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AS 9100

AS 9100 Quality Management Systems - Preventing Counterfeit Parts

The AS 9100 Revision D standard contains numerous additional requirements specific to the Aerospace, Space and Defence industries and in today's article we will be looking at Counterfeit Parts.

What is a Counterfeit Part?

A counterfeit part is officially defined as any unauthorised copy, imitation, substitute or modified part that is knowingly misrepresented as a specified genuine part of an OEM or authorised manufacturer.

As well as the product itself, this definition can also apply to any supporting documentation e.g. a mill test certificate or certificate of conformity.

Unfortunately this issue has dogged several manufacturing sectors for many years now - with a quick internet search you will find many notable examples, particularly within the steel industry and electronic component market. Due to the potential risks to product conformity within an Aerospace, Space or Defence application; specific requirements around preventing counterfeit parts were incorporated into the latest revisions of the AS 9100 Series of standards.

How can Counterfeit Parts be avoided?

The first place to start with avoidance of counterfeit parts would likely be through the source of supply. When selecting a new supplier, whether it be a manufacturer or stockholder there should be a good level of due diligence performed. Some good starting questions may be:

  • Are they an authorised / approved vendor for the product you are looking for?
  • Do they hold recognised third party certifications such as AS9100 or ISO9001?
  • Are you confident in their capability to provide full traceability back to source for all materials?

These are just 3 fundamental areas consider, however the type of diligence required will likely go beyond this and vary by sector.

I personally think there is also a strong link here to AS 9100 clause 8.4.3m and the need to flow-down requirements for Ethical Behaviour / Product Safety to suppliers. High profile past events have taught us that known misrepresentation of parts is often result of a poor organisational culture where delivery has been prioritised over integrity of product.

When evaluating a new supplier it is well worth considering how a supplier educates their employees on matters such as product safety and counterfeiting, and whether a "just culture" is evident in the organisation - where staff can openly report mistakes and speak up against a violation of procedure.

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How can Counterfeit Parts be detected?

Understandably controlling the source of supply will be your first line of defence against counterfeit parts, but controls specific to the verification of actual product purchased shall also be considered.

This is where the robustness of your goods receiving processes and competence of personnel working in this area will come into play. Before the product is even taken out of it's packaging, there are questions we can start to ask:

  • Does the packaging look genuine?
  • Do the accompanying conformity documents look acceptable? Is there any evidence to suggest the use of correction fluid?
  • Can it be verified that the results stated on the conformity documents (e.g. mill test report) match the buyer's criteria?

That last one is particularly important, and the need to assess validity of supplier test reports is actually a requirement of AS 9100 clause 8.4.2.

In the example given above for metal, any deviation in the chemical analysis results stated on the mill test report against the actual Aerospace Material Standard (AMS) for that material grade would open up a cause for concern. Especially if the supplier has agreed to supply material against a specific AMS.

In the context of electronics manufacturing, it may also be useful to keep track of obsolescence databases. If a part is observed to have a date of manufacture in 2020 but it officially became obsolete in 2016, then alarm bells should certainly start to ring!

For some parts determined to be high criticality, or at high risk of being counterfeited - source controls / visual inspection will most probably not be enough, and it will be the responsibility of your organisation to put in place more diligent inspection and test regimes.

Naturally what you do here will vary a lot by product. The level of test and inspection will also vary depending on how critical the final application of the part is - for example, for materials used on important engine components I have seen several organisations using handheld XRF Spectrometers to verify metal stock at receipt.

A good Quality Management System that follows a risk-based approach will help you decide what is appropriate within the context of your product / service.

Protecting the Wider Supply Chain

One final consideration is the requirement to prevent counterfeit parts from re-entering the supply chain. Hopefully most organisations will never find themselves in possession of counterfeit parts, but if they do it is very important to ensure the goods are controlled. Simply sending them back to the vendor poses a threat to the wider Aerospace / Space / Defence supply chain as the goods could be re-sold to another unsuspecting consumer. It is therefore very important to ensure instances are reported through the necessary channels.

It may be beneficial to check your local requirements for reporting such issues - such as how containment is addressed in Control of Non Conforming Product procedures, and the need to report counterfeit part events to external regulatory bodies.

Read more about our AS9100.

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