Quality Clause Definitions
Scope The following clauses apply to all Raw Material and Special Processing Purchase Orders.
QC 1: MIL-I-45208A Quality System or Equivalent Compliance
- Seller shall comply with MIL-I-45208A, Inspection System Requirements or equivalent.
- Unless expressly authorized by this contract, Buyer does not delegate Material Review Board (MRB) authority to Seller or its sub-tier suppliers relative to permanent Non-conformances of features, characteristics or parameters that are controlled by Buyer's specifications. Non-conformances to Seller-controlled features, characteristics, and parameters that do not result in failures to completely meet specification requirements may be dispositioned by Seller's system for the control of nonconforming goods.
- If Seller is not the manufacturer, Seller shall furnish goods which have been obtained from a source approved by Buyer, as well as provide the name and address of the manufacturer on the shipping report or applicable certification. A list of approved sources shall be furnished by Buyer's authorized purchasing representative upon request.
- Seller shall insert the substance of this clause, including this sentence, in all lower-tier subcontracts for work done under this contract.
QC 2: MIL-STD-45662A Calibration System or Equivalent Compliance
Seller shall comply with MIL-STD-45662A or ANSI/NCSL Z540-1 or later revision, requirements in the utilization of measuring and test equipment during the performance of this contract.
QC 3: First Article Piece Inspection
- A First-Piece inspection requirement is mandatory, to ensure process capability before production. This requirement does not relieve Seller from verifying that all goods meet contractual requirements. In the case of numerical control (NC) operations, every effort shall be made to fully qualify NC software before production use. When software on complex parts cannot be fully qualified before use, cutter path simulation software and substitute material shall be employed to minimize nonconformance in the production lot.
- The first piece machined or formed shall be inspected (all machined/formed characteristics) for acceptance to the design requirements by Seller, before fabricating the remainder of the lot deliverable under this contract. The inspection results shall be documented (e.g., inspection point on the traveler) and maintained with the lot records by Seller. Seller is not required to record actual measurements unless this data is required to satisfy First Article Inspection requirements.
- If Seller utilizes a process to fabricate multiple pieces at the same time on the same machine as in the case of a multiple spindle NC machine, the first-piece inspection shall include units from each spindle machined at that time. If Seller uses multiple machines, the first piece from each machine shall be inspected.
- If the first piece(s) is Non-conforming, Seller shall make the necessary adjustments and fabricate another first-piece part. Seller shall continue this first-piece process until an acceptable first-piece part is fabricated. Seller shall proof its process sufficiently before the first piece to ensure minimal Non-conformances. Evidence of this proofing must be maintained as required in the second paragraph above.
- If the design involves multiple operations (e.g., machining, heat treating, forming), the first-piece inspection shall be required immediately following machining and forming processes.
QC 4: Dimensional Inspection Objective Evidence
- Seller shall provide objective evidence with each shipment that all goods furnished under this contract show evidence of dimensional inspection for conformance with drawing and other contract requirements. Objective evidence shall consist of records of actual readings taken during the inspection of each part, with the dimension and its tolerance noted. All out-of-tolerance measurements shall be identified on the records, and Seller shall indicate the authority for acceptance of an out-of-tolerance condition.
- Seller shall identify the contract number, part number, revision number, and when applicable, serial number on each inspection data sheet. Each inspection data sheet shall be signed by the Management Representative responsible for Seller's inspection activity, with the title of the individual whose signature appears on the inspection data sheet and the date of the signature.
Evidence of Buyer's source inspection, when applicable, shall beindicated by Buyer's source inspection stamp, or signature, on Seller's dimensional record for each dimension verified.
QC 5: Statistical Process Control Planning – Data Management
- Seller shall create a statistical process control plan, stating the details of the techniques to be used on both dimensions and processes for the goods delivered under this contract. The plan shall be submitted to Buyer's authorized purchasing representative for approval by Buyer's Quality Assurance. After approval by Buyer's Quality Assurance, Seller will comply with the plan. Any changes to the approved plan shall be submitted to Buyer for approval.
- Statistical Charts are required with shipment to demonstrate the process Integrity. The following charts are required as a minimum: Histogram and appropriate Run charts (IX & MR or X-bar & R). A Cpk of 1.33 the minimum is required for an acceptable process dimensional record for each dimension verified.
