Subcontractor Development (4.6.2.1 and C9)

QS9000 third edition Appendix I.4 Subcontractor development says " When a subcontractor is so small as to have adequate resources to develop a system according to QS9000 Section 1, certain specified QS9000 subelements may be waived by the supplier of their subcontractors" .

Based on this,
a) can we waive our subcontractor the requirement of having quality manual and documented procedures , and ask them to maintain our Subcontractor Quality Assurance Manual instead. Has anyone done this?

b) what other subelements of QS9000 can be waived?

We are trying to waive these elements for those small but good subcontractors who may not be able to maintain voluminous procedures.

Granted, not all of QS 9000 applies to the smaller companies, but you cannot waive all of the requirements. If you read further in I.4, "The majority of QS-9000 contains fundamental quality system requirements which would be of value to any size of provider of production/service parts/materials. Note that there are many ways to implement a compliant system, so a simpler approach could be used for the smaller subcontractors."

Some things like APQP can be standardized for a process, rather than on a part specific basis. If there is only one set of gages that is used to measure the output of the process, then do measurement system studies have to be conducted for every single PPAP? (repeatability and reproduceability can be proven through one study, while bias, linearity and stability can be proven through the collected inspection records.) Once again, the adage K.I.S.S. is totally appropriate.

Advance HAPPY NEW YEAR folks!

There are only two more days for the deadline of developing subcontractors to either certification / compliance to ISO9001 to expire.Can you share the status of compliance to this requirement?

Few of our subcontractors may get certified only in the month of Jan /Feb 2002. Any one facing the same situation?

Yes, we are facing the same problem. I received a waiver from our registrar giving us another year to get those suppliers certified or compliant.

Angela

The REGISTRAR gave you a waiver? Has the IAOB/IATF/AIAG extended the deadline or is this something specific to your registrar? I did not think a registrar could grant a waiver.

Tom

How can a registrar give waiver when the Big three / IATF requires all QS9000 registered companies to develop their subs to either certification or compliance to ISO9000.

tomvehoski wrote:

Has the IAOB/IATF/AIAG extended the deadline or is this something specific to your registrar?
Would be happy if they had done it.

What about the other QS9000 companies?

I wrote to them about my situation. They contacted a big wig at Ford. ( We mainly supply to Ford) and they gave them the OK to give us another year.

Angela

Do you have a documented WAIVER from FORD.

What about your other customers? Have they agreed?

I have a document from my registrar's stating that we cannot be audited on the three suppliers for the next year. The letter also states the individual that agreed to this from Ford. It says that we are a preferred supplier to Ford and it would not suite them for us to be issued a major non-conformance.

Angela

So basically you are saying that your registrar went to Ford and obtained a waiver for you. It is NOT a blanket statement saying you (or everyone else) have another year to get your suppliers certified. Am I correct? Has someone from Ford actually signed the letter?

Tom

Yes that is what I am saying. It is a letter pertaining strictly to my company. This is what the letter states

Pursuant to our recent telephone discussuin and e-mails regarding the three subcontractors that your company is having difficulty in meeting the subcontractors requirements as stated in the IASG Sanctioned Interpretations, RE: C9 Supplier Development. For the following subcontracts:......

This letter is a waiver for ---------- auditors tha the three above subcontractors are not to be considered when auditing the C9 Supplier Development Requirement at ----- for the next year (2003)

Ford Motor Co. (Russ Hopkins) has stated that ------ is a very good supplier with zero PPM's and should be allowed additional time to resolve these subcontractor issued with the above three suppliers.

A couple of issues here for me: 1) I didn't realize that a registrar could wear the hat of mediator between customer and supplier (I learn something new every day) and 2) this has happened a couple of times - the Big 3 comes up with a "requirement" and then waives it. Now I am not saying that there aren't valid reasons for this out there, but why come up with a date to comply and then turn around and change it for some suppliers? I guess this is called a "flex requirement"! Again, I am not saying there aren't valid reasons to consider waivers, but I have never understood the waiver criteria.

