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AS9100D - Updating Scope Exclusions
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AS9100D - Updating Scope Exclusions
AS9100D - Updating Scope Exclusions
AS9100D - Updating Scope Exclusions
AS9100D - Updating Scope Exclusions
AS9100D - Updating Scope Exclusions
AS9100D - Updating Scope Exclusions
AS9100D - Updating Scope Exclusions
AS9100D - Updating Scope Exclusions
AS9100D - Updating Scope Exclusions
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AS9100D - Updating Scope Exclusions


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as9100 revision d (2016), exclusions of clauses in a standard, scope of accreditation
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  Post Number #1  
Old 10th January 2017, 04:47 PM
MrOctober

 
 
Total Posts: 8
Question AS9100D - Updating Scope Exclusions

I would like some help with our scope and the exclusions written in it. Our next audit will have to be to rev AS9100D and our scope is written to rev C, what would our scope be to the new revision?

Background:
My company is a sub-tier machining vendor to a prime aerospace supplier, we only provide a machining service for their parts that they manufacture and design by removing flash and gating from their lost wax processes.

Since we are only a vendor we have exclusions written into our scope. It appears the from the correlation matrix provided by IAQG that section 7.3 Design and Development is now 8.3 Design and Development of products and services. Now, that the 8.3 clause now includes “services” does it apply to our company?

7.5.1.4 a, c, d, and e, a lot was added to this clause; 8.5.5 a) is now f), c) is now g), d) is now rolled into possibly g), finally e) is now h).

AS9100C Scope:
Electrical Discharge Machining, CNC Milling, CNC Grinding, CNC Turning, CMM Inspection, and Building of Gauges & Fixtures; Excluding Design (AS 9100 rev C sec 7.3) and Post Delivery Support (AS9100 rev C sec 7.5.1.4 a, c, d, e)

AS9100D Scope:
Electrical Discharge Machining, CNC Milling, CNC Grinding, CNC Turning, CMM Inspection, and Building of Gauges & Fixtures; Excluding Design and Development (AS9100D sec 8.3) and Post Delivery Activities (AS9100D sec 8.5.5 f, g, h)

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  Post Number #2  
Old 13th January 2017, 09:52 PM
dsanabria

 
 
Total Posts: 1,175
Re: AS9100D - Updating Scope Exclusions

Quote:
In Reply to Parent Post by MrOctober View Post

I would like some help with our scope and the exclusions written in it. Our next audit will have to be to rev AS9100D and our scope is written to rev C, what would our scope be to the new revision?

Background:
My company is a sub-tier machining vendor to a prime aerospace supplier, we only provide a machining service for their parts that they manufacture and design by removing flash and gating from their lost wax processes.

Since we are only a vendor we have exclusions written into our scope. It appears the from the correlation matrix provided by IAQG that section 7.3 Design and Development is now 8.3 Design and Development of products and services. Now, that the 8.3 clause now includes “services” does it apply to our company?

7.5.1.4 a, c, d, and e, a lot was added to this clause; 8.5.5 a) is now f), c) is now g), d) is now rolled into possibly g), finally e) is now h).

AS9100C Scope:
Electrical Discharge Machining, CNC Milling, CNC Grinding, CNC Turning, CMM Inspection, and Building of Gauges & Fixtures; Excluding Design (AS 9100 rev C sec 7.3) and Post Delivery Support (AS9100 rev C sec 7.5.1.4 a, c, d, e)

AS9100D Scope:
Electrical Discharge Machining, CNC Milling, CNC Grinding, CNC Turning, CMM Inspection, and Building of Gauges & Fixtures; Excluding Design and Development (AS9100D sec 8.3) and Post Delivery Activities (AS9100D sec 8.5.5 f, g, h)
Observation: The word Excluding has been replaced with non applicable.

The Post Delivery activities is know as warranty and they are covered under 8.2 so if all you do is provide a product that does not have a warranty (i.e. this product will work for so long or for so many times) take the complete 8.5.5 and make it not applicable.

Finally, include a justification for not applicable items. For example, design & development - explain why it does not apply.

Last edited by dsanabria; 13th January 2017 at 09:52 PM. Reason: replacing 7 with & in design 7 development
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  Post Number #3  
Old 13th July 2017, 12:40 PM
nacnack

 
 
Total Posts: 20
Re: AS9100D - Updating Scope Exclusions

dsanabria

What if part of a clause 8.5.5 is not applicable? let say f,g,h & i. Do you write those into the scope or just inform the auditor that not all parts of the clause are applicable? If we cherry pick the standard, the NA's in the scope would be huge.

