What is your company policy regarding material traceability? Does your company track lots, batches, etc. for every part you consume into your products? Or, do you have some exemption for certain types of parts, for example hardware standards or COTS parts?

I note that the requirement in AS9100D only provides the guidance in section 8.5.2, “NOTE: Traceability requirements can include: …the ability to trace all products manufactured from the same batch of raw material, or from the same manufacturing batch, to the destination (e.g., delivery, scrap);”. However, this is only a note and does not say “shall include”.

Neither does 14 CFR Part 21 provide any specific requirements for the extent of material traceability required to be maintained by the QMS. However, having working in the Aerospace industry for many years, the general consensus is that every part, regardless of size, impact, risk, etc. must be traceable to it's raw material. Is this overkill for the industry? It certainly is expensive to enforce through the supply chain. I would like to hear thoughts from others on this topic.

Thank you.