API SPEC Q1 Clause 5.6.1.2.C).2) First Article

[Taudi Afiat]

Hi All, Just open discussion here.
Our organization has been recently audited by API for Surveillance. The auditor took a note implementation of clause 5.6.1.2.C).2). In our organization, we implement incoming receiving inspection and review mill cert of raw material from supplier, then we consider that this activity meet requirement clause 5.6.1.2.C).2). we didn't send out test piece to check the chemical and mechanical composition as the supplier is certified API 5CT.
However, the auditor interpreted the clause 5.6.1.2.C).2) that first article shall be performed by sending out test piece to check the chemical and mechanical composition.

How do you think about the clause?
What kind of activity do you think to satisfy this requirement?

 

[prayudha]

Hi All, Just open discussion here.
Our organization has been recently audited by API for Surveillance. The auditor took a note implementation of clause 5.6.1.2.C).2). In our organization, we implement incoming receiving inspection and review mill cert of raw material from supplier, then we consider that this activity meet requirement clause 5.6.1.2.C).2). we didn't send out test piece to check the chemical and mechanical composition as the supplier is certified API 5CT.
However, the auditor interpreted the clause 5.6.1.2.C).2) that first article shall be performed by sending out test piece to check the chemical and mechanical composition.

How do you think about the clause?
What kind of activity do you think to satisfy this requirement?

Dear taudi, is this case become nonconformance from auditor?

because the explanation from clause 5.6.1.2.C).2) refer to term and definition 3.1.11 first article (representative sample of a product, component, or output from a process used to verify that prescribed activities have satisfied the requirements as specified by the organization).

 

[Taudi Afiat]

Dear Prayudha,

Yes, it is raised as finding.

 

[Thee Bouyyy]

Yes, I agreed with the auditor findings and interpretation of 5.6.1.2 C) 2.

First article definition itself in API Q1 Standard (3.1.11) says that, "Representative sample of product, component or output from a process used to verify that prescribed activities have satisfied the requirements as specified by the organization."

So, you have to send test piece to check chemical and mechanical composition.

Now, As you said that you implemented incoming receiving inspection and review mill cert of raw material from supplier. I just wanted to know that are you manufacturer or supplier or what?

 

[Taudi Afiat]

Thanks for your Explanation

We buy raw material to manufacture oilfield equipment

 

[lanley liao]

I agree with Prayudha and Thee. but We think that the words of Taudi were also right. The key point of this question is that the item 1),2) and 3) in API Q1 5.6.1.2 C) were optional. At first, you should check the Procurement Control Procedure to how to address it. The evidence implemented should conform with requirements specified, if no, you should modify your corresponding document; if yes, you should show your evidence with the API reviewing committee for appealing this NC. Sometimes, we also can verify that the raw material meets the requirements specified by the customer through the MTR and incoming receiving inspection results of raw materials. The last evidence was depended on the company itself.

 

[Taudi Afiat]

Thanks Lanley

Since supplier has been certified by API 5CT and audited by API. We previously considered that we didn't need to send test piece to check chemical and mechanical composition. So, we verified raw material through MTR.

 

[Thee Bouyyy]

So, we verified raw material through MTR.

What you are saying here, is documented anywhere in your QMS that raw material verification control through reviewing MTR.

 

[Taudi Afiat]

yes, it is documented in our QMS

 

[Thee Bouyyy]

OK great, as @lanley liao said in this thread, you can twist this nonconformance and appeal it for this NC with your supporting evidence. It's time to convince the reviewer.