API Spec Q1 9th Edition - 12 month Internal Audit Schedule Audit Nonconformance

#1
Hello all!
I have recently participated in my re-certification audit for API Q1 9th edition. The following was first deemed an Observation then later upgraded to a minor NC. The finding is listed below. Keep in mind that we have identified 22 separate processes that need to be audited annually. The corporate training process was audited but in a 15-month time frame instead of a 12-month time frame(i.e Jan-17 initial audit, Apr-18 next audit). I feel I should challenge this but don't really have much to stand on considering we did not meet the standard verbatim. The problem that I am having is that this allows for no changes in frequency or flexibility of the audit schedule in my case to move audits around based on need or other. I realize that if you read the standard it clearly outlines the requirements but this allows no flexibility in the schedule especially when your organization has identified and has this amount of processes to be audited. Can anyone help on how I should answer this finding?

Requirement - MS StandardAPI Spec Q1 9th Ed

Clause 6.2.2.1 (Identify Criteria, Scope, Etc.)

DescriptionThe organization shall identify the audit criteria, scope, frequency, and methods to ensure that all processes of the quality management system claiming conformity to the requirements of this specification are audited at least every 12 months.

Objective Evidence: All areas were audited within the 12-month timeframe with the exception of Corporate Training that was performed at a 15-month interval. The facility needs to ensure that all audit areas be held to the 12-month requirement.

Nonconformance/Concern DescriptionOne area of the QMS was outside of the 12-month requirement for the performance of internal audits.
 
Elsmar Forum Sponsor

Sidney Vianna

Post Responsibly
Staff member
Admin
#2
The problem that I am having is that this allows for no changes in frequency or flexibility of the audit schedule in my case to move audits around based on need or other. I realize that if you read the standard it clearly outlines the requirements but this allows no flexibility in the schedule especially when your organization has identified and has this amount of processes to be audited. Can anyone help on how I should answer this finding?
Not sure if I am following your logic here. The API Q1 Spec calls for a MAXIMUM interval of 12 months. If you deem (and you probably should) that some critical and/or low performing processes should be audited at higher frequency, the standard does not prohibit that.
 

Eredhel

Quality Manager
#3
Are you asking if you can go longer? The language is pretty clear, "...ensure that all processes of the quality management system claiming conformity to the requirements of this specification are audited at least every 12 months." I may be misunderstanding what you're asking.
 

jmech

Trusted Information Resource
#4
API does not allow for an increase to the 12 month interval.

API has issued an interpretation that performing the audit the same month every year meets the 12 month requirement (for example, you can do March 11 one year and March 18 the next year), so it is not a precise 365 day requirement. However, some auditors are not aware of this interpretation and will still issue findings if you exceed 365 days, but you should win on appeal if you do it the same month as the previous year. You can find the interpretations at: http://mycommittees.api.org/standards/techinterp/mspecs/Shared Documents/Q1.pdf

API will require you to respond with a full root cause (Why did you think a 15 month interval was acceptable when the standard states 12 month maximum?), correction (audit immediately if it has been more than 12 months since any process was audited and/or change the audit schedule if any scheduled audits exceed the 12 month requirement), and corrective action (update your procedure to clarify the 12 month requirement; train the person responsible for scheduling audits on the 12 month requirement; provide additional audit resources if required).
 
#5
Thank you all for the answers. I guess my biggest issue that I am having is adjusting to the new requirement in API Q1 as ISO states annually (calendar year my take on it). So this requirement has caught me a little off guard as I am fairly new to the API specification.
 

Eredhel

Quality Manager
#6
No doubt. ISO and AS will tell us to do something at planned intervals where API will say do it in this time frame and have more documented procedures. Fun stuff!
 
Last edited:

Eredhel

Quality Manager
#7
Thank you all for the answers. I guess my biggest issue that I am having is adjusting to the new requirement in API Q1 as ISO states annually (calendar year my take on it). So this requirement has caught me a little off guard as I am fairly new to the API specification.
Btw what part of ISO do you mean on "annually", are you talking about ISO 9001?
 
