Expanding our Company's AS9100D Registration Scope and Location

[Jcornett344]

Hey guys. I am quite new to this job as my company's ISO Management Representative and this is my first time in this or any related positions.

We are AS9100D certified and our company's scope currently includes the manufacturing of machined parts and the contract manufacturing of custom injection molded parts.

Our surveillance audit is next month but the owners decided they wanted to begin to perform fabrication jobs without even notifying me. They bought an offsite facility a few miles down the road, and a bunch of fabrication equipment (plasma cutter, welders, shear, brake etc.). I never found out until the equipment began to arrive.

With our surveillance audit a few weeks away, this has got me very nervous as I am not sure what changes, if any, this requires us to make to our QMS.

Can anyone advise me as to what those revisions might be? Or any other steps that may be required?

 

[Sidney Vianna]

Your management has to be careful about this. Transfer of work, especially the ones that are not transparent to the customers and CB's, is one of the most frequent reasons for quality escapes. That's why AS9100D stipulates

The organization shall establish, implement, and maintain a process to plan and control the temporary or permanent transfer of work, to ensure the continuing conformity of the work to requirements.

The process shall ensure that work transfer impacts and risks are managed.

From a certification perspective, it also impacts the certification structure. Best thing for you to do: communicate with the CB about the changes, let them know if the products to be manufactured at the second site are part of the scope of certification and when the new site will come on line. Also, check if any of your customers have requirements for informing them of "change of manufacturing facility" or similar. Your management team might not realize the implications of switching manufacturing processes to a second site.

Good luck.

 

[Big Jim]

If I understand correctly, this is not work transfer, that is work that you currently do in-house or sublet, that is part of the scope of registration.

It sounds like new work, not related to your current scope.

What is the intent of your company? Do they want to bring this into the scope of registration?

If they don't, the only concern is to make sure that any advertising doesn't indicate those activities are included in what is registered.

If they do, your audit needs to include an expansion of scope and that starts with conversations with your certification body.

 

[Sidney Vianna]

If I understand correctly, this is not work transfer,

According to the IAQG SCMH

Aviation, Space & Defense companies continuously change the source of supply or manufacturing of a component, a component package or assembly across a company or its external supply chain. Such movement of the work (products and associated activities) from one manufacturing site to another (internal or external) is referred to as “Work Transfer”. Work Transfers often cause On Time / On Quality issues because they are not properly managed.

So, if the new location, "a few miles down the road" (according to the OP), is deemed a new site and the work at the new location is under the current scope of certification, that would be considered work transfer. Obviously, irrespective of that, the new location will bring risks that have to be managed.

 

[howste]

...decided they wanted to begin to perform fabrication jobs...

It looks to me like this is new work that is outside the scope of the existing certification.

 

[Sidney Vianna]

It looks to me like this is new work that is outside the scope of the existing certification.

It could be. That's why I mentioned the need for a dialogue with the CB concerning the scope of certification. But the new "fabrication jobs" could be part of the machined parts which are currently in the scope of certification.

 

[Big Jim]

According to the IAQG SCMH

So, if the new location, "a few miles down the road" (according to the OP), is deemed a new site and the work at the new location is under the current scope of certification, that would be considered work transfer. Obviously, irrespective of that, the new location will bring risks that have to be managed.

Agreed.

That is why I asked if this was current work being transferred or if was completely different work. It appears to be the latter and needs clarification.