QC 6: Manufacturing and Inspection Control Plan
Seller shall submit a manufacturing and inspection control plan for Buyer's approval. As a minimum, the plan shall delineate the sequence of manufacturing operations to be performed, the points within the manufacturing sequence where inspection is to be performed, the type of each inspection specified, and, if applicable, the specifications that define each inspection requirement. This plan shall be submitted to Buyer's authorized purchasing representative and approved by Buyer's Quality Assurance before production of the goods. Buyer's approval of this plan does not relieve Seller of the responsibility to perform all inspections required by the applicable specifications. After approval by Buyer's Quality Assurance, Seller shall comply with the plan. Any changes to the approved plan shall be submitted to Buyer for approval.
QC 7: Source Inspection
BERANEK INC., and PRIME SOURCE INSPECTION is required at Seller’s facility. Goods ordered by this contract are subject to Buyer's inspection prior to assembly and throughout all assembly, processing, and testing operations. Buyer's Quality Assurance shall establish and coordinate the mandatory Buyer inspection points. Evidence of such inspection shall be indicated on the shipping report, process certification, or fabrication order accompanying each shipment. Seller shall notify BERANEK INC Quality Assurance at least two days prior to processing or manufacturing in conjunction with this contract.
QC 8: Buyer's Quality Source Surveillance Validation of Seller's First Article Inspection Report
Upon receipt of this contract, Seller shall promptly notify Beranek, Inc., Quality department so that appropriate planning for surveillance of the First Article Inspection (FAI) can be accomplished.
First Article Inspection (FAI), or test shall be performed by Seller at Seller's facility. Quantitative results shall have documented information. A report identified as the "First Article Inspection Report." Seller shall notify Beranek, Inc., Quality department at least 48 hours in advance to schedule surveillance of the FAI. Buyer's Source inspector shall verify the conformity of Seller's FAI, as applicable, and shall document results in the FAI Report. Seller shall retain one copy of the FAI Report, as evidence of Buyer's approval of the FAI, and one copy shall be forwarded with Seller's shipper to Buyer.
QC 9: Government Source Inspection
GOVERNMENT SOURCE INSPECTION is required prior to shipment from Seller's plant. Upon receipt of this contract, Seller shall promptly notify the Government representative who services typically its plant so that appropriate planning for Government inspection get scheduled and performed.
NOTE: Seller shall provide evidence of Government inspection on the shipping report accompanying each shipment.
QC 10: Manufacturer's Certification of Compliance
- Seller shall include with each shipment the manufacturer’s certificate that states that the goods shipped meet all applicable specifications and purchase order requirements. The manufacturer’s certificate shall include the following information:
1) Name and address of the manufacturer.
2) The specifications that controlled the manufacture of the goods. Seller shall include revision numbers or letters, if any. If no revision is stated on the purchase order, it is expected that the latest revision shall be used.
- Seller shall reference Buyer's contract number on the manufacturer's certificate of compliance.
QC 11: Material Certification
Seller shall include with each shipment a certificate that states that the materials used in the manufacture of the goods furnished under this contract were tested, inspected, and found to be in compliance with the applicable material specifications. As a minimum, the Certification of Compliance or Certification of Analysis and/or shipping document shall include or reference the following information:
- Purchase Order Number
- Material description, specification including revision letter or number, of the item being furnished.
- Specialty Metals:
All specialty metals used for Beranek’s hardware shall be melted in the United States or a qualifying country. Exceptions must have written prior approval by Beranek, Inc. customers. These specialty metals are defined in the Defense Federal Acquisition Regulation (DFAR) Supplement Clause 252.225-7009, Preference for Domestic Specialty Metals. Alternate I apply. Qualifying countries are listed in 225.872-1 (a). http://www.acq.osd.mil/dpap/dars/dfars/pdf/current/20150420/252225.pdf.
- Preference for domestic Aluminums.
- Quantity of Material
- Date of Manufacture/ Shelf life dates (when applicable)
- Part number including revision number or letter of the item being furnished.
- Vendor's Shipping Document Number.
- Raw Material SINGLE LOT as preference
- Manufacturer's lot identification number of the item being furnished.
- Raw Material Heat Lot Number(s)
- Results of Test as required by Beranek, Inc.
