Notifying Registrar of Management Changes - A TS 16949 requirement?

[jmp4429]

Yesterday we had a consultant in who told me that since we’ve had a change in senior management, I needed to notify our registrar in writing. One of our VP’s retired, and he has been replaced by another person whose position is now called “Senior manager.” Also, the MR used to report to that VP, and now reports to the plant manager.

I called our registrar this morning and the lady told me that they did not require notification of this change if it didn’t affect the Quality System.

I’m a little nervous that maybe I wasn’t able to communicate the change well and that notification might be required.

Our contract with the registrar reads

2.1.1 Inform XXXXX in writing of any changes in the Applicant's management system related to requirements of the standard (i.e. managerial or organizational structure; production; location; upgrade/downgrade of process capability or control; etc.) that could reasonably be expected to impact registration hereunder.

Wouldn't this be managerial or organizational structure? It doesn't really affect our quality system except for who the MR reports to, but I just want to :ca:

 

[Jim Wynne]

Yesterday we had a consultant in who told me that since we’ve had a change in senior management, I needed to notify our registrar in writing. One of our VP’s retired, and he has been replaced by another person whose position is now called “Senior manager.” Also, the MR used to report to that VP, and now reports to the plant manager.

I called our registrar this morning and the lady told me that they did not require notification of this change if it didn’t affect the Quality System.

I’m a little nervous that maybe I wasn’t able to communicate the change well and that notification might be required.

Our contract with the registrar reads



Wouldn't this be managerial or organizational structure? It doesn't really affect our quality system except for who the MR reports to, but I just want to :ca:

Why not just write a letter to the registrar explaining the changes?

 

[jmp4429]

Will do, thanks. Sometimes I just freak out about things

 

[Jim Wynne]

Will do, thanks. Sometimes I just freak out about things

I understand. Look at it this way: even if notification isn't required, the information is inocuous--it isn't likely to affect anything one way or another--so notification is just a matter of courtesy.

 

[Wes Bucey]

Perhaps I'm dense. It doesn't appear you've changed the management STRUCTURE as it regards the Quality System, only the person occupying a position on the hierarchy chart.

People come and go, the function remains. The oversight and reporting remain. I doubt this personnel change means that you changed work instructions, only who sees the reports. Have you also made a change in how the Internal Audit team goes about its business? Do you still have "some" senior management review the results? Probably yes. I agree with the Registrar spokesperson who has probably seen and heard of such situations dozens of times.

On my reasoning, unless the person was THE liaison to the Registrar, I see no official reason to notify. If the person was the liaison, then a courtesy notice of his replacement might be in order.

Daimler is cutting 8500 people off its payroll. Do you think they need to get blessed by any registrar as a result?

 

[D.Scott]

Wes, you are absolutely right from a business sense but when applied to a contract with a registrar I have found they are actually looking for PEOPLE changes in the quality system. We had a change in quality management - the manager moved up to director and a quality engineer went to manager. They required this in writing. I assume it would depend on the registrar but I would play safe and do as JSW05 suggests and send a letter anyway. My guess is our registrar (and maybe others) use "people movement" as an indicator - possibly like the rats leaving a ship.

Dave

 

[ralphsulser]

Also CSRs may require notification. We have a requirement in our CSR that they be notified of any change in Senior Management, and/or Customer contact representative. Also our registrar wants to be notified if the Management rep. is changed

 

[Wes Bucey]

Ralph and Dave:

I read what you write, but I'd sure like an explanation of WHY from a senior registrar officer. Seems to me like one of those "Show me the shall" moments.

Try as I might, I can't see any more importance to the change of a senior manager than a change to a critical inspector from a registrar's viewpoint. If one individual makes that much difference, there is not much of a "system" is there? Why bother with a systemic audit if only a change in an individual matters?

 

[Jim Wynne]

I read what you write, but I'd sure like an explanation of WHY from a senior registrar officer. Seems to me like one of those "Show me the shall" moments.

I tend to agree, but you have to remember that the issue is the contract between the registrar and the auditee, which doesn't necessarily have anything to do with the standard (although it should).

Try as I might, I can't see any more importance to the change of a senior manager than a change to a critical inspector from a registrar's viewpoint. If one individual makes that much difference, there is not much of a "system" is there? Why bother with a systemic audit if only a change in an individual matters?

Well, there is the matter of qualifications of individuals. It's possible to replace a well-qualified person (with whom an auditor is familiar) with a doofus. I think it's just a heads-up, fair warning type of thing. But like I said, I tend to agree with you that it shouldn't be a matter of grave concern for the registrar.

 

[ralphsulser]

Wes, RE:Notification to customer of changes in Senior Management.This is a requirement in writing directly in our Customer Specific Requirements.
Since this is a CSR we are then audited by the TS16949 registrar for compliance to the CSR in additon to the TS requirements.
The "shall" is in the CSR. Our company is not about to get into a challange with our customer. Especially since we were just awared 6 new jobs.