Quality Name Plate AS9100 Quality System


QNP AS9100 Main Index

 

 


Counterfeit Avoidance and Mitigation

Counterfeit Avoidance and Mitigation: OP-743-02 rev -

Effective Date:2-19-16
Owner Approval by Andrew Adams, Quality Assurance Manager, on 2-15-16
Management Approval by Craig O. Garneau, President, on 2-15-16

Printed copies of this document are for information purposes only and are uncontrolled. Printed copies are not valid after the date of printing. This document was printed on


1.       PURPOSE

The purpose of this procedure is to describe the process and due diligence performed by Quality Name Plate, Inc. (QNP) to prevent the purchase and/or use of counterfeit material and meet the requirements of AS6174 Standard for Counterfeit Material, Assuring Acquisition and Conforming Material.   

2.       ISO REFERENCE

AS9100, Clause 7.4.3

3.       SCOPE

This procedure is applicable to all procured materials that are used to manufacture any Quality Name Plate product. 

4.       TERMS AND DEFINITIONS

4.1.    Material - Material in this procedure refers to material, parts, assemblies, and other procured items.

4.2.    Manufacturer – Manufacturer in this procedure refers to the point of origin of any material covered by the AS6174 standard, including factories, mills, foundries, mines, chemical plates, laboratories, etc.

4.3.    Suspect Material – Material, items, or products in which there is an indication by visual inspection, testing, or other information that it may meet the definition of fraudulent material or counterfeit material provided below.

4.4.    Fraudulent Material – Suspect material misrepresented to the customer as meeting the customer’s requirement.

4.5.    Counterfeit Material – Fraudulent material that has been confirmed to be a copy, imitation or substitute that has been represented, identified, or marked as genuine, and/or altered by a source without legal right with intent to mislead, deceive or defraud.

4.6.    Broker Distributor – A type of independent distributor that works in a “Just in Time” (JIT) environment.  Customers contact the broker distributor with requirements identifying information such as the part number, quantity, target price, and date required.  The broker distributor searches the industry and locates parts or other material that meet the target price and other customer requirements.

4.7.    Certification of Conformance (CoC) – A document provided by a supplier formally declaring that all buyer purchase order requirements have been met.  The document may include information such as manufacture, distributor, quantity, lot and/or date code, inspection date, etc., and is signed by a responsible part for the supplier.

4.8.    Open Market – The trading market that buys or consigns primarily original manufactures’ and contract manufactures’ excess inventories of new material and subsequently utilizes these inventories to fulfill supply needs of other original manufactures and contract manufactures, often due to urgent or obsolete material demands.

 

5.       GENERAL

5.1.    The Quality Manager is responsible for implementation, oversight and training related to this document.  All QNP employees involved in procurement, engineering, receiving and inspection activities are responsible to comply with the requirements and processes identified in this document.

5.2.    Engineering is responsible to ensure the drawing, specification, process, or other description identifies the applicable type, class, style, part number, manufacture, or other related information so the correct product is identified.

5.3.    Purchasing is responsible to procure the correct part/material using the applicable drawing, specification, description, Engineer’s guidance or other information to ensure the product meets the customer’s requirements and the intended use.

5.4.    Receiving/Inspection is responsible to examine, inspect, and/or control the parts/material to identify or mitigate the receipt and/or use of counterfeit parts/material.

 

6.       PROCEDURE

The processes shall maximize availability of authentic, originally designed and/or qualified parts/material throughout the product’s life cycle, including management of part/material obsolescence.  Additional information and guidance for ensuring parts/material availability is provided in AS6174.

6.1.    Purchasing shall examine a potential source of supply to assess the risk of receiving counterfeit parts/material.  Assessment may be a review of supplier website, survey, audit, product alert review, or a review of the internal supplier quality data to verify past performance.  The goals is to ensure that approved sources of supply are maintaining effective processes for mitigating the risks of supplying counterfeit parts/material.

6.2.    Purchasing shall maintain a list of approved suppliers along with their scope of approval in order to minimize the risk associated with the supply and/or receipt of counterfeit parts/material.  Reference Approved Vendor/Subcontractor List FM-741-02

6.3.    Purchasing shall place a priority on obtaining material direct from the mill source, original manufactures, authorized suppliers, or other legally authorized sources on the approved supplier/source register/list.

6.4.    Purchasing shall specify on the Purchase Order that the contractor should include with each shipment the raw materials manufacture’s test report and/or certification (e.g., mill test report) that states the lot of material furnished has been tested, inspected and found to be in compliance with the applicable material specification.  The test specimen should come from the same thickness/diameter that is being supplied. 

