Launch Your Next Mission - Part 3: Raw Material Testing
The standard doesn’t state to test raw material when asked to, it asks you to test when the risk of counterfeit is high. When I dig a bit deeper I learn that most of the organizations have not determined the risk and therefore don't do any testing.
Raw material testing is one of the new requirements (although it was in revision B, taken out in revision C and now put back in again), most organizations haven't even thought about the impact of this. We also often get the excuse 'customer delegated sources', but that doesn't absolve your responsibility. Even though a customer has told you to buy from a certain source doesn't mean that the risk is gone.
Although the standard refers to counterfeit parts, I am going to focus on the raw material element in this article. The same rules however can be applied to parts but there are additional mitigations that can be put in place.
There is a misconception that counterfeit parts only relate to electronic components, 82% of the known counterfeit parts on the market are electronics, and the remaining 18% is material.
There have been well publicised examples of fraudulent material on the market and many clients believe that by getting the mill cert they are covered. This is not the case, the purpose of having the raw material tested is to verify that the material certificates are true because they have been fraudulently produced in the past.
Do not just state that you are not doing raw material testing without fully evaluating the risk and determining when you should perform testing.
In order to understand this clause requirement you first need to understand some of the definitions:
Certificate of Conformity
A document provided by a supplier formally declaring that all buyer purchase order requirements have been met. The document may include information such as manufacturer, distributor, quantity, lot and/or date code, inspection date, etc., and is signed by a responsible party for the supplier.
Certificate of Authenticity
A statement to the effect that all materiel items listed above furnished on this contract are genuine, new and unused unless otherwise specified in writing herein; are suitable for the intended purpose; are not defective, suspect, or counterfeit; have not been provided under false pretenses; and have not been materially altered, damaged, deteriorated, or degraded.
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.
The process of becoming obsolete or the condition of being nearly obsolete
Suspect material misrepresented to the customer as meeting the customer’s requirements.
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 materiel or counterfeit materiel provided below:
Assess the Risk
One of the first things you need to do is assess the risk, your management system should already be in place to address this but often it does not go into sufficient detail to assess the risk of counterfeit material.
Don't just look at the word in the standard that states 'critical' without understanding what is critical, it is not just flying parts, it is material which poses a high risk.
The standard mentions high risk of counterfeit parts and most organizations have not determined when there is a high risk.
The risk of counterfeit material depends on a number of factors not just how long you have known the supplier for which is what most organizations will use. There is actually a 3 pronged approach that needs to be taken; the product and application risk, the source of supply risk and supplier assessment.
Only once all three areas have been assessed can you determine if raw material should be tested or not.
Product and Application Risk
The first risk you need to consider is the product and application risk, what is the product being used for that the material is for? Is the application critical and life dependent or is it just a commercial type product which life does not depend on it in case of failure.
There is no set rule for this but I have set out suggested risk levels below from low to high. To put some context around each level you could simply put a number against each and we can use this later to determine the overall risk of a product to determine if we should have material tested or not.
Source of Supply Risk
Source of supply is used to assess the risk from where you are purchasing the material from. If you are purchasing direct from the source (the OEM/OCM etc) then you can consider this a low risk. If you are purchasing from a new supplier who you do not know then the risk is higher.
The problem with the aerospace world and most products nowadays is that the supply chain can be very complex, the more organizations involved in the chain of custody for material or parts then the risk increases. Do you fully understand the source of your material? Don’t just think of the source as the person you are directly buying from, think about where they are buying it from and so on. There can be multiple levels of material supply that you are not aware of.
The chances of you purchasing directly from a mill are slim unless you are one of the larger distributors so you would tend to use a smaller distributor. Often the smaller distributors will purchase from each other and the chain gets muddy.
Do a full chain of custody evaluation of the supply chain to ensure you are aware of the sources.
Supplier Assessment Risk
This is the part of the risk process which is generally always performed by client organizations, however, it is rarely done accurately.
A typical supplier assessment process consists of a questionnaire being submitted with a load of boxes ticked and then the questionnaire is filed. When I review these questionnaires I will get a sample of suppliers and put them next to each other; one with AS9100, one with ISO 9001 and one with nothing at all. I will ask the organization what would make them purchase from one over the other, the answer is price and they are all treated the same.
What is the point of filling in questionnaires if you do nothing with the answers?
I am not going to say to use one supplier over another due to their accreditation approvals (unless it's in a contract somewhere) but I would expect some kind of an assessment on the risks surrounding each of these suppliers. The standard requirements on an AS9100 certified organisation are greater than that of an ISO 9001 supplier and again over someone with no formal quality system in place. You should assess the risk of using each of those suppliers and take appropriate action.
