Federal Aviation Administration Supplier Control Audit (SCA)

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Federal Aviation AdministrationSupplier Control
Audit (SCA)

• Presented by Ed Bayne
• Boeing Enterprise and Industry Interface
  Representative
• Prepared by Brian Simons
• Boeing Oversight Representative

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What is an SCA?

• FAA Order 8120.2, Part 3, section 124.
  Certificate Management Activity
• Certificate management activity will be focused
  on the Production Approval Holders (PAH) control
  of its suppliers.
• The FAA will determine if a PAH (e.g. The Boeing
  Company) is complying with its supplier control
  system by performing the following activities
• b. Supplier Control Audit. The Principle
  Inspector (PI) will determine that the supplier
  complies with purchase order and/or quality
  requirements.

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What is an SCA? (Cont.)

• FAA Order 8120.2, Part 6. Supplier Control Audit,
  section 139. General
• A SCA is conducted as part of the Certificate
  Management of the PAH (e.g. The Boeing Company
  PC700).
• Evaluates the outside sources (e.g. supplier)
  system to control parts, materials, supplies, and
  services.
• The SCA determines that the supplier complies
  with purchase order and/or quality requirements,
  including any statistical sampling that may be
  utilized.

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What are the results of an SCA?

• FAA Order 8120.2, Part 3, section 125.
  Determination of Supplier Control
• The PI determines whether a PAH is controlling
  its suppliers by reviewing the results of the
  supplier control audits.
• The PI looks for evidence that may indicate a
  system breakdown in supplier control by the PAH.
• Corrective action is requested for a system
  breakdown.

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What are the results of an SCA? (Cont.)

• If the FAA identifies evidence indicating a
  system breakdown in supplier control, a Letter of
  Investigation (LOI) or Surveillance Evaluation
  Report
• (SER) is issued to the PAH.
• LOI vs. SER depends on the severity of the
  issue(s)
• The LOI/SER informs the PAH that the FAA is
  investigating the matter.
• The LOI/SER describes each of the identified
  nonconformances as follows
• Required Condition (e.g. AS9100 requirement,
  supplier procedure, etc.)
• Encountered Condition (e.g. PAH failed to ensure
  AS9100was implemented
• at supplier)
• Example (e.g. specific evidence collected during
  SCA un-calibrated inspection tools, past due
  internal audits or management reviews, incomplete
  corrective action, missing training records,
  etc., etc., etc.)

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What are the results of an SCA? (Cont.)

• The PAH is requested to provide a response
  containing
• Additional evidence or statements addressing the
  conditions or examples
• Mitigating circumstances relevant to the case
• Nonconformance cause, and action to correct and
  prevent recurrence
• Response is typically due within 20 working days,
  upon receipt of LOI
• This language sounds like legalese, because it is!

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What are the results of an SCA? (Cont.)

• The PAH, and its suppliers, are required to
  maintain a quality management system per Code of
  Federal Regulations, 14 CFR 21.165.
• The PAHs Production Certificate is at risk
  during every SCA
• The PAH is at risk for civil penalties stemming
  from LOIs
• By law, 14 CFR 13.14 Each violation is subject
  to civil penalty of not more than 25,000 per
  occurrence. (i.e. each individual bolt improperly
  torqued, each part improperly heat treated)

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What are the results of an SCA? (Cont.)

• Past supplier Issues resulting in a civil penalty
  have included
• Special Manufacturing Processes (9100 clause
  7.5.2) Improper Heat Treating
• Design Control (clause 7.3) Revision Control of
  Drawings Specifications, Parts Manufactured
  Without Proper Engineering Approval
• Material Control (clause 8.3) Level of Control
  Over Non-conforming Product Parts Not Properly
  Identified for Scrap
• Tool Gauge Control (clause 7.6)
  Non-compliance of Calibration/Certification
  System
• Inspection System (clause 8.2.4) Control of
  Sampling System (Lack Training, Audits)
• Manufacturing Control (clause 7.5.1) Inadequate
  Work Instructions
• Certifications (clause 6.2.2) Employees Not
  Properly Certified Performing Operations

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Why should the Certification Bodies (CBs) and
their auditors care about SCA results?