6.5.    Purchasing shall flow the following information on the Purchase Order as applicable:

a)      Specifications including revision numbers or letters to which the material has been tested and/or inspected to

b)      Heat or Lot numbers

c)       When the material specifications requires quantitative limits for chemical, mechanical, or physical properties, the test report shall contain the actual test and/or inspected values contained.

6.6.    Purchasing shall require the manufacture provide certification with each shipment, to demonstrate that all required processing (e.g., forming, heat treating, thermal cycling, conversation, etc.) has occurred and the results meet all specification and testing requirements. 

6.7.    If the material was altered (e.g., forged, rolled, heat treated, etc.) subsequent to procurement from the original material source and prior to delivery, the manufacture should provide with each shipment an independent laboratory test certifying that the material complies with the requirements and the test report should contain all of the following information:

a)      Lot/heat/batch/date code

b)      Purchase order number under which material was supplied

6.8.    Receiving inspection shall examine the CoC or other documentation for authenticity and applicability to the delivered material, including:

a)      Lot and/or date codes on the packaging do not match the lot and/or date codes on the material

b)      Review of logos, trademarks and other identifying marks to ensure they match manufactures’ marks as applicable.

c)       Changes to or irregularities in the documentation and/or paper trail

d)      Material identification on the CoC or other document does not match the material identification on the Purchase Order.

e)      Materials are inconsistent with the description on the supplied documentation

If there is an elevated concern for product integrity, it may be possible to verify with the manufacture that date, lot codes, heat number, thickness listed on the CoC or other documentation are valid.

6.9.    QNP Quality Manager shall notify the customer within 24 hours if QNP becomes aware or suspects that it has furnished counterfeit product.  Format and method of communication shall be based on customer requirements.

 

7.       CONTROL OF SCRAP OR SUSPECT MATERIAL

7.1.    Scrap Material

Material that has been found to be nonconforming or otherwise unsuitable for use shall be controlled per OP-830-01 Control of Non-Conforming Product

7.2.    Control of Suspect of Confirmed Counterfeit Material

In the event that product assurance actions, in-process inspections/tests, or product failure experiences indicate that material may be counterfeit, the following steps should be implemented:

a)      Physically identify the material as suspect/counterfeit material (e.g., tag, label, mark).

b)      Physically segregate the material from acceptable non-suspect material and place in quarantine.  Quarantine should consist of physical barriers and controlled access.

c)       Do not return the material to the supplier for refund, replacement, etc., except under controlled conditions which would preclude resale of the suspect counterfeit material into the supply chain, and to allow the supplier to conduct internal investigation.

d)      Confirm conclusively the authenticity of the material.  This may include further tests, communications with the materials supposed manufacturer, third-party analysis, etc.

e)      Upon confirmation that material is counterfeit, identify and place “HOLD” all potential additional counterfeit material in storage and used in product pending disposition by appropriate authorities.

f)       Report counterfeit material to the appropriate regulatory agencies.

a.       E.g.: Government Industry Data Exchange Program (GIDEP)

 

 

Source

How Likely is the Risk Cause to Occur?

Recommended Surveillance Frequency

Counterfeit Risk Cause Likelihood

Distributor with a history of providing suspect counterfeit material, fraudulent activity

It is likely to occur

Quarterly

High

Performance data shows evidence of an inability to meet the contractual requirements.

The material is extremely difficult to obtain

Open Market Purchase

It is probable or likely to occur.

Semiannually

Medium

Non-Authorized/Non-Franchised Distributor

No data available to show the suppliers' ability to meet contractual requirements

Semiannually

Non-Authorized/Non-Franchised Distributor with a proven track record
Qualified Testing Suppliers List
Qualified Suppliers List of Distributors

The material is somewhat difficult to obtain

Semiannually

Authorized or Franchised Distributors

It is unlikely that the risk will occur

Annually

Low

Qualified Manufactures List
Manufacture on the Qualified Products List
Original Equipment Manufactures

Performance data shows evidence that the contractual requirements will be met.

Annually

Original Component Manufactures
Original manufactures

It is a common material and not difficult to obtain.

Annually

 

                Figure 1 – COUNTERFEITING OCCURRENCE RISK ASSESSMENT MODEL

 

8.       RELATED DOCUMENTATION

8.1.    FM-741-02, Approved Vendor/Subcontractor List

8.2.    OP-830-01, Control of Non-Conforming Product

8.3.    AS 6174, Counterfeit Materiel; Assuring Acquisition of Authentic and Conforming Materiel

 

RECORDS/OBJECTIVE EVIDENCE

The retention duration for records referenced in this procedure are available on-line in the FM-423-01 Master Document List with Revision History.
Records are maintained in accordance with OP-424-01 Control of Quality Records.


REVISION HISTORY

Revision, approved date, effective date, and a document change summary for this document is located on-line in the FM-423-01 Master Document List with Revision History.