Annual PPAP Re-Validation Requirements? CP/PF/FMEA? Everything?

C

Chemlab

#1
Have a question regarding the requirements of annual validation PPAPs. From what I can tell from the PPAP manual, unless the customer requires otherwise, it appears that all that is needed for submission is a dimensional layout on characteristics not addressed by the control plan and a level 4 warrant. I have a customer that only requires the layout and PSW for re-certification, but also state all 19 elements on pg. 16 must be available within 48 hrs upon request. I have another customer that does not use the AIAG PSW. On this warrant, it states this PPAP is only good for 1 year. Additionally, our auditor, unless I misunderstood, said that level 3 PPAP documentation must be completed annually regardless if the customer asks for it or not. It is clear that the dimensional layout is required, not a problem with the CP/PF/FMEA since they are already there, but it seems to suggest that capability studies for that PPAP run need to performed again just as if it were an initial submission. This is despite the fact that designated characteristics are monitored on-going anyway. That also seems to mean that I would have to repeat all the gage r&r studies annually. While perhaps a good practice, I can't find direct verbage saying, "...shall perform R&Rs annually". Also, my requirements for physical testing often include expensive tests we only submit and perform at PPAP. Lately, we have been getting the customer to agree that these tests are only a 1 time deal. Otherwise, it appears that I must complete this testing annually and have it on file regardless if they want it or not. At any rate, since it is unclear, to be safe I've been putting together a new level 3 PPAP for annual recertification just as if it were the initial submission. Even though its more work, if its required by QS-9000, its required. So be it. It just seems that instead of focusing on improving the process, I spend all of my time re-PPAPing part number after part number. My question is: Is there verbage anywhere that directly/indirectly implies that level 3 documentation must be generated (doing all the initial submission work over again except for CP/PF/FMEA) and kept on file annually?

Thanks,
Chemlab
 
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D.Scott

#2
To my knowledge, there is nothing in QS-9000 to require you to do annual PPAP submissions. The PPAP 3rd edition shows the situations where the customer must be notified (1.3.1) but the customer has the option of requiring a PPAP (in most cases for us they don't need one). 1.3.2 shows when submissions are neded but there is no requirement for annual submissions. It is however where most auditors will refer you for review and update of the PPAP data. The requirement is "review and update AS NECESSARY all applicable items .. to reflect the process, regardless of whether the customer requests a formal submission." This is normally intrepeted as maintaining the PPAP to include updates due to C/As and other items but it certainly could be taken as "you need to review it to see if it has changed". In any case there is no requirement of doing this annually.

The level 3 distinction is strange to me. There is nothing that would make a level 3 any different than any other level. The difference is in what is sent to the customer, not in the PPAP requirements. All PPAP documentation, regardless of the level, must be on file with the supplier and available to the customer.

Layouts is another thing. Each company has their own requirements - Chrysler requires annual layouts on everything - Ford on characteristics not measured on an on-going basis, and GM waives them unless specified. Check with your customer.

Bottom line is not the auditor, but the customer. Even if it is a direct requirement of QS, the customer can waive it. Customer requirements always take precedence. I certainly wouldn't do any costly testing unless your customer required it.

We have had to send re-submissions on PPAPs in the past for various reasons but I can't remember any where the customer has required the full package.

I am certainly no expert and this is obviously just my opinion but I will be very surprised if it is wrong.

Dave
 
A

Al Dyer

#3
I would also be surprised if you were wrong Dave.

This sounds like an overzealous auditor or a misunderstanding. I have never heard of an annual completion of PPA, that would kill businesses!

Might be time to call the registrar and "discuss" the situation and ask for a specific statement that backs up the auditor. I'm sure there is not one in QS9000.
 
C

Chemlab

#4
Annual Re-validation

Thanks for the replies.

Anytime there is a drawing change, level 3 documentation must be reproduced even if the customer doesn't require it? The question is "reproduced" or "on file based on old PPAP submissions". Does the previous PPAP submissions (ex: initial submission) on file, even if it is 5 yrs old, satisfy the requirements not covered by the change? For example: If we just change an ink-jet ID and I PPAP just that change, do I have to re-do capability studies not at all related to the change or are they already "on file" based on a 5 yr old initial submission? I guess the confusion is the fact that the auditor seemed to suggest that all 19 items are only valid for one year. Even though I have level 3 documentation on file, after one year, the auditor said all items including capability studies, gage R&Rs, physical testing had to be current within a year.

