RSC Colour: Black

  • Who should have authority to approve scrap, repair, or concession dispositions?

    It should be approved by the roles formally designated in your quality system and product governance process, not by whoever discovered the issue or whoever is under the most schedule pressure.

    In practice, that usually means:

    • Scrap: often approved by authorized quality personnel, and sometimes operations leadership as well, if the part is clearly non-recoverable and local procedures allow it.
    • Repair: typically requires engineering authority in addition to quality review, because repair changes how the product is brought back to an acceptable condition and may affect form, fit, function, reliability, or future maintenance.
    • Concession or use-as-is: usually requires a formal review board or delegated authority that includes quality and engineering, and may also require customer or design authority approval depending on contract terms, product criticality, and whether the nonconformance affects requirements.

    The short answer is: authority should follow documented delegation, competency, and risk classification, with clear evidence of who approved what and under which procedure.

    What should not happen

    Operators, supervisors, planners, or buyers should not independently approve repair or concession dispositions unless your controlled procedures explicitly delegate that authority and the individuals are qualified to exercise it. In regulated environments, informal approvals create obvious traceability and change control problems, and they can invalidate downstream assumptions in inspection, genealogy, costing, and customer reporting.

    It is also risky to assume that scrap is always a simple local decision. Scrap may trigger material accountability, customer notification, supplier recovery, serialized asset updates, or impact analysis for work orders already linked in MES, ERP, PLM, or QMS.

    What determines the right approval model

    • Product criticality and safety significance
    • Whether the disposition changes design intent or process intent
    • Customer, contract, or design authority requirements
    • Internal delegation rules in the QMS
    • Competency and training records for approvers
    • Whether the item is serialized, traceable, or already installed in a higher-level assembly
    • System capability to enforce routing, signatures, and evidence retention

    If these conditions are not well defined, approval authority becomes inconsistent across shifts and sites. That is a governance problem, not just a workflow problem.

    Brownfield system reality

    In many plants, the actual approval path is split across QMS, MES, ERP, email, and engineering records. That is common, but it increases the chance of mismatched statuses, missing signatures, and weak evidence trails. A digital workflow can help enforce role-based approvals, but only if master data, role mapping, and system integrations are reliable.

    Full replacement of legacy quality or execution systems is often not the practical answer. In regulated, long-lifecycle environments, replacement can fail because of validation effort, qualification burden, downtime risk, integration complexity, and the need to preserve historical traceability. More often, the workable approach is to tighten disposition authority rules and connect existing systems well enough that approvals, records, and status changes remain synchronized.

    Practical rule

    If a disposition could affect product acceptance, configuration, traceability, customer obligations, or future airworthiness or serviceability decisions, approval should sit with authorized quality and engineering functions under controlled procedures, with escalation to customer or design authority where required.

    If your process cannot show who had authority, what evidence they reviewed, and which system became the system of record, then the approval model is not mature enough yet.

  • What are examples of non-conforming behavior?

    In regulated manufacturing, “non-conforming behavior” means actions or omissions that do not follow approved requirements, methods, or controls. It is broader than just nonconforming product. It includes behaviors by people and systems that bypass, weaken, or contradict documented processes, specifications, and controls.

    1. Operator and technician behaviors

    • Skipping required process steps: Omitting an in-process inspection or cleaning step because “it always passes” or “we are behind schedule.”
    • Using unapproved work methods: Following a tribal shortcut instead of the current, approved work instruction.
    • Bypassing interlocks or safety features: Using magnets, jumpers, or manual overrides to defeat guards, light curtains, or door switches to “get the job done faster.” (Also a safety issue.)
    • Using wrong or outdated documents: Printing a work instruction months ago and continuing to use it after new revisions are released.
    • Using incorrect tools or equipment: Substituting a different torque wrench, adhesive, fixture, or gage that is not specified in the routing or work instruction.
    • Working without required qualifications: Performing special processes (welding, NDT, sterilization, etc.) without current certification or training sign-off.
    • Improvising rework without approval: Filing, shimming, drilling, or bending parts to make them fit without an approved rework instruction or deviation.
    • Inaccurate or incomplete recording: Checking off steps not actually performed, copying another operator’s readings, or leaving required fields blank in batch records, travelers, or eDHR.
    • Ad-hoc material substitution: Grabbing “similar” hardware, o-rings, lubricants, or chemicals from another bin when the specified material is not available.