Some examples of the types of supplier assessment questions are shown below:
When you have determined the levels appropriate to your organisation you can then put them in a risk grading as appropriate:
Buyers Supply Chain Risk
When organizations are performing design activity they also need to add in an additional risk assessment; the supply chain risk.
Every product goes through a life cycle and as a product reaches obsolescence the risk of counterfeit increases as there is less of the material available which drives the black market to create alternatives or fraudulent parts.
You should not be designing parts where product materials are likely to become obsolete before the life expectancy of the product itself reaches obsolescence.
When putting parts out to tender you can then consider the risk of the supply chain using a classic impact and likelihood table and determine the risk through traceability requirements. These requirements could then be cascaded down to your suppliers through purchasing terms in order to mitigate the risk of the supply chain.
Impact of supply chain risk:
1. Negligible - Easily Mitigated
2. Minor - Increase the cost of operations
3. Moderate - Degrade the function, use or operation of the system
4. Serious - Sabotage, or maliciously introduce unwanted function
5. Critical - Result in injury or death of personnel, or significant destructive product damage
Likelihood of occurrence
There are different factors to consider when thinking about the likelihood of occurrence; the quality of the supply chain and the availability in the supply chain.
If the historical quality of the production is known to be poor then this could be a trigger for there being counterfeit material in the market. If there is a low number of manufacturers of the material then this drives the black market, other manufacturers who could not be authorised to manufacture the material start producing and putting into the market, great example of supply and demand. Limited supply also forces organizations to just source from anywhere they can get the material which is why design organizations need to consider the materials they are specifying on parts, are the materials becoming obsolete or superseded?
Are your customers going to be driven to the black market to source the material being specified as its rare and hard to come by?
I have one client who is unable to purchase a specific type of material anymore as the application using the material is being replaced by new technologies. Mills have stopped making the material as there is not enough demand. This has forced him to place a very large order directly with the mill to manufacture a batch just for him. If he didnt do this then he would have to turn to the black market or seek alternatives which may not achieve the characteristics he needs.
1. Not likely - Stable, high quality production base
2. Low likelihood - Isolated poor performance in second tier of production base
3. Likely - Suppliers are exiting the production base
4. Highly likely - Diminishing sources and material shortages exist
5. Near certainty - Widespread degradation of the production base; frequent poor performance instances.
Risk of Counterfeit
When you incorporate the three-pronged approach to assessing the risk, you can put the results of each assessment onto a simple table. You will need to determine what mitigations you will put in place for each of the resulting scores.
The highest possible score is 24 so you could consider anything above 20 to require raw material testing. You could possibly work towards reducing the risk, you couldn’t do much about the application as the product is what it is, you can however focus on improving the source and giving a more thorough assessment of the supplier.
You always need to do what the customer wants though so if a customer has put on their purchasing terms that you must perform raw material testing then you shall do it.
Mitigations and Controls
The mitigations and controls applied depend on the risks of counterfeit, organisations need to identify what method they are choosing for each received product.
- Receipt visual inspection
- Certificate of authenticity/conformity
- Authorised Supplier
- Process Audit/Review
- Auditible Part History/traceability back to source/mill
- Verification Testing
- Buy direct from OEM or OCM
Counterfeit Material Detection
There are many different methods of supporting the identification of counterfeit parts, raw material testing is only one of those processes and we should be performing other activities before that point. Unless you are testing 100% of the time then you need to implement some additional checks.
Documentation and Packaging Inspection
Any Certificates of Conformance or other documentation should be examined for authenticity and applicability to the delivered material, including:
Lot and/or date codes on the packaging does not match the lot and/or date codes on the parts.
Review of logos, trademarks and other identifying marks to ensure they match manufacturers’ marks as applicable.
Changes to or irregularities in the documentation and/or paper trail.
Part number marked on the material does not match the part number on the Purchase Order and the certifications.
Materials are inconsistent with the description on the supplied documentation.
Serial number issues or duplication of UII (Unique Item Identifier).
If there is an elevated concern for product integrity, it may be possible to verify with the manufacturer that date, lot codes, serial numbers, and quantities listed on the documentation are valid.
For material with product identification and/or other identifying/traceability markings, a representative sample based on a determination of product risk should be examined from each lot (date code or other identification code) for evidence of remarking and/or salvaged, reclaimed, or other indications of re-use.
Examples of suspect counterfeiting include, but are not limited to:
Altered or unexplained markings, stampings, mouldings, and engravings.
Improper surface treatment or signs of refurbishment without being identified as refurbished materiel.
Re-marked, smeared or illegible bar codes (IUID or UII)
Faceplates and nameplates showing signs of removal and reinstallation
Altered labels and tags
Signs of re-painting or re-coating
Other signs of reused material such as oil stains, overheated areas, signs of disassembly and reassembly, erosion, wear, dents and scrapes, etc.
