Minor NC - IATF Rules 5th Edition Sanctioned Interpretations against 4.2

[W. Becker]

Our CB just issued a minor NC against 4.2 because although we have evidence we (I) monitor the IATF website for updates, and downloaded the Rules 5th edition sanctioned interpretations the same day new ones were issued, reviewed and made a positive statement via email to my QM that no changes were needed, the auditor wrote that because I had not specifically called out which SI's were new, we did not present "clear evidence" they were reviewed. I'm going to appeal this on 2 fronts.
1. Although we need to "understand" (from the Rules 5th Ed. introduction) the rules, they do not influence our QMS.
2. The evidence provided shows that we did dowload and review, the clause does not state anything about retaining documented information so the level of evidence should fall in our favor.

I"m curious as to if anyone else has had their auditor ask about Rules 5th Ed during their audit. Seems like the auditor is reaching for an NC to me.

 

[Funboi]

What non-sense! Where’s the requirement to do what they are suggesting is needed. #graspingatstraws

 

[Howard Atkins]

Our CB just issued a minor NC against 4.2 because although we have evidence we (I) monitor the IATF website for updates, and downloaded the Rules 5th edition sanctioned interpretations the same day new ones were issued, reviewed and made a positive statement via email to my QM that no changes were needed, the auditor wrote that because I had not specifically called out which SI's were new, we did not present "clear evidence" they were reviewed. I'm going to appeal this on 2 fronts.
1. Although we need to "understand" (from the Rules 5th Ed. introduction) the rules, they do not influence our QMS.
2. The evidence provided shows that we did dowload and review, the clause does not state anything about retaining documented information so the level of evidence should fall in our favor.

I"m curious as to if anyone else has had their auditor ask about Rules 5th Ed during their audit. Seems like the auditor is reaching for an NC to me.

Please post complete wording of finding

 

[W. Becker]

Requirement
4.2 Understanding the needs and expectations of interested parties
“Due to their effect or potential effect on the organization’s ability to consistently provide products and services that meet customer and applicable statutory and regulatory requirements, the organization shall determine:
a) the interested parties that are relevant to the quality management system
b) the requirements of these interested parties that are relevant to the quality management system.
The organization shall monitor and review information about these interested parties and their relevant requirements.”

Statement of nonconformity
The sales and marketing process was found not fully effective

Objective evidence
Assessment of SIs found that latest issued IATF-Rules-5th-Edition SIs were not clearly evidenced reviewed for determination of impact to HMG’s QMS. IATF-Rules-5th-Edition SIs examined: SI 29 revised and reissued in April 2022, effective 1 May 2022; SI 30 issued in April 2022, effective 1 May 2022, and SI 31 issued in May 2022, effective 1 June 2022.

 

[Howard Atkins]

I agree this seems grasping at straws
Have you thought of appealing against this?

 

[W. Becker]

Yes, we will be appealing this finding...my first appeal in 22 years. As I dig further this is a bad finding on a lot of levels, and the below is the basis for our appeal.
1. Rules 5th Edition doesn't have an impact on the QMS. The introduction states that Rules 5 is binding on CBs, but that clients only need to "understand" the rules. Any requirements that Rules 5 has on the client is done through the CB. "the certification body shall require the client...." appears in several places.
2. Our CB sends out a newsletter to clients when there is an IATF 16949 SI, but no mention of Rules SI's in the newsletter.
3. ISO 9001 in Annex A, section A.3 Understanding the needs and expectations of interested parties states "However, 4.2 does not imply extension of quality management system requirements beyond the scope of this International Standard," and "It is for the organization to decide of a particular requirement of a relevant interested party is relevant to its quality management system."
4. Further in Annex A, section A.6, it delineates between "informaton" and "documented information."
"Where this International Standard refers to “information” rather than “documented information” (e.g. in 4.1: “The organization shall monitor and review the information about these external and internal issues”),
there is no requirement that this information is to be documented. In such situations, the organization can decide whether or not it is necessary or appropriate to maintain documented information." The same prhaseology appears in 4.2.
5. In fact, we did review the Rules 5th Ed SI, the same morning they were released, and I sent an email with the SI's attached and stated to the QM that no change was required, the auditor leaned in the direction that I should have called out the SI by number and we should have included them in managment review and made the statement there that no change was required.

It's a pretty well drafted appeal. I can send you the final document once it is sent if you are interested.

 

[W. Becker]

Update - 8/8/22. The appeal that was submitted was reviewed and accepted, and the NC was removed.

 

[Howard Atkins]

Good for you