Ok. They are not waiving the requirement for us. They have given us one more year to either get them compliant or registered. I believe the reason for their generosity is largely due to one of the supplier being an approved supplier from them. We were in a catch 22 situation. We had to use the supplier but as the requirement states their being an approved supplier did not negate our responsiblity. What were we going to do? The supplier would not allow us onsite. Ford or Visteon did not want to change their approved supplier. The supplier had no plans to pursue certification. Ford had no choice but to do something for us. We had supplied to them for approx. fourty years. Our PPM's our very low. There refusing to help us would have put us out of business. If we lost out certificate we could no longer supply to them. They are approx. 65% of our business.
But again they have not completely waived the requirement. Just extended the time we have with three of our suppliers. We still have ten other suppliers that have to meet the requirement.

Angela

Angela - don't get me wrong: I am not being critical of your situation. It's just that this is somewhat of a "hot button" here at the Cove. The issue of waiving or delaying a requirement by the Big 3 has been going on for years. As far as getting a delay for your company, your situation is in no way unique (although I haven't often heard of registrars getting in the middle like yours did) . That's why I call, especially Sanctioned Interpretations, them "flex requirements". It doesn't appear that there is always a rational system for granting these waivers or delays. Your situation sounds, like you said, like a catch-22. Ok. What does that mean to any supplier trying to look for a delay due to, what they consider, good reasons? There is no system that I can find for rationally granting these concessions. Maybe I am showing my ignorance here( I have a lot of that).

Ok, so then is it rational to put us out of business because they can't force their approved supplier to be certified. Is it rational for me to be out of a job? Don't get me wrong, I did not receive this extension easily. I wrote to people, I threatened our registrar with taking business away. I did everything short of breaking legs to get an extension. There is something everyone here needs to remember, your registrar works for you. Just in case anyone is wondering our registar is very creditable. We are not registered by a fly by night registrar.

Angela

I should probably mention that we supply them with labels. They are considered production parts because they label the engine, radios, car seats etc. The car would run if they were produced wrong but they are still a production part.

Angela

Angela – I am sorry, but I am not trying to say that your registrar is doing something underhanded I am sure that your registrar is within their bounds to do what they did for you. I just have a problem with "adjustable requirements" depending on your need without a rational (meaning up-front, across-the-board applicability) system for handling adjustments. I am sure that for you (and I agree with you), you have sufficient reasons for getting the delay. It's just that it isn't very obvious to me that there is a consistent system to back these decisions up(the key word is "system"). I think that's why so many of us reacted the way we did when we heard that you received a delay in the C9 application date. (That's why I say that this situation is not unique to your company.) Anyway, I appeciate your situation and am glad you received the delay. You would not want to lose suppliers!

is it rational to put us out of business because they can't force their approved supplier to be certified
Angela, being a subsidiary of Ford we have the same problem. Here is one with a different spin: We buy stampings from a Ford stamping plant, restrike the panel to make it into a right hand drive and send it to Ford Brazil for assembly. The stamping plant we buy from is not ISO registered anymore. Now by the Sanctioned Interpretations we need to assist them in becoming ISO registered! We also have a few other Ford designated suppliers that fall into the same category. I contacted Ford concerning this issue and was told that I should not incur any additional costs due to a Ford designated supplier! I'm leaving it at that.

It is a Ford stamping plant and there not registered? Boy, that does put a different spin on it. There really is no way around it. Glad to see someone understands this dilemma. I worked on this from July 02 through Dec 02. It has been a nightmare. For me the nightmare is not over yet.

Angela

I just found the following guidance for major/minor nonconformances concerning non-registered suppliers on www.qs-9000.org.

Advisory: QS-9000 Clause 4.6.2.1 and Sanctioned Interpretation C9 (December 10, 2002)

Situation:

QS-9000 certified supplier site not meeting the requirements of Clause 4.6.2.1 and Sanctioned Interpretation C9 related to subcontractor development.