Suppliers should consider establishing a library of digital photographs for material received, that can be used to supplement other inspection criteria.
Raw Material Testing
So what raw material testing is actually needed, there is no set requirement for how much is tested or how often but this should form part of your assessment. Put something in place that is realistic and suitable for the applications.
If you are changing suppliers often and buying from multiple sources then you need to consider this as part of your frequency. How often are you buying the material altogether?
There are 2 basic types of testing; non-destructive testing and destructive testing.
Non-destructive Testing (NDT): Can also be described as Non-destructive Inspection (NDI) or Non-destructive Evaluation (NDE). NDT encompasses a wide variety of analytical techniques used in science and industry to evaluate the properties of materials, components, subcomponents, or systems without damaging or permanently altering them. The following NDT Techniques can be used to validate the materials, processes and markings of material:
Visual, weight, optical and infrared (if applicable), and dimensional inspections. Can be used on all items.
Liquid penetrant inspection (surface defects only). It can be used only on non-porous materials; either metals or non-metals. Liquid penetrant may be fluorescent (Type I) which requires black lighting inspection, or non- fluorescent (Type II) also called visible dye which requires white light inspection. Most commonly used materials are post emulsified hydrophilic, post-emulsified lipophilic, water-washable and solvent removed penetrants.
Magnetic particle inspection (surface to ~0.25 inch depth). It is limited to the inspection of iron/steel items only. The process may be wet particle inspection using stationary or portable equipment, or dry particles inspection using portable equipment such as yokes, contour probes or prods. The inspections may be fluorescent which requires black lighting inspection, or non- fluorescent which requires white light inspection.
Ultrasonic inspection may include thru transmission, pitch/catch, straight beam, shear, immersion or phased array. The inspection can be performed through the entire part depending on configuration, but is not good on/near surface). Used on all materials except very porous or non-homogenous materials.
Eddy current inspection (also called electromagnetic inspection). It is limited to the inspection of metals only, to about 0.25 inch depth. Special controls are needed to use eddy current on iron/steel items. May also include phased-array eddy current. Eddy current is only used rarely to detect flaws on new/unused items, and is used extensively to detect flaws on used items, (in-service inspections, corrosion, wear, crack, impact, fatigue, etc.). Other uses of eddy current are conductivity testing, alloy sorting, coating thickness tests, and tubing/piping inspections.
Radiological inspection includes film radiography, digital radiography, computed radiography, real time radiography and computed tomography. There are three main types of penetrating radiation used; those are X-ray, gamma ray (also called radioisotope source inspection), and neutrons. Can be used for internal inspections for most configurations or items or materials (metals, composites, etc.), and is also used to inspect assemblies. Neutron radiography is used to inspect explosives and plastic materials. Radiological inspections are not commonly used to find surface defects. X-ray fluorescence analysis (XRF) is sometimes used to identify the thickness and composition of plating, as well as being a viable method for detecting certain metal alloys.
Thermography inspections. Used on both metals and nonmetals to find defects, however, can be used to find “hot spots” in systems and assemblies. Acoustic Emission. Used to test systems for noise/noise reduction. Occasionally, the term is used for inspections that generate sounds into materiel to check for delamination’s, (for example, tap tests or hammer tests, etc.). Used on systems requiring a certain level of sound control (i.e., submarines) and on composite materials/components (i.e., composite tap tests).
Holography/shearography. Laser inspections, mainly used on composites and tires to find flaws and delamination’s.
Heat Flow Microcalorimetry. Inspections performed using comparative heat transfer rates of known versus unknown/suspect materials. Can be used to determine if material has been properly processed. Can also be used to predict corrosion or other material changes prior to its occurrence.
Functional tests: Install part to see if it works, fit tests, perform dynamometer tests, etc.
Other types of technology-specific non-destructive tests not listed.
Destructive Testing can include: deformation tests (bend, vibration, shock, tensile, compression, shear, fatigue, hardness, adhesion, impact, etc.); metallurgical tests (cut materiel, polish and evaluate under magnification); exposure tests (heat, cold, fuel, weathering, aging, UV, ozone, chemical, salt spray, corrosion, etc.), analytical tests (gas chromatography, spectral analysis, electron microscopic inspections, wet chemistry composition analysis, etc.); functional tests (run it until it breaks), etc. These tests should be applied as appropriate per contractual agreements.
When considering whether or not you should perform raw material testing do not just assume that you don’t need to perform it without giving full consideration to the risks associated with the products and the supply chain.
A classic answer is always to assume that your supplier is performing it so you don’t need to. Do you tell the supplier to test? If the answer is no then why would they have done the tests on the raw material? Everyone points the finger and assumes the previous supplier has done the testing as they are AS certified themselves.
Author: Michael Venner - NQA's Aerospace & Automotive Director
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