Thread starter Similar threads Forum Replies Date
C Validation of process for production and servicing 5.7.1.5 API Spec Q1, 9th Edition Oil and Gas Industry Standards and Regulations 9
SANTHSH API spec Q1 9th edition - Castings & Forgings Oil and Gas Industry Standards and Regulations 4
N API spec Q1 9th edition Oil and Gas Industry Standards and Regulations 2
M API Spec. Q1, 8th Ed. Section 7.5.2 vs. Q1, 9th Ed. Section 5.7.1.5 ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 0
N Audit non-compliance - API Spec Q1 9th Ed 5.6.1.2 b Oil and Gas Industry Standards and Regulations 25
A API Spec Q1 9th Edition # Re-audit - Disputing with API AARs Oil and Gas Industry Standards and Regulations 1
F API Spec Q1 9th Edition Surveillance Audit - Questions about internal audits. Oil and Gas Industry Standards and Regulations 22
J API Spec 6D 25th edition release date? Oil and Gas Industry Standards and Regulations 2
T API SPEC Q1 Clause 5.6.1.2.C).2) First Article Oil and Gas Industry Standards and Regulations 16
lanley liao How to understand correctly the section of 5.11 MOC in API Spec Q1? Oil and Gas Industry Standards and Regulations 3
U API Spec Q1 - 5.6.1.2 C (3) - Design software Oil and Gas Industry Standards and Regulations 3
lanley liao How to correctly understand the bullet list d) of 6.3 Analysis of Data for API Spec Q1 Oil and Gas Industry Standards and Regulations 7
A API Spec Q1 Purchasing Process - Supplier Reevaluation based on Supplier Risks 5.6.1.4 Oil and Gas Industry Standards and Regulations 17
lanley liao The validity of API Spec Q1 certificate Oil and Gas Industry Standards and Regulations 2
A Design and development procedure for API Spec Q2 Oil and Gas Industry Standards and Regulations 6
SANTHSH API Spec.Q1 Standards Version in Purchasing Information Oil and Gas Industry Standards and Regulations 1
SANTHSH API Spec. Q1 clause 5.6.1.2 On site evaluation Oil and Gas Industry Standards and Regulations 10
lanley liao How to understand the term 3.1.21 'Servicing' and the clause 5.7.1.2 'Servicing' of API Spec Q1? Oil and Gas Industry Standards and Regulations 19
A Does anyone have a checklist of API Spec 650 13th Edition? Oil and Gas Industry Standards and Regulations 0
R Process control documents - Context of API Spec Q1, Clause 5.7.1.3 Other ISO and International Standards and European Regulations 0
S Internal Auditing for API Spec Q1 - auditor qualification requirements Oil and Gas Industry Standards and Regulations 6
S API Spec Q1 - How to define Management Representative competency for QMS Oil and Gas Industry Standards and Regulations 12
R Interesting Discussion API Spec Q1 Addendum 2 Oil and Gas Industry Standards and Regulations 0
F API Spec Q1 Scope - Limiting the scope of certification Oil and Gas Industry Standards and Regulations 3
Moumen H API Spec Q2 Design and Development Requirements for Service Providers Oil and Gas Industry Standards and Regulations 11
A Integrating API Spec Q1 with ISO 9001:2015 Oil and Gas Industry Standards and Regulations 18
S API SPEC 7-1, 7-2 and 5 CT implementation Oil and Gas Industry Standards and Regulations 3
H API Spec Q1 7.5.2 & 7.5.2.1 - Audit Nonconformance Help Oil and Gas Industry Standards and Regulations 15
S Sample Quality Manual which complies with API Spec Q1 Ninth Edition Oil and Gas Industry Standards and Regulations 17
P New to API Spec 7-1 (Rotary Drill Stem Elements) Oil and Gas Industry Standards and Regulations 6
C TS 29001/API spec Q1- help needed Oil and Gas Industry Standards and Regulations 1
H API (American Petroleum Institute) Spec Q1 Manual - Looking for samples Oil and Gas Industry Standards and Regulations 4
Q API (American Petrolium Institute) Spec 6D - Specification for pipeline valves Oil and Gas Industry Standards and Regulations 2
D How to testing of Pressure relief valve as per API 6D ? Oil and Gas Industry Standards and Regulations 1
P API Q1 - Monogram Product & API 4F - Proof Load Test Oil and Gas Industry Standards and Regulations 3
L API Q1 Application Oil and Gas Industry Standards and Regulations 2
U Need Help With API Q2 Quality Manual Oil and Gas Industry Standards and Regulations 8
lanley liao Confusion between national standard and API related standard. Oil and Gas Industry Standards and Regulations 8
Thee Bouyyy API Q1 9th edition 5.4.3 c) and 5.4.3 d) Oil and Gas Industry Standards and Regulations 10
T Non API products need to comply to API Q1? Oil and Gas Industry Standards and Regulations 3
C API Q1 internal audit report Internal Auditing 3
lanley liao How to understand and master the requirements of each section in API monogram product. Oil and Gas Industry Standards and Regulations 5
Thee Bouyyy Internal NCR - API Q1 5.4.2b - API 16C Clause 4.1.3 Internal Auditing 9
N NC on API Q2 Oil and Gas Industry Standards and Regulations 4
A API Monogram audit review process Oil and Gas Industry Standards and Regulations 5
lanley liao Are there guidelines for application of all API monogrammal product? Oil and Gas Industry Standards and Regulations 2
U API License Agreements Oil and Gas Industry Standards and Regulations 2
R American Petroleum Institute - Becoming an API Auditor Professional Certifications and Degrees 3
B Is there an estimated date of release of API Q1 10th edition? Oil and Gas Industry Standards and Regulations 17
lanley liao How to keep the manufacturing capability under the API monogram Oil and Gas Industry Standards and Regulations 6

Similar threads

Top Bottom