AS9100 7.5.1.5 Control of Service Operations

[Eloy Gomez]

We take exclusion to:
7.5.1.5 Control of Service Operations: Xcompany does not offer or provide any servicing activities that require installation, maintenance and/or repair of the products processed.

Our surveillance auditor said that we should reconsider the total exclusion of 7.5.1.5 due to a & b.[FONT=Arial,BoldItalic][FONT=Arial,BoldItalic]
a) a method of collecting and analyzing in-service data, &
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b) actions to be taken where problems are identified after delivery, including investigation, reporting activities, and actions on service information consistent with contractual and/or regulatory requirements,

He says that a) & b) are post service activities and these include warranty. Could someone clarify this requirement?​

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[Big Jim]

The first thing to be aware of is that this is an item that might not need to be excluded. If the following is incorrect, I would like to understand why.

At the beginning of 7.5.1.5 we read:

"Where servicing is a specified requirement".

From the TC176 Guidance on 1.2, example 5, we read:

Example 5 – Traceability

Situation:
AKP Corp. is a company that manufactures electric motors for sale by licensed distributors. Traceability of the component parts of the product is not an internal or external requirement of this company. The organization has excluded the traceability requirement of sub-clause 7.5.3 Identification and traceability from its QMS, while claiming conformity to ISO 9001:2008.

Issue(s):
Can AKP Corp. exclude the traceability requirement of sub-clause 7.5.3 Identification and traceability from its QMS and claim conformity to ISO 9001:2008?

Analysis and conclusion:
The organization’s decision to exclude the requirements for traceability is justified. However this exclusion is not necessary, since ISO 9001:2008 only requires traceability when it “is a requirement”.

Now I realize that we are dealing with AS9100, not ISO 9001. If there is something about AS9100 that would keep this from applying, I would like to know about it. The wording of 1.2 is identical between the two standards.