    2. Supervisor, engineering, and management behaviors

    • Informal deviations: Telling a team to ignore a spec, skip a test, or change a process step “just this once” without formal deviation or change control.
    • Schedule pressure over compliance: Explicitly or implicitly rewarding on-time delivery while tolerating or encouraging shortcuts around inspection or documentation.
    • Uncontrolled process changes: Changing parameters (e.g., oven cure time, pressure, CNC feeds/speeds) or sequences without documented change control, validation, or risk assessment.
    • Overriding quality decisions without process: Releasing material that failed inspection or that has open nonconformances without approved concession or use-as-is disposition.
    • Delaying or avoiding issue escalation: Instructing staff not to log an NCR, deviation, or complaint to avoid metrics impact or audits.
    • Ignoring training and competence gaps: Assigning complex or regulated tasks to untrained personnel because “they will figure it out” or “we are short-staffed.”

    3. Quality system and documentation behaviors

    • Using uncontrolled documents: Relying on personal copies, spreadsheets, or shared-drive instructions that are not under document control.
    • Backdating or pre-signing records: Completing signatures or timestamps before work is done (or altering them afterward) to match schedules.
    • Incomplete traceability: Not recording required lot numbers, serial numbers, or equipment IDs for traceable materials or special processes.
    • Not following NCR/CAPA procedures: Handling defects verbally instead of raising a nonconformance, or closing CAPAs without verifying effectiveness.
    • Editing data without audit trail: Modifying inspection results or batch data outside the validated system, or without justification and traceability.

    4. Equipment, calibration, and maintenance behaviors

    • Using out-of-calibration gages: Continuing to use instruments, torque tools, or test rigs beyond calibration due date or after known failure.
    • Adjusting equipment without authorization: Technicians changing recipes, offsets, or control logic without proper authority or documentation.
    • Disabling alarms or interlocks: Silencing nuisance alarms, removing fuses, or changing alarm thresholds to avoid stoppages instead of resolving root causes.
    • Running outside validated ranges: Routine operation of ovens, sterilizers, molding presses, or environmental chambers outside validated setpoints or limits.
    • Skipping preventive maintenance: Deferring required PM on critical equipment because “it is still running fine” and not documenting the decision appropriately.

    5. Data, IT, and system behaviors

    • Work outside validated systems: Running production from offline spreadsheets or emails when MES/ERP/QMS is the approved system of record.
    • Manual workarounds for system constraints: Re-typing, copy-pasting, or duplicating data between systems without reconciliation or checks, leading to mismatches between paper and digital records.
    • Uncontrolled configuration changes: Changing routing logic, part masters, electronic signatures, or security roles in MES/ERP/QMS without change control and testing.
    • Inadequate access control: Shared logins, generic accounts on production systems, or supervisors entering data on behalf of operators as routine practice.
    • Shadow IT solutions: Deploying unapproved apps or databases to track production, quality, or maintenance data outside corporate governance.

    6. Brownfield and coexistence realities

    In brownfield environments with mixed legacy and modern systems, non-conforming behavior often appears around the gaps between systems, not just within one system:

    • Operators following the paper traveler while ignoring later changes applied only in MES or vice versa.
    • Parallel, unofficial trackers used to “fix” poor integrations, which slowly diverge from the system of record.
    • Plants running different revisions of the same work instructions due to incomplete rollout or limited downtime for updates.

    Trying to “fix” non-conforming behavior purely by replacing systems usually fails in regulated, long-lifecycle operations. New platforms do not remove the need for disciplined change control, validation, clear ownership of requirements, and practical workarounds for downtime and integration gaps. Without addressing these, non-conforming behaviors simply migrate to the new tools.

    7. How to interpret and act on non-conforming behavior

    • Context matters: Some behaviors may be non-conforming in one plant or program but acceptable in another with different approvals, risk assessments, or validated ranges.
    • Look for patterns, not one-offs: A single deviation may be a mistake; repeated behaviors usually indicate process, training, or system design issues.
    • Tie behaviors to documented controls: Classify behaviors against specific SOPs, work instructions, drawings, or system configurations they violate or bypass.
    • Use structured problem solving: Treat persistent non-conforming behavior as a signal for root cause analysis and potential CAPA, not just individual blame.

    Any assessment of non-conforming behavior must be grounded in your actual procedures, specifications, and regulatory obligations. The same act can be either acceptable variation or a serious violation depending on documentation, approvals, and validated limits in your environment.