Is it okay to mix some fasteners, different lots, manufacturers, at shipping time?
This edition of the Fastener Training Minute with Carmen Vertullo was originally published May 20, 2019 as “Comingling” during episode 140 of Fully Threaded Radio.
I received an interesting question from one of our Fastener Training Institute students, and it had to do with a very important word. At least it used to be a very important word back in the 90s. That word was commingling.
The question read like this read like this: I cannot find in the 1999 FQA anything about commingling of product. Is it okay to mix some items, different lots, manufacturers, at shipping time? I know it is best not to do so, but is there anything in writing that says it’s not allowed.
Well it was very interesting to get that question because it used to be of great concern back in the 1990’s when that thing called the FQA (Fastener Quality Act) raised its ugly head for us in the fastener industry. One of the big issues with the Fastener Quality Act was we could not commingle product. I’m not going to talk deeply about the Fastener Quality Act, but basically the government decided it needed to regulate the fastener industry and one of the constraints that was going to be placed on the industry was that we could not commingle different lots of product either for shipping or packaging or plating or other secondary processes.
So this is how I answered that person’s question I said: When the FQA was first conceived it had a lot of requirements that did not make it to the final cut. No, or limited commingling was one of those requirements. I believe the ACT allowed us to maybe initially commingle to separate lots. In the final version of the law, a distributor or supplier can do any kind of commingling they want because there are no legal requirements for distributors under the Fastener Quality Act, only for manufacturers and importers. Now having said that, I will also say it’s not a good idea to mix lots of the same size and type of fastener for plating or any other secondary processing. If you do it, you should take steps to be sure the product is in conformance before you do the secondary processing whatever it may be, whether it’s plating, packaging, kitting, patch pellet drilling, whatever.
Also, this is the most important note to keep in mind, virtually all but not all fasteners are manufactured in ISO registered facilities these days, so fasteners are not even subject to the Fastener Quality Act. So if you are a supplier, there are no restrictions on commingling product for any purpose under the Fastener Quality Act, but you shouldn’t do it. And if you do do it, make sure you take steps to ensure that the lots have good integrity and they’re in conformance prior. In case there is a problem, you won’t have to end up scrapping more material than is necessary. Well, that’s about all you need to know about commingling and I hope you can put it to good use.