risk? Such as: some electrostatic sensitive components in aero engines. Or does it mean managing the risks of "product release activities"? Such as: release the non-conforming product to the customer?
Q2: Does "Risk Release" refer to the risk of product release activities? Could you provide some examples to better understand the requirements of clause 8.6.1?
 
8.6.1 Release of Products and Services - Supplemental Requirements  
“Controls to manage the risks associated with “releasing products and services at risk” shall be documented by the organization and define the key accountabilities to ensure that the required controls are implemented, including those of external
stakeholders.” & “Product subject to Risk Release shall be clearly identified as being subject to Risk Release with traceability to the approval document.”
Q1: What is the meaning of "releasing products and services at risk"? Is it a product that has its own risk? Such as: some electrostatic sensitive components in aero engines. Or does it mean managing the risks of "product release activities"? Such as: release the non-conforming product to the customer? LB response: 8.6.1 relates to risk release of hardware or services; moving product or service beyond a point of manufacture or inspection/test and not having required process or service output (e.g., testing, documentation, certification) to fully approve the operation.
Q2: Does "Risk Release" refer to the risk of product release activities? Could you provide some examples to better understand the requirements of clause 8.6.1? LB response: in concert with Q1 response above, an example would be: operation 10 is a furnace operation and the hardness results are not available because the required test equipment is out of calibration. The product is processed to operation 20 “at risk” due to the open faults from operation 10.
8.6.1 This spec is addressing risk release.  I have a couple of sites that consider risk release as a “partial shipment” and that’s it. 
There are others ( like me) that considers risk release as a part or service that does not comply to print req. but are being accepted on concession by the cust.
Please let me know which (if not both) are correct.
AS13100 8.6.1 relates to all risk releases including internal release of hardware (e.g., moving product from operation to operation with incomplete certifications) and external release to another supplier or to a customer. If nonconforming product is involved, ensure applicable unique customer requirements are addressed.
8.7 Please can you clarify, if there is a standard format for suppliers to use to inform their customer/s of a Notice of Escape (NoE) ?
If yes, where can this be found?
If not, is this something that is being worked on by the AESQ team or is being considered ? Could we make a proposal ?
There is not currently a prescribed form for escape reporting. It is assumed each OEM has their preferred process/document. 
9.1.1.2

In 9.1.1.2 it states:
Product acceptance for design characteristics shall be 100% inspection unless customer specific sampling plans are flowed down to the organization, or the customer has an approved alternate sampling plan for use by the organization.
Could you please explain the exact intent of this sentence? 

  1. I can understand the first part is trying to state that all product characteristics on all parts must be inspected (which seems to be a duplication of the requirement already made in 8.5.1.4.3 and duplicating requirements should be avoided in the same standard – also this portion is grammatically incorrect). 
  2. However, it is the “unless” part that has me perplexed. In the second (middle) part of this sentence, how can customer specific sampling plans be realistically flowed down to the organization? Sampling plans must be based on statistical process control – how does the customer know the supplier’s exact production process, which characteristics are being recorded for SPC, and when the output from a supplier’s process has attained statistical control and is stable with a capability >1.33 so that sampling can even begin? Am I missing something? Which OEM(s) is doing this and how exactly do they do it? 
  3. Now the 3rd and last part states that “or the customer has an approved alternate sampling plan for use by the organization.” – how/why would a customer have an approved alternate sampling plan? Isn’t the intent supposed to be “unless the organization has a customer approved alternate sampling plan? And why is it being limited to sampling plans, shouldn’t reduced inspection plans also be included? Why not simply use the term alternate inspection frequency plan? 

The Customer shall specify the method of obtaining documented approval, as applicable. Where specific customer sampling plans are not flowed down, see RM13002 for guidance on alternate inspection frequency options. The AS13100 requirements are not intended for customers, these are requirements for suppliers so I am assuming that the first sentence of this paragraph is trying to say something like “The organization shall use the customer defined alternate inspection frequency plan submission process to obtain documented approval for any proposed sample inspection or reduced inspection plans.” (or it could use alternate inspection frequency plans that covers both types). 