Second question

I have a company that is a machine shop (aerospace) and also manufactures machines that do various automated functions (Commercial). My question is, when it comes to design and post-delivery or basically any place in AS9100D, can those Aerospace requirements be determined as “Not Applicable” for the commercial side even though its an Aerospace company. If so, can you point me to an IAQG, IAF, AAQG, some sort of reference ?
  Post Number #4  
Old 13th July 2017, 12:56 PM
howste's Avatar
howste

 
 
Total Posts: 4,925
Re: AS9100D - Updating Scope Exclusions

Quote:
In Reply to Parent Post by nacnack View Post

Second question

I have a company that is a machine shop (aerospace) and also manufactures machines that do various automated functions (Commercial). My question is, when it comes to design and post-delivery or basically any place in AS9100D, can those Aerospace requirements be determined as “Not Applicable” for the commercial side even though its an Aerospace company. If so, can you point me to an IAQG, IAF, AAQG, some sort of reference ?
Your AS9100 scope can be written to not include commercial products, but if commercial products are included in the AS9100 scope you can't exclude those requirements just for commercial products. If you also have an ISO 9001 certificate it could include the commercial products, and then your AS9100 could include only your aerospace products.
  Post Number #5  
Old 13th July 2017, 01:10 PM
nacnack

 
 
Total Posts: 20
Re: AS9100D - Updating Scope Exclusions

howste

So are you saying that the company should have a split scope, and separate certs if they do not want to include Aerospace requirements into their commercial product?

AS9100 - Aerospace Machining

ISO 9001 - Commercial Automated product
  Post Number #6  
Old 13th July 2017, 01:50 PM
howste's Avatar
howste

 
 
Total Posts: 4,925
Re: AS9100D - Updating Scope Exclusions

Quote:
In Reply to Parent Post by nacnack View Post

howste

So are you saying that the company should have a split scope, and separate certs if they do not want to include Aerospace requirements into their commercial product?

AS9100 - Aerospace Machining

ISO 9001 - Commercial Automated product
That's an option. Or if the commercial doesn't require any certification it could be scoped out of AS9100 and have no ISO 9001 certificate. If you do have both certifications the ISO 9001 could also include both aerospace and commercial.
Thanks to howste for your informative Post and/or Attachment!
  Post Number #7  
Old 13th July 2017, 05:20 PM
dsanabria

 
 
Total Posts: 1,175
Re: AS9100D - Updating Scope Exclusions

Quote:
In Reply to Parent Post by nacnack View Post

dsanabria

What if part of a clause 8.5.5 is not applicable? let say f,g,h & i. Do you write those into the scope or just inform the auditor that not all parts of the clause are applicable? If we cherry pick the standard, the NA's in the scope would be huge.

Second question

I have a company that is a machine shop (aerospace) and also manufactures machines that do various automated functions (Commercial). My question is, when it comes to design and post-delivery or basically any place in AS9100D, can those Aerospace requirements be determined as “Not Applicable” for the commercial side even though its an Aerospace company. If so, can you point me to an IAQG, IAF, AAQG, some sort of reference ?


Quote:
What if part of a clause 8.5.5 is not applicable? let say f,g,h & i. Do you write those into the scope or just inform the auditor that not all parts of the clause are applicable? If we cherry pick the standard, the NA's in the scope would be huge.
You need to make a statement as to what is not applicable to the standard and you need to provide justification so that when the auditor shows up - they are able to review and agree.

Quote:
I have a company that is a machine shop (aerospace) and also manufactures machines that do various automated functions (Commercial). My question is, when it comes to design and post-delivery or basically any place in AS9100D, can those Aerospace requirements be determined as “Not Applicable” for the commercial side even though its an Aerospace company. If so, can you point me to an IAQG, IAF, AAQG, some sort of reference ?
When you have a company that has multiple tasks... You can have multiple certificate. So to your question - can I have a certificate for aerospace with section of the company doing commercial product? - the answer is yes, However... You need to make sure that individuals in the commercial section do not cross over and do aerospace products - that will cause you and the auditor to increase the scope of the audit and include that section into the aerospace scope.

Let me know if this helps...)

Last edited by howste; 17th July 2017 at 08:36 AM. Reason: Fixed quotes.
  Post Number #8  
Old 14th July 2017, 03:32 PM
Big Jim

 
 
Total Posts: 2,803
Re: AS9100D - Updating Scope Exclusions

Quote:
In Reply to Parent Post by dsanabria View Post

Observation: The word Excluding has been replaced with non applicable.

The Post Delivery activities is know as warranty and they are covered under 8.2 so if all you do is provide a product that does not have a warranty (i.e. this product will work for so long or for so many times) take the complete 8.5.5 and make it not applicable.

Finally, include a justification for not applicable items. For example, design & development - explain why it does not apply.
There is more to 8.5.5 than just warranty. Please see the NOTE at the end of 8.5.5.

The AS9100D clarifications also provides some more illumination on the topic.

Additionally, according to my business law professors, and my attorney friends, if you deliver product with the understanding that you will take care of it if something is wrong, that is a warranty. That would make 8.5.5 difficult to ever exclude.

However, there is no reason to exclude it. It is in essence an "as appropriate" clause.

"The organization shall meet requirements for post-delivery activities associated with the products and services. In determining the extent of post-delivery activities that are required, the organization shall consider . . . " (Emphasis added)

So this would mean that you don't do any of the a - l requirements unless needed and even then that you consider them, not necessarily act on them.
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