Customer Specific Requirements - Packaging Spec

[mege83]

Hello Everyone,

This is my first post as I just found this forum due to a recent non conformaty during our surveillance audit on Customer Specific Requirements.

The situation was that we have an automotive customer on which we have been supplying parts for the last 2 years with approved PPAP along with annual revalidations. During our last IATF audit a non conformance was raised as we didn't have evidence of the submission of the called packaging spec in their supplier manual which states this: "All purchased part suppliers will be required to fill out a XXXXX Production Component Packaging and Shipping (FORM XXX)."

The packaging we use complies with all their requirements but this form was never submitted and hence we do not have it signed but customer have been receiving parts for over a year. Our scorecard doesn't reflect any reduction due to this situation so I would think they accepting our parts(packaging).

This was the base to raise it as major as we were not complying with CSRs.

Any thoughts on this?

Thanks

 

[Johnny Quality]

The nonconformity sounds valid but it was raised as a major?!

 

[Sebastian]

CSR was issued by customer representative - person A.
Parts were received by person B, who was not aware of CSR issued by person A.
Person B didn't raise any complaints due to own incompetence, so person C who prepares scorecard, gave you 100%.
CSR remains CSR, and accepting delivery doesn't mean CSR was void.

Your organizational process of CSR management was not effective.
You know now, that XXXXX Production Component Packaging and Shipping (FORM XXX) exist.
CSR were given to you some time ago.
Did anybody review it then?
Did anybody evaluate it, trying to find what is applicable or not to your organizational activities?
Did anybody work on addressing applicable requirements in your own processes, e.g. reflecting them in internal instructions?

Major, probably because it applies to all products they supply.
Maybe if they "overlook" one of CSR, they overlook others as well, so major is justified.

 

[Jim Wynne]

This is an old problem. I can recall a similar situation in a QS9000 audit a long time ago where I argued that a PPAP approval was tacit approval of everything that was in the approved PPAP package. I managed to back the auditor off, but it was a close one. You have the customer requirement, and presumably had it at the contract review stage. It was overlooked or disregarded for some reason, and never got done. This is the essence of the NC, and it doesn't matter much that the PPAP was approved. This situation, as far as the level of nonconformity is concerned, could have gone deeper than it did, but I don't see a one-off thing like this rising to the Major level. I would contest that, but not the NC itself.

 

[Sebastian]

Single case yes, but when all PPAPed parts were delivered without this form no.
I do not know their customer PPAP procedure, but one of appendixes of PPAP file mentioned in AIAG PPAP manual was record of compliance with CSR. It would not be a first time, when supplier writes "not applicable" or "ok" or doesn't submit any record at all, but PPAP evetually get approval.

 

[Jim Wynne]

Single case yes, but when all PPAPed parts were delivered without this form no.
I do not know their customer PPAP procedure, but one of appendixes of PPAP file mentioned in AIAG PPAP manual was record of compliance with CSR. It would not be a first time, when supplier writes "not applicable" or "ok" or doesn't submit any record at all, but PPAP evetually get approval.

First, there is confusion over the term "Customer-Specific Requirement." In IATF-Land, this refers to those requirements that alter or expand upon clauses of the 16949 standard. They are available for review here: Customer Specific Requirements – International Automotive Task Force (iatfglobaloversight.org). This means that there are "customer requirements" and "Customer-Specific Requirements," and there is a difference.

That said, the requirements codified by the customer still must be honored. We don't know the extent of the issue, nor do we know whether or not the customer actually gives a rat's posterior about it. I have seen many requirements that were at some time functionally abandoned by customers that were never removed from the written requirements. We also don't know whether in this specific case, the issue was raised internally by the customer at the time of receipt and a person with authority to do so said "Don't worry about it." The whole point is that you can't have a major NC, or advise that an NC should be major without knowing a whole lot more about the issue(s).

 

[mege83]

Thanks everyone for the inputs. The CRS was reviewed but there was definately a lack of follow up on that documentation that resulted on the NC. What I can get from the comments is that CSR superceed any PPAP approval.

Based on your experience, how do you address "extraordinary" requests from CSR as you can not take exception; well...you probably can but will not get it signed back from customer. You don't have any other option but to accept them if you want the business?

When you have only a handfull of customers this should not represent a problem but what about when someone has 20-30 customers under IATF.

These questions might be naive but just trying to get my head around how things actually work.

 

[Jim Wynne]

Thanks everyone for the inputs. The CRS was reviewed but there was definately a lack of follow up on that documentation that resulted on the NC. What I can get from the comments is that CSR superceed any PPAP approval.

Based on your experience, how do you address "extraordinary" requests from CSR as you can not take exception; well...you probably can but will not get it signed back from customer. You don't have any other option but to accept them if you want the business?

When you have only a handfull of customers this should not represent a problem but what about when someone has 20-30 customers under IATF.

These questions might be naive but just trying to get my head around how things actually work.

All customer requirements must be reviewed at quote stage--contract review. If there are requirements that are seen to be overly onerous, you either have to negotiate them away with the customer or account for them in quoting.

 

[John C. Abnet]

So @mege83 , this raises an interesting point.

The point that I am referring to ( a point of contention and frustration for me and others), is what IS a CSR?

The IATF 16949:2016 standard CLEARLY defines a CSR in section "3.1 Terms and Definitions" as follows...
- Customer-specific requirements (CSR,s)
Interpretations of or supplemental requirements LINKED to a SPECIFIC CLAUSE(s) of this Automotive QMS Standard.

In other words unless there is a customer requirement linked to a clause in the standard, it is NOT a CSR.

e.g.
* For example, GM has a document titled "Customer Specific Requirements". Within that document is an index of each IATF 16949 clause. Those which have additional GM CSR, are stated (linked) within the stated clause. These are clearly GM CSR,s.

* GM has a SEPARATE document titled Packaging Standards and Requirements. By the IATF supplied definition (and implied by GM considering they are NOT in the GM CSR manual?) the GM Packaging Standards and Requirements requirements are NOT CSR but simply "Customer Requirements" which is ALSO defined specifically by IATF section 3.1...to include CSR but also "all requirements specified by the customer (e.g. technical, commercial, product and manufacturing, process-requirements, general terms and conditions, ....."
It seems extremely clear that (unless your packaging requirements are linked to an IATF clause, which I doubt), that the packaging requirement is, by IATF definition, a Customer Requirement but NOT a Customer-Specific Requirement. This would be reason to appeal the nonconformance.


However, to complicate things more, IATF has issued FAQ that address this topic. In FAQ 8, if the customer is "non-IATF or other automotive customer", the IATF renege on the definition they provide in the standard and simply state "...if...customers do NOT clearly link to IATF 16949 clauses in their customer specific requirement, ...a way to identify if CSR exist, is to COMPARE sections of the IATF 16949 standard where the term "if required by customer" ...and verify if ....are related to a requirement in the IATF 16949 standard.

Summary:
By IATF definition, if the packaging requirement is NOT linked to an IATF clause and the customer IS an IATF participating OEM, then the packaging requirement is NOT A CSR and there is no basis (per IATF 16949's own definitions) for the nonconformance and your organization should appeal it.

Hope this helps.

Be well.

 

[Ron Rompen]

Although the wording of the nonconformance may be a LITTLE incorrect (as John pointed out, this is a CR, not a CSR) the fact still remains that there was a failure to comply with the customer requirements which had been plainly stated. Although I would argue whether or not it merits a MAJOR nonconformance, I would agree that it is nonconforming.