With the second sentence, again here I am unsure of how a customer can realistically be flowing down specific sampling plans to suppliers – please see my same question above. Again there is no mention of reduced inspection plans.

For these two paragraphs of 9.1.1.2, is the overall intent simply that; The organization shall include all requirements of the Design Record when developing the inspection/test plan and apply 100% inspection unless approval is obtained by the organization for an alternate inspection frequency, see RM13002 ?
(This is not my own wording….it actually comes from paragraph 16.5.10 so the standard is actually triplicating the same requirement - this needs to be addressed in the next revision.)

In 9.1.1.2 it states:
Product acceptance for design characteristics shall be 100% inspection unless customer specific sampling plans are flowed down to the organization, or the customer has an approved alternate sampling plan for use by the organization.
Could you please explain the exact intent of this sentence? 

a)    I can understand the first part is trying to state that all product characteristics on all parts must be inspected (which seems to be a duplication of the requirement already made in 8.5.1.4.3 and duplicating requirements should be avoided in the same standard – also this portion is grammatically incorrect). 

b)    However, it is the “unless” part that has me perplexed. In the second (middle) part of this sentence, how can customer specific sampling plans be realistically flowed down to the organization? Sampling plans must be based on statistical process control – how does the customer know the supplier’s exact production process, which characteristics are being recorded for SPC, and when the output from a supplier’s process has attained statistical control and is stable with a capability >1.33 so that sampling can even begin? Am I missing something? Which OEM(s) is doing this and how exactly do they do it? 

c)    Now the 3rd and last part states that “or the customer has an approved alternate sampling plan for use by the organization.” – how/why would a customer have an approved alternate sampling plan? Isn’t the intent supposed to be “unless the organization has a customer approved alternate sampling plan? And why is it being limited to sampling plans, shouldn’t reduced inspection plans also be included? Why not simply use the term alternate inspection frequency plan? 

The Customer shall specify the method of obtaining documented approval, as applicable. Where specific customer sampling plans are not flowed down, see RM13002 for guidance on alternate inspection frequency options. The AS13100 requirements are not intended for customers, these are requirements for suppliers so I am assuming that the first sentence of this paragraph is trying to say something like “The organization shall use the customer defined alternate inspection frequency plan submission process to obtain documented approval for any proposed sample inspection or reduced inspection plans.” (or it could use alternate inspection frequency plans that covers both types). 

With the second sentence, again here I am unsure of how a customer can realistically be flowing down specific sampling plans to suppliers – please see my same question above. Again there is no mention of reduced inspection plans.

For these two paragraphs of 9.1.1.2, is the overall intent simply that; The organization shall include all requirements of the Design Record when developing the inspection/test plan and apply 100% inspection unless approval is obtained by the organization for an alternate inspection frequency, see RM13002 ?
(This is not my own wording….it actually comes from paragraph 16.5.10 so the standard is actually triplicating the same requirement - this needs to be addressed in the next revision.)

9.1.1.3  am looking for some guidance for AS13100 9.1.1.3.  It references RM13006 statistical concepts, and the training that is needed listed in appendix C.
I would like to know if there is something that AESQ has or will have that will help with this training? It does reference six sigma or ASQ training however,
If we do not have any of those,  what would be your suggestion for this?
The AESQ website has a list of approved training providers.  Also, you should investigate courses covered at your local community colleges.  One excellent online source that is very inexpensive yet high quality is the Quality Training Portal with courses such as Basic SPC/Advanced SPC/Gage Capability-MSA/PFMEA/Mistake Proofing/8D Problem Solving, basically courses that support the AESQ AS13100 Chapter 2 and 3 sections quite nicely.  https://qualitytrainingportal.com/
9.2.3

In AS13100, sect 9.2.3, 3 paragraphs after table 9 shows the following:
“The Production Process Audit shall be conducted using an approved checklist, e.g., VDA6.3 checklist (2.4), or equivalent, see RM13005”
So working with my QM, he is asking “ who approves the checklist?”  I said the checklist in RM13005. But to him, that is not official enough and thinks that if HE approves the checklist, that is enough. I don’t think so but that is why I am asking you. 😊

Also, the link for the check list in RM13005 is a dead link.  Do you have a working one?