Finding recommendations:

Major non-conformity:
1) Non-compliance with 4.6.2.1 and C9, and
2) Certified supplier site has performance problems as identified by customer performance trend data including, but not limited to:

a. Delivered part quality
b. Customer disruptions including field returns
c. Delivery schedule performance (including incidents of premium freight)
d. Customer notifications related to quality or delivery issues, and/or

3) Other non-conformities in the certified supplier system indicating either a likely failure of the quality system or conditions exist to materially reduce its ability to assure controlled processes and products.

Implications: A “major” finding means certification probation status with four months to remedy the probation as provided in R3 of the Sanctioned Interpretations currently in effect.

Minor non-conformity:

1) Non-compliance with 4.6.2.1 and C9, and no other performance or quality system factors as listed above.

Implications: A “minor” finding requires 60 days to correct. If the “minor” is not corrected, the result is a “major” finding as provided in R3 of the Sanctioned Interpretations currently in effect.

The nonconformity would be issued when identified.

Just reread this after I posted. At first I thought that if the subcontractor was causing quality problems and not certified, the NC would be raised to a major.

Looking back now I read it as if YOU have problems, even if the supplier has nothing to do with it, it will still be a major. So, if I am QS and in controlled shipping or some other situation, and have a completly unrelated supplier not certified, it still becomes a major even though the supplier has nothing to do with it.

Is anyone else reading this the same way? Looks scary.

Tom

Tom;

I just read the advisory. Reads to me as if you do not meet the requirement and have quality issues it is a major. If you have system failures and do not meet the requirement then it is a major. Your right though, seems to read that it doesn't matter if the supplier caused your quality issues or not.

Angela

I received this reply when I questioned IAFT about being required to use non-registered suppliers by the B3.
Randy: these are excellent questions.

We can waive these few cases where registration is not feasible, reasonable or other methods have been taken to assure sub-supplier development.

Since Ford has directed use of those sub-suppliers, then Ford has other methods to assure sub-supplier development. That is why you were directed to use those sub-suppliers.

DaimlerChrysler has already approved some unregistered sub-suppliers for similar reasons. So there is precedent.

Please do the following, if possible, electronically via e-mail:

· Please send the list of sub-suppliers in this condition to both Bob and to me.
· Please send us the Ford document which requires use of those particular sub-suppliers (including details of addresses, parts, services, etc.)
· Please send us the list of your other sub-suppliers and their certification status (we need this to prove to the registrar that only the directed sub-tiers are in this condition)

Randy: I understand your concern and we will take care of it, since you certainly appear to have a legitimate case.

Russ Hopkins

If anyone else is in this situation, I hope this helps.

I am in a similar situation.
We are a tier 2 supplier to GM. One of our sub-suppliers is not ISO registered.
We know that this same supplier supplies to Delphi direct.
Would it be our responsibility for sub-supplier development to that supplier? Wouldn’t it make more sense for Delphi being a tier 1 supplier?
Also, we were basically directed to use this supplier by GM.

I apologize if I am beginning to sound like a broken record.

If you are not a direct supplier to the Big 3, you have to continue to develop your subcontractors with a goal of COMPLIANCE. The C-9 interpretation is for tier 1 suppliers. We have been audited at all 10 locations since the interpetation and have had not had an issue with this even though some of our suppliers are not certified.

I understand that others on these boards have been told differently by their registrars and still others are working on waivers from their customers. It appears to have a lot to do with who your registrar is as to how it will be audited.

This is one of those requirements that in my mind don't add one thing to the quality system. It serves no one but those who do the certifications. Having a certificate DOES NOT ensure good quality. Neither does having a "so called" perfect QMS. The proof is in the performance not in the paper.

If my registrar were to make the interpretation that I as a tier 2 or below supplier were required to ensure all of my suppliers were certified, I would tell him I was looking for a new registrar.

Ask your registrar how they will be auditing you on it and you may find out you needn't be worried.

Dave

Dave,
You say that "The C-9 interpretation is for tier 1 suppliers".
Where is that written? Is it something that I would be able to prove to my reg.?