If I understand you correctly, once I submit the initial full level 3 PPAP, I only have to document the changes and add this "amended" documentation to my original PPAP file. So, if I submit a level 4 for a minor change and the customer comes back and asks for, say a physical tests unaffected by the change, I just pull out this data from a 5 yr old (>1 yr) old PPAP book and send it to them? If I had a customer that for some reason demanded a level 3 PPAP submission for a change that only affected an ink-jet ID, could I pull out the old capability studies or physical test results (which would be unrelated to the change) from an old PPAP (>1 yr old) and stick it in the new submission and call it done? Then, simply comply with layouts per the customer requirements?

Thanks again.
Chemlab
 

Howard Atkins

Forum Administrator
Staff member
Admin
#5
I have known customers asking for a new PPAP for a number of reasons,
One multinational based in Europe was very suprised that the US branch requested Annual PPAP and said this was not policy or needed.
Another Multinational asked for a new PPAP for a product that was approved by a full PPAP in 1996 as the stated that in 1996 they did not read them.
Another case when a part was transfered from one company to another a PPAP was requested.
Annual PPAP's are not mandatory and I agree this is an auditor that "for a change" does not understand the standard.
 
A

A. Stuart Dyer

#6
The only requirement on this topic is Chrysler, that requires an annual layout. Other than that it is all mail, email, or fax. What is required is that the most current documentation (PPAP/APQP) be on file for customer review.
 
C

Chemlab

#7
Annual Re-validation

Thanks for everyone's help.

I went to work for a company that insisted that every drawing change, which resulted in the need for PPAP, was only a matter of whether the information was retained or submitted for all items on page 16. So regardless, if it applied or not to the change, it was interrupted to mean that a level 3 PPAP was re-completed as if it were the initial submission. New capability studies, R&Rs, etc. even if it did not apply. If, as a customer, I asked for a level 4 PSW and a layout on the 1 dimension that changed, the company's position was that the supplier had to complete all the items on pg. 16 anyway and "Retain" the new information, so it was insisted that I require them to submit a level 3 PPAP since 'they had to do the work anyway'. Not only was this crazy to me, but obviously the suppliers complained. However, despite protesting that this made me look stupid as the SQA, I could not find direct verbage in AIAG to dispute this position, even though I know this is not the common industry practice. The standard seems to suggest when a PPAP is necessary, then pg 16 says to "Retain" or "Submit" with a PPAP.
I know it says that the supplier is responsible to update the PPAP documentation as necessary, but perhaps it should more directly address "amendments" to the initial submission.

So not happy with the position I was asked to argue with suppliers, I confronted our auditor. Perhaps I didn't explain well, but he told us that it was OK not to re-complete items on pg 16 that were not affected by a simple drawing change, AS LONG as it was within a year of the lastest level 3 PPAP. Ok at least I was getting somewhere. Now at least a full level 3 PPAP, regardless of submission level requested by the customer, was only necessary if the last one was less than a year old. However, when pressed on this issue, I got the feeling he didn't really know and was dancing.

I moved on to another company and participated in the QS audit with the QA Manager. The QA manager seemed to take the former position. I maintained we were doing too much work unnecessarily after posting on this site. I asked this auditor. His view was simple and what I wanted to hear. "Retained?" -- that was completed on the initial submission, so it is RETAINED just not repeated. The level 4 PSW is just an amendment to the initial submission. And... per the standard, depending on the customer, the only annual requirements is a dimensional layout.

However, I do have a customer that sends a PPAP requirement sheet to its suppliers that states at the bottom that PPAPs are only valid for one year. While this may be a customer requirement in which I have to comply, I believe there are many out there that misunderstand and make ignorant policy as discribed above. I have talked to many suppliers and customers which subscribe to one of the positions above. I told many suppliers they were due for annual re-validation, so go ahead and send me a fresh level 3. No dispute what-so-ever. Either they were good suppliers that did whatever the customer asked, or they were just as stupid as I was.

Chemlab
 
D

dianeoliver

#8
What about FMVSS 302 and FMVSS 305 requirements?

Also looking for clarification of accredited lab... for glass suppliers OEM usually accept THEIR internal lab but the TS says ACCREDIATED.
I've also heard if their internal lab scope covers it and they are TS certified it's okay - but if sent to an external lab, THAT EXTERNAL lab must be accrediated. CAN someone please clarify. ?
 
L

lk2012

#9
hi,
the lab has to be covered whichever way you look at it. Either it's on-site and that would then be covered by the site TS certificate, or it's external and then it's your responsibility to make sure you're using certified labs and following your supplier management process.
hope this helps
Lil
 
D

dianeoliver

#10
Thanks so much for your reply.
That is how I always viewed it, but some auditors are telling me that internal lab certs for component PPAPs, such as glass suppliers, etc. that are a safety items must be tested by accrediated lab.... , and I keep arguing that the OEMs usually accept these internal labs (as they are the experts) but I feel like I'm spinning my wheels. I can't seem to win this argument and keep getting non conformance issued?
 
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