QC 12: Raw Material Test Results
- Seller shall include with each shipment the raw material manufacturer's test report (i.e., mill test report) that states that the lot of material furnished has been tested, inspected, and found to be in compliance with the applicable material specifications. The test report shall list the specifications, including revision numbers or letters, to which the material has been tested and/or inspected and the identification of the material lot to which it applies.
- When the material specification requires quantitative limits for chemical, mechanical, or physical properties, the test report shall contain the actual test and/or inspection values obtained. For aluminum mill products (except castings), certifications for chemistry may indicate compliance within the allowed range. Certifications for physical properties shall show actual values.
- If Seller supplies converted material produced by a raw material manufacturer, Seller is responsible for ensuring performance of all physical tests where the manufacturing process has altered the properties from what had been certified by the raw material manufacturer. The data submitted must reflect the condition of the material as offered for delivery. This data is in addition to the raw material manufacturer's test report required above.
QC 13: Nondestructive Test (NDT) Certification
Seller shall include with each shipment a certificate that lists the NDT performed. A record of the procedures or techniques used, and actual results shall remain on file for at least ten years after shipment to Buyer and shall be furnished to Buyer upon request. These records must include the inspector's signature or stamp, NDT certification level and/or technique or plan number.
QC 14: Export Controlled Information
ITAR NOTICE - THIS ORDER CONTAINS INFORMATION WHICH FALLS UNDER THE PREVIEW OF THE U.S. MUNITIONS LIST (USML), AS DEFINED IN THE INTERNATIONAL TRAFFIC IN ARMS REGULATIONS ( ITAR ), 22 CFR 120 – 130, AND IS EXPORT CONTROLLED. IT SHALL NOT BE TRANSFERRED TO FOREIGN NATIONALS IN THE U.S. OR ABROAD, WHITOUT SPECIFIC APPROVAL OF A KNOWLEDGEABLE EXPORT CONTROL OFFICIAL, AND/OR UNLESS AN EXPORT LICENSE/LICENSE EXEMPTION IS OBTAINED/AVAILABLE FROM THE UNITED STATES DEPARTMENT OF STATE. VIOLATIONS OF THESE REGULATIONS ARE PUNISHABLE BY FINE, IMPRISONMENT, OR BOTH.
This order is subject to export control laws. Supplier shall not disclose oral written or otherwise any drawing specifications and other technical data to any foreign person, firm or institution including but not limited to suppliers own employees and subcontractors.
QC 15: Serialized Traceability Required
This order includes products that are traceable by individual serial numbers. It is required that seller maintain traceability of product throughout processing from receiving to shipment. Certifications shall reflect serial numbers processed and status as applicable.
NOTE: If this clause has been invoked and you have received hardware without serial numbers: Do not process the order. Contact Beranek, Inc purchase representative noted on signature block of purchase order.
QC 16: Product Verification Right
Beranek, Inc., or any regulatory agency shall be allowed the right to audit and inspect the Supplier’s activity for records, products and processes, including at Supplier’s facility, upon prior notification to the Supplier, to determine and verify the quality of work at any point of manufacture in any subcontractor plant and its sub-tiers. Beranek, Inc. will notify the Supplier a minimum of five (5) working days in advance of such surveillance audits.
QC 17: Non-Conformance Notification and approval process
In the event of product Non-conformance, the supplier must contact Beranek, Inc., Quality Manager within a reasonable period. The Non-conformance shall be clearly documented and when applicable, a corrective action included. After Beranek, Inc. Quality Manager reviews the Non- conformance and contacts it’s customer as needed, final disposition shall be determined by Beranek Inc.’s Customer. NO FOD allowance.
QC 18: Notification of changes in product and or process definition.
In the event of changes in product and/or process, the supplier must contact Beranek, Inc., Quality Manager within a reasonable period. The changes should be clearly documented and a copy of the revision or process change included in the documentation. After Beranek, Inc. Quality Manager reviews the change and / or process definition, and contacts it’s customer as needed, final disposition shall be determined by Beranek Inc.’s Customer.
QC 19: Flight Safety Part
- Suppliers and their sub-tier suppliers that perform any process that affects a critical characteristic identified on the “PURCHASE ORDER” and/or any attached documentation as a “FLIGHT SAFETY PART” shall obtain customer initial approval for the process prior to initial delivery and all subsequent changes prior to the delivery, as well as invoking ASQR-09.1.