Thanks

Avogel -

Have a look through this thread - the info from our registrar is there and I think there is a link to the actual IASG document.

http://Elsmar.com/Forums/showthread.php?s=&threadid=451&pagenumber=3

Dave

Reading this thread with some interest and anxiety. Does this apply to ISO/TS 16949 as well as QS9000.

We are a Tier 2 supplier and expecting an audit next month. We have suppliers and subcontractors who are not certified and some who don't really intend to be - one has just 2 or 3 employees and doesn't feel the necessity.

Will we be required to seek other suppliers if they are not willing to get certified?

Sue

Dave Scott,
Thank you.
The letter from your registrar was very informative.
But I guess that the only thing that would need to be clarified is that “Customers subscribing to this document” is referring to the list on page 79 of the QS-9000 3rd edition and not referring to all customers that are QS certified.
If so, I think I have the answers that I am looking for.
It seems that the answers were within the definitions of the terms Subcontractor and Supplier. Pretty elementary wouldn’t you say?

Allen

According to my registrar "customers subscribing to this requirement" means any company that subscribes to QS. Not just OEM's. Again that is the interpretation that I received from my auditor.

Angela

Angela said:

According to my registrar "customers subscribing to this requirement" means any company that subscribes to QS. Not just OEM's. Again that is the interpretation that I received from my auditor.

Angela


The official requirements at QS-9000.org support the above statement. Check out the "Update on Section 4.6.2.1 and C9" link:


2. Does 4.6.2.1 and C9 apply to all tiers of subcontractors?


No. Section 4.6.2.1 and C9 only apply to those subcontractors of suppliers who have QS-9000 certification.



Basically if you are QS-9000 certified, all off your production part suppliers and critical service suppliers are affected.

Tom

2. Does 4.6.2.1 and C9 apply to all tiers of subcontractors?

Still, It refernces the same two terms: Subcontractor & Supplier.

Where in this answer does it say that "customers subscribing to this requirement" means all qs certified companies?

We still don't know what the true meaning of Subcontractor & Supplier is.

The terms are officially defined in the glossary of QS-9000, which I don't have in front of me right now, but basically:

Supplier = organization that is implementing the standard. This would be your company if you are implementing QS. Hence all of the requirements are stated as "the supplier shall".

Subcontractor = anyone that the supplier buys components, materials or critical services for. You only have to worry about subcontractors that are critical to quality.


ISO 9001: 2000 and ISO/TS 16949: 2002 have changed the terms to:

Supplier ------> Organization
Subcontractor ------> Supplier

Customer remains unchanged.


"Subscribing" is not officially defined in QS. Its synonyms include "agreeing", "supporting", "endorsing", "get behind", etc. So if you implement QS you are subscribing to it.


Tom

tomvehoski said:

The terms are officially defined in the glossary of QS-9000, which I don't have in front of me right now, but basically:

ISO 9001: 2000 and ISO/TS 16949: 2002 have changed the terms to:

Supplier ------> Organization
Subcontractor ------> Supplier

Customer remains unchanged.

Tom,
You’re defining these terms from TS. My next audit is for QS. The definitions seem to be totally different. All I am asking:

Does "customers subscribing to this document" mean customers that are Qs certified, or other OEMs listed on page 79 of the QS 3rd.

Angela says her registrar says that it is all customers with Qs certification.
Dave Scott says that it is customers listed on pg. 79.

If you will look in the Qs 3rd you will see this as part of the definition to Suppliers and Subcontractors.

With all due respect, the definitions in QS-9000 use the words "directly to". The "subscribing to" in this context has been defined as the signatories on page 79.

I agree that it only applies to companies who are QS certified. But the fact remains that you can be certified yet not be a direct supplier. If the interpretation were to mean ALL QS-9000 companies, it would be redundant to distinguish suppliers and subcontractors as no one but a QS company would be reading the clause in the first place.

There is a distinct gap between suppliers and subcontractors and that is one of the reasons the Big 3 are reluctant to "open the gates" for 16949. Common sense and review of the QS standard show a number of "requirements" which may be good for tier 1 suppliers but become non-value-added nonsense the further down the supply chain you go.