• PAH supplier approval is based on 9100
  certification recognition
• The majority of tier 1 and tier 2 aerospace
  suppliers are 9100 certified
• The supplier QMS processes assessed during the
  SCA are the same ones assessed by the CB during
  initial and surveillance activity
• FAA verbal comment following a recent SCA audit,
  regarding a certified supplier that did not have
  an established FAI process, per AS9100
• clause 8.2.4.2 requirements
• He (FAA auditor) is concerned that they are CRB
  approved and it
• apparently wasnt identified as an issue by the
  approving CRB

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SCA Statistics (The Big Picture Show)

• FAA supplier control audits conducted at Boeing
  Commercial Airplane (BCA) division suppliers from
  October 2005 through March 2007
• 52 clients (9100 certified suppliers)
• 28 domestic / 24 non-domestic clients
• 21 clients had at least 1 identified QMS
  nonconformance
• 40 of total
• 86 total nonconformances identified
• Average per client 4
• Top client 9

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SCA Statistics (The Good, The Bad, The Ugly)
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SCA Statistics Top Nonconforming 9100 Clauses

• FAA SCAs conducted at BCA division suppliers from
  October 2005 through March 2007
• 7.5.1 Control of Production and Service Provision
  (13)
• 8.2.4 Monitoring and Measurement of Product (8)
• 8.2.4.2 First Article Inspection (7)
• 7.5.1.1 Production Documentation (6)
• 7.5.5 Preservation of Product (6)
• 4.2.3 Control of Documents (5)
• 4.2.1 Documentation Requirements (4)
• 4.2.2 Quality Manual (4)

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7.5.1 Control of Production and Service Provision

• Production work order issues
• Obsolete/inaccurate drawing and specification
  call-out
• Missing or omitted manufacturing/inspection
  operation entries
• Different part counts between operations (Part
  accountability)
• Manufacturing/inspection practice does not match
  operation instruction
• Manufacturing practice does not meet
  engineering/specification requirements
• Recommendations for CB auditor
• Increase audit time in manufacturing/inspection
  areas
• Increase production work order sample size during
  audits
• Review for part accountability, required entries,
  evidence of operation completion
• Compare work order to drawing/specification
  requirements
• Witness manufacturing/inspection practice vs.
  work order, drawing, specification, instruction,
  etc.

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The Loud and Clear Message

• Aerospace QMS certification/registration scheme
• The FAA allows the PAH to use other-parties to
  perform supplier assessments, surveillance, and
  certification. It is an earned privilege, not
  guaranteed.
• FAA perception of effectiveness is based on facts
  collected during SCA activity
• Certification body management and auditor
  responsibilities
• Ensure the integrity of the audit process and the
  validity of the issued certificate
• Recognize the inherent conflict of interest
  perception (Clients pay for certificates)
• Demonstrate ethical behavior to build trust and
  confidence with the PAH and FAA
• (i.e. no soft grading of nonconformances,
  thorough CA verification, etc.)
• CB auditors role is critical for PAHs
  Certificate Management

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Proposed Process Improvements

• Direct communication of SCA results from PAH to
  responsible CB
• OASIS feedback loop
• Formal PAH report (e.g. Boeing Strengths and
  Issues document)
• Participation by CB in LOI corrective action
  response
• Participation of CB auditor, along with PAH
  personnel, during a SCA
• Direct communication of SCA results to
  accreditation body (e.g. ANAB) for CB oversight
  planning and auditing activity

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The Reality of the Civil Aviation Industry.......

• PAH and FAA personnel
• Are not as constrained by audit agendas/plans or
  time during their audit activity
• Audit trails can be methodically followed and
  investigated, allowing greater possibility of
  exposing process nonconformances
• Spend the majority of audit time focused on
  manufacturing/inspection processes
• Shouldnt the Certification Body Personnel
• Ensure audit planning policies and CB/Client
  agreements meet the intent of AS9104 clause 8.2.2
  Duration of Assessment
• It is anticipated that the requirements of the
  AQMS Standards shall add on-site assessment time
• Justify and utilize additional on-site assessment
  time to emphasize manufacturing/inspection
  documentation, personnel competence, and process
  conformance

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Supplier Control Audit - SCA

• Questions or clarifications?
• Comments?
• Discussion?
• Email feedback to brian.d.simons_at_boeing.com
• FAA CFR's and Orders http//www.faa.gov/