- When sub-contracting any operation that affects a critical characteristic of a “FLIGHT SAFETY PART”, the supplier shall insure that the purchase order to the sub-tier supplier identifies the part as a “FLIGHT SAFETY PART” and invokes ASQR-09.1.
QC 20: Use of Certified / Approved Special Processors by Sub-tier Suppliers
- In the event the seller cannot perform the work internally and is required to delegate work to its suppliers, seller shall contact Beranek, Inc., Quality Manager to verify that seller’s sub-tier supplier is a certified / approved special processor, prior to delegating work.
QC 21: Quality Inspection System and Control of Documented Information
The seller shall provide and maintain an inspection system which shall assure that all delivered products conform to purchase contract requirements whether manufactured or processed by the supplier or obtained from one of his suppliers. The seller shall maintain controls and perform all inspections and tests required to substantiate product conformance to drawings, specifications and other purchase contract requirements. The seller shall notify Beranek Inc., of changes in product and/or process definition and always obtain Beranek Inc., approval.
ATTENTION: All documentation and records pertaining to Beranek Inc. shall be maintained and stored by the seller's as follows:
- Material Distributors for ten (10) years minimum.
- Processors ten (10) years minimum.
- General Purpose for ten (10) years minimum.
Unless otherwise specified period of time or life terms in the purchase order. The seller shall ensure that records kept in their area are stored in a way that prevents deterioration or damage and prevents loss. Where computerized records need to be kept, the Seller needs to ensure that these records are regularly backed up. Hard copies or computerized records shall be easily retrievable within 72 hours from Beranek Inc., or any Regulatory Agency request.
QC 22: FOE/FOD Requirement
Certificate of Conformance must contain the following statement. “Deliverable products are free of any foreign materials that could result in foreign object damage to the installed product or companion component/systems.”
QC 23: Conflict of Minerals
As part of Beranek, Inc. commitment to responsibility, including its policy on protecting human rights in our operations along with our supply chain, Beranek, Inc. goal is to purchase raw materials from manufacturers who have certified that their products are “DRC Conflict Free,” and we do not directly purchase any Conflict Minerals from any source.
Beranek, Inc. expects its suppliers to have appropriate policies and due diligence measures in place that will allow us to reasonably determine if products and raw materials containing conflict minerals originate from conflict-free sources, including those from the Democratic Republic of the Congo (DRC) and its surrounding areas.
In support of this Beranek, Inc. will:
- Exercise due diligence of its relevant suppliers consistent with the Organization for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the OECD Due Diligence Guidance) and expect those suppliers to do the same with their supply chain; and
- Engage and collaborate with its suppliers to communicate the use of conflict-free supply chain for Beranek, Inc. products, and
- Evaluate the progress of its Conflict Minerals Program periodically and communicate to internal and external stakeholders as applicable.
QC 24: Counterfeit Materials
Beranek Inc. acknowledges and understands there is a global issue concerning the sale and distribution of counterfeit components, and counterfeit materiel. In addition to training and communicating this phenomenon throughout our company, we are committed to procuring parts from our contracted OEM’s or authorized OEM distributors. Beranek, Inc. requires our suppliers to conform to any Federal and State requirements regarding the detection and control of counterfeit materials. If counterfeit materials are suspected, they must be reported to the Government Industry Data Exchange Program (GIDEP). Although Beranek, Inc. has not experienced an issue with counterfeit components or counterfeited materiel, procedures are in place to immediately quarantine any questionable components or materiel and initiate corrective action. If a component or materiel is determined to be counterfeit, it shall go through the disposition process, and all documented information retained, preventing it from re-entering the supply chain.
QC 25: Code of Ethics
Employees – Beranek Inc. makes it clear to employees the actions and behavior expected of them when representing the organization. The organization strives to maintain the highest standards of employee conduct and ethical practice when operating and managing its supply chain.
Suppliers – Beranek, Inc. suppliers must demonstrate the highest standards of ethics and where necessary prove that they provide safe working conditions, treat their workers with dignity and respect and act ethically and within the law in their use of human resources.
The Quality clauses noted above are to be used by the Beranek, Inc. Purchasing department to show required Quality Systems compliance requirements. The Beranek, Inc. management as indicated below has approved these clauses.
Date: August 11, 2020