Avogel - 16949 DOES require all suppliers to be certified so I am only speaking of QS. It should also be stated that unless you are a tier 1 supplier, there is no requirement (YET) to be certified to 16949 - only to ISO 900x. If you go for 16949 as a tier 2 or lower supplier you are in for the same troubles we have had in QS. We are continuing our QS untill it dies but have no intention of going to 16949.

In the meantime, I would like to suggest for those of you that are having an interpretation problem on this issue, approach your registrar with a comment made by our friend from across the pond - "Do you agree with that or shall we find another supplier of your non-critical commodity service who does agree?". Thank you Jim Wade, even though it is taken out of context. I think it says it perfectly.

Dave

we have a supplier who is starting up a brand new facility.
is there a time frame for which they have to get certified?
they seem to think they have 1 year after sop, I think they need to have a pre assessment before ppap.
any help would be appreciated.:confused:

Depending on your customer, yes, there is a deadline. QS-9000 is dead. You need to be thinking about new ISO ot TS-16949 as your system.

Al...

Sarah,

The timeline for getting a new company registered is up to them and their customers. Six to 12 months from startup is a "standard" accepted by most companies. Note that if they are going for TS, they will have to show 12 months of production data, so registrars I have talked to recommed start with ISO 9001: 2000 if ready sooner and upgrade to TS at the time 12 months of data are available.

See some of the other threads in the 16949 forum.

Tom

In the sanctioned interpretation of subcontractor development (4.6.2.1), is it required to perform an "on-site" audit of all non-certified suppliers, or can waivers be granted without an in person audit? I am confused!

From AIAG:
----------------------------------------------------------------------------------
Element 4.6 Purchasing

C9 Supplier Development (4.6.2.1) (07/01/01)

“Goal of subcontractor compliance” requires subcontractors to achieve compliance within a defined period of time not to exceed 18 months from the effective date of this sanctioned interpretation. Minimum subcontractor compliance shall be certification by an accredited certification body to a current version of the ISO 9000 Quality Management Series of Standards, excluding ISO 9003; plus any requirements specified by the customer. Assessment by an OEM or an OEM-approved second party will be recognized as meeting subcontractor compliance requirements to 4.6.2.1.

Note: The second note under 4.6.2.1 referencing “prioritization” does not negate this requirement.
----------------------------------------------------------------------------------

Personally I think this interpretation is more clouded than the original text.

That said,

Since QS-9000 will be defunct in about 180 days I would not put much effort or worry into the matter, who can gig you on a defunt requirement?

Also,

Nowhere does it mention anything about "on-site" audits, only assessments that can take many forms. Ask your customer if they will approve you as the second party assessor and at the very least you can submit a self assessment form to your suppliers. No need to travel across the world and personally visit each supplier. The best bet is to ask the customer what they want, and get it in WRITING;)

If you supply more info as to your business and customers I'm sure we can submit more detailes comments.

Al...

David,

There are a couple other threads here that will probably answer your questions.

Your options are basically:

1. Get a waiver from your customer - not normally very easy to do.
2. Do your own audit. The training/experience requirements for the auditor are pretty strict, so you can't just send anyone out for a 1/2 day visit and call it an audit. You need objective evidence of the system.
3. Get them certified.
4. Hope your auditor does not notice or does not make a big deal about it.

There is more information at www.qs-9000.org. Select the "additional information" link for the interpretation of the interpretation.


Tom

Related threads:

http://Elsmar.com/Forums/showthread.php?s=&threadid=5800

http://Elsmar.com/Forums/showthread.php?s=&threadid=4694

http://Elsmar.com/Forums/showthread.php?s=&threadid=451

http://Elsmar.com/Forums/showthread.php?s=&threadid=472

http://Elsmar.com/Forums/showthread.php?s=&threadid=495

http://Elsmar.com/Forums/showthread.php?s=&threadid=478

http://Elsmar.com/Forums/showthread.php?s=&threadid=4813

Polls

http://Elsmar.com/Forums/showthread.php?s=&threadid=5800

and

http://Elsmar.com/Forums/showthread.php?s=&threadid=4694