All,

We are cuurently going through a preassessment audit with our registrar. We have just been informed that if we distribute fully assembled "pass through" parts, the sister company we get them from must be registered to TS within 90 days of us. Of course they may be shipping "pass through" stuff from another sister company which would then have to be registered within 90 days! This could have a HUGE domino effect possibly meaning that 40 companies worldwide would have to be registered within 90 days of one another!

Is this really correct? Is there no way around this????

Please help! :confused:

Who is doing your preassessment? It sounds to me like your customer is talking. I would ask to see the written requirement for the 90 time limit and what happens if your sister company doesn't make it.

I agree with Randy. Find out where the requirement is. TS 16949 requires that suppliers be certified to ISO 9001:2000, not TS. Really it sounds to me like this should fall under outsourced processes, but I don't see a 90 day requirement anywhere. I even checked Ford, Chrysler, GM, and Delphi customer-specific requirements...

Our registrar is UL. Our auditor called back to her office to confirm the 90 day rule and was told that this is indeed the case. It seems almost impossible to comply with!

To me that's not an acceptable answer from them. Their office doesn't make the rules - they need to show you the where exact requirement is. It needs to be in the standard, the customer-specific requirements, or in UL's contract with you.

To me that's not an acceptable answer from them. Their office doesn't make the rules - they need to show you the where exact requirement is. It needs to be in the standard, the customer-specific requirements, or in UL's contract with you.

No kidding!! As she stated in her first post - this could be a huge issue with 40 companies worldwide!

Josianna - is it possible that some misunderstanding is happening? Did she perhaps get the impression that they are multiple sites under the same registration?

Howste - does the 90 day rule apply to that scenario? I have been away from the automotive industry for the last three years.

If TS requires suppliers to be ISO - maybe the auditor meant that the supplier/sister company would need to be ISO registered within 90 days.

No kidding!! As she stated in her first post - this could be a huge issue with 40 companies worldwide!

Josianna - is it possible that some misunderstanding is happening? Did she perhaps get the impression that they are multiple sites under the same registration?

Howste - does the 90 day rule apply to that scenario? I have been away from the automotive industry for the last three years.

If TS requires suppliers to be ISO - maybe the auditor meant that the supplier/sister company would need to be ISO registered within 90 days.

I couldn't find any 90-day rule, unless it's talking about the 90 days in which corrective actions must be resolved? This is specified in the IATF "rules" document.

Here's about the only scenario I can think of that might apply here: They perform the audit and find that supplier(s) are not 3rd-party registered to ISO 9001:2000. They write a nonconformity, which must be resolved within 3 months (90 days). The only way to resolve it would be either certification of the supplier(s) or to have waivers from all customer(s) involved with the affected product(s).

If this is the situation, then the only "out" is an agreement from the customer(s) that supplier certification is not necessary.

From TS 16949:
7.4.1.2 Supplier quality management system development
The organization shall perform supplier quality management system development with the goal of supplier conformity with this Technical Specification. Conformity with ISO 9001:2000 is the first step in achieving this goal.
NOTE The prioritization of suppliers for development depends upon, for example, the supplier’s quality performance and the importance of the product supplied.
Unless otherwise specified by the customer, suppliers to the organization shall be third party registered to ISO 9001:2000 by an accredited third-party certification body.

From the "Rules" document:
For each nonconformity the Organization shall perform a root cause analysis and define corresponding corrective actions to be implemented as soon as possible, in any case within three months from the end of the site visit.

Here's about the only scenario I can think of that might apply here: They perform the audit and find that supplier(s) are not 3rd-party registered to ISO 9001:2000. They write a nonconformity, which must be resolved within 3 months (90 days). The only way to resolve it would be either certification of the supplier(s) or to have waivers from all customer(s) involved with the affected product(s).

Thanks howste. Because they are a supplier, not because they are sister co.'s. And registered to ISO - not TS? That would make sense then.

josianna - be sure to let us know how this unfolds! And if you don't mind - could you post the exact wording of the finding from the auditor when it is written up? This would help anyone who may be able to help you to answer a corrective action request if howste's scenario is what has happened. Good Luck!

My organization is ISO 9001:2000 so I don't know how relevant this is, but we also distribute product from our sister companies. Our way around is that we "buy" it from them...WE are the Customer. WE have requirements.

Our sister companies are our on Approved Vendor List and are treated like all our other suppliers. We have indicated the method used to get them placed on the Approved Vendor List and their products/delivery are monitored for compliance. If we do not like their product, we complain and are entered into the Customer Complaint system (rather nice since I have access and I can see if the other facility is treating us in an effective and timely manner ;) )

Thank you for your help everyone. We are trying to get some clarification/ something in writing from UL. I'll let you know what happens.

Josianna,

If you are simply passing through (distributing) completed parts and not performing anything "value added", you are not eligible for TS certification. It sounds like your registrar may be saying that you can get TS as a support site to the sister company that is actually making the part.

If you are making some parts, and distributing others, the scope of TS could only apply to the parts you make and you could have your own stand-alone certificate. If you only distribute, I can see where the requirement for the sister company to be TS would come in. The 90 days may be the registrars requirement for completing all sites within a multiple site audit scheme.

From howste,
"I couldn't find any 90-day rule, unless it's talking about the 90 days in which corrective actions must be resolved? This is specified in the IATF "rules" document."

howste, good call and I agree.
But what I find disheartening is that there are auditors/CB's playing these word games with their clients. IMO this type of behavior should be reported to the IATF for review.

But what I find disheartening is that there are auditors/CB's playing these word games with their clients. IMO this type of behavior should be reported to the IATF for review.

You said it! What's the hassle in getting this clarified for josianna? She is waiting for "clarification/something in writing"? If it is not in any standard, any customer specific requirements, the UL contract, or any internal documentation then what's up?

It sounds like a way to make more money by the registrar to me. I can't find anything about the 90 rule and our registrar didn't know of the requirement either.

We use the same registrar and have experienced both "the good, the bad and the ugly" (all puns intended) auditors with them. Where is this requirement is coming from? Is it a UL interpretation? or does your own system require your suppliers (including sister divisions) to become registered? I'm not as versed in 16949 as I am in the 9001:2000 standard, but here's what some of our customers (in the Automotive industry) have asked us to do:

In some instances, you can get away with completing a QSA (Quality System Assessment) for those Automotive industry customers... The QSA is only a kind of Gap analysis survey (a rather lengthy one) which some of our customers require instead of forcing us to become registered to QS-9000 or TS-16949 [yes, I know QS-9000 is on its way out, but some of our customers refuse to bury it and move on to 16949].

Thank you for your help everyone. We are trying to get some clarification/ something in writing from UL. I'll let you know what happens.

josianna - anything yet?

Nope, nothing yet that I know of. Hoping to hear something next week!

What this MAY refer to is the "support site" requirement within TS, which IS indeed being put out there as a requirement that the support site be audited within 90 days. They're probably referring to page 2 of the "Automotive Certification Scheme for ISO/TS 16949:2002 Rules for Achieving IATF Recognition" document. It says that if another site is a "support" site, it's supporting function must also be audited as part of YOUR audit. Fer' instance, here we have "territory managers" who perform the initial customer contact and funnel the orders to us. The TM's work out of our "mother ship" location, the corporate office. In preparing for our TS upgrade audit we were told that our registrar will require an audit of that support function within 90 days of OUR audit.

That said, the IATF document goes on to say "supporting functions shall be audited as they support a site but cannot obtain independent ISO/TS16949 certification." Presumably unless, as in our case, that support function is part of a larger organization that DOES have independent TS certification anyway.

I'm just guessing this is what your registrar was referring to?