Dead link: https://aesq.sae-itc.com/content/aesq-documents  (page 25)

Thanks for the questions and the effort to read and understand the requirements; here are my responses:
The approved checklist is the VDA6.3 or equivalent. The RM13005 guidance was intended to provide a roadmap for organizations to determine if an existing process satisfies the equivalency allowance in AS13100 9.2.3

Not sure what happened with the link in Appendix D of RM13005 but it does not work. File names may have changed with application or website updates possibly.

9.2.3 We are going through the flowdown to AS13100 and there is a question: If we have special process like welding, which is performed by three different units then we should audit welding for one of them and the welding process is considered audited or we have to audit all of our three units, which performed welding and only then the process welding is considered audited? Based on the AS13100 section 9.2.3 requirements, the checklist used is dependent on whether the welding process is Nadcap certified or not. I would expect each welding unit to be audited; if they are identical in terms of process and control, one could be representative of all three. At minimum, all should be audited over time.
10.2.3

The organization shall analyze the causes of each type of nonconformity and determine risk based prioritized improvement plans to continually improve performance (10.3.1).

Question to AESQ: "type of nonconformity" needs definition. Causes are addressed during CAPA or low risk so what additional activities are needed?

The intent in this requirement is to look at nonconformities on a larger cale than the individual causes for each event. By grouping nonconformities by type (e.g., 6M codes) gives an opportunity to use a pareto or similar statistical tools to prioritize improvement plans.
10.2.3

This question requests clarification of the extent of application of full 8D (D0 – D8).  Within the first paragraph of AS13100 10.2.3 it states “When a nonconforming product escapes to the customer and where the organization is required to conduct a problem investigation by the customer then the default problem solving methodology shall be the 8D Problem Solving process approach (steps D0 to D8), see RM13000”

Question: Who is the customer in this context?  
Is it only:  The next organisation in the supply chain e.g., the OEM receiving product from a first tier / a first tier receiving product from a second tier?

Or is it also:
An internal customer within a manufacturing process from where non-conformance has been received e.g., an inspection area receiving non-conformance from a machining process area?

The reason for this question is because the definition of Customer within AS13100 does not specifically help;
CUSTOMER: Organization, legal entity, or person that receives a product or service (e.g., consumer, client, end-user, retailer, beneficiary, purchaser).

The customer is the organization that flowed down AS13100 requirements to the source; typically, an OEM.
10.2.4

The organization shall perform analysis on customer complaints and initiate problem solving and corrective action to prevent reoccurrence.

Question to AESQ: Does this apply to every customer concern/complaint? Risk based used to allow not having to do full corrective action for a low impact customer concern/complaint.

The requirement is to analyze customer compliants and take action to prevent recurrence. The intent in this requirement is to look at customer complaints on a larger cale than the individual causes for each event. By grouping nonconformities by type (e.g., 6M codes) gives an opportunity to use a pareto or similar statistical tools to prioritize improvement plans.
10.2.4

AS13100, 10.2.4:  Customer Complaints and In-Service Failures - Supplemental Requirements

The organization shall perform analysis on customer complaints and initiate problem solving and corrective action to prevent reoccurrence.

To the extent contractually agreed between the organization and the customer, the organization shall:

  • Perform analysis on in-service failures of products that the organization has designed and initiate problem solving and corrective action to prevent reoccurrence.
  • Include analysis of any interaction of embedded software of the organization's product within the system of the customer's product.
  • Communicate the results of analysis to the customer and within the organization.

For the highlighted paragraph, if I understand correctly, if we did NOT design the failed product, this whole spec does not apply to us. We are make to print, is my thinking correct on this?

AS13100 Section 10.2.4 has an opening statement that applies to all types of organizations. The next set of requirements are conditional as stated (to the extent contractually required) and based on the type of organization.

 

 

 

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