AS9100 Rev D Clause 10.2 - Is Cause always required?

howste

Thaumaturge
Super Moderator
#1
The new wording in AS9100 Rev D clause 10.2.1.b.2 states:
When a nonconformity occurs, including any arising from complaints, the organization shall... b. evaluate the need for action to eliminate the cause(s) of the nonconformity, in order that it does not recur or occur elsewhere, by... 2. determining the causes of the nonconformity...
We have a customer representative that is of the opinion that with this AS9100 Rev D requirement we are required to determine causes for EVERY nonconformity we encounter, no matter how insignificant.

AS9100 Rev C has some "weasel words" that allow us to decide when we will determine causes. Realistically I don't believe that any organization has the resources to determine causes for every nonconformity. With this customer representative's interpretation, if we have a slight scratch in paint requiring touch-up we would have to determine the cause. If we have a 5 cent washer that is bent we would have to determine the cause.

I don't believe that the intent of the requirement was supposed to change with the new standard, or someone would have highlighted this as a significant change in the standard. Is anyone aware of any sanctioned interpretations about this requirement? Since this text is in ISO 9001, anything from TC 176, IAQG, AAQG, etc. would be acceptable to show as evidence one way or the other. Any ideas?
 
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Marc

Hunkered Down for the Duration
Staff member
Admin
#3
Re: AS9100 Rev D Clause 10.2 - Is Cause always required to be determined?

First off, what AS9100 Rev C "weasel words" allowed a company to decide when they will determine causes?
... We have a customer representative that is of the opinion that with this AS9100 Rev D requirement we are required to determine causes for EVERY nonconformity we encounter, no matter how insignificant.

AS9100 Rev C has some "weasel words" that allow us to decide when we will determine causes. ...
I have seen this for years in various industries. It comes down to what you define as a nonconformance and has been discussed here in other threads here over the years. The main issue is what are in-process "nonconformances" (i.e.: what is and isn't in your company). This also is part of when you have a nonconformance, as defined in your company, is a full corrective action required.
... Realistically I don't believe that any organization has the resources to determine causes for every nonconformity. ...
This is the reality if you use a broad definition of what a nonconformance is in your processes and final product.

I can't speak to AS9100 requirements interpretations, but I have seen it in automotive many times. One of the rationalizations is for one off things like a scratch, it's not a nonconformance. However recurrence pushes the issue to require a corrective action. In addition, internal process nonconformances tend to not be a customer concern (or any of their business to begin with) when they do not escape.
 

howste

Thaumaturge
Super Moderator
#4
Re: AS9100 Rev D Clause 10.2 - Is Cause always required to be determined?

First off, what AS9100 Rev C "weasel words" allowed a company to decide when they will determine causes?
AS9100 Rev C clause 8.5.2 said:
A documented procedure shall be established to define requirements for... b) determining the causes of nonconformities...
This says I can define in my procedure the requirements I choose to implement about when and how to determine causes.
 

Marc

Hunkered Down for the Duration
Staff member
Admin
#5
Re: AS9100 Rev D Clause 10.2 - Is Cause always required to be determined?

I don't have Rev D so I have no means to compare, but was AS9100 Rev C clause 8.5.2 b) eliminated in Rev D? Or was it reworded?

I will say, if it is a customer complaint that is driving this, as you well know there is an escape that has to be closed the cause of which would have to be determined. An external escape is the worst of the worst.

It's been quite a few years since I worked in aerospace, which has always been tougher than automotive, but one bad piece out of a lot of 10,000 and it could cause rejection of the entire lot of 10,000 and would require a corrective action. I say "could" because there were many times alternatives were often agreed to. None the less it was always expensive, such as 100% sort at the supplier's expense. I have even seen a customer require a 3rd party to do the sort and to do it at a 3rd party location when a defective showed up in assembly. I remember it well as I supervised the sort. I forget how many parts, but it was several thousand somewhat large parts (assemblies, actually). The sort came up with zero defectives. Needless to say an external escape can be seriously expensive in some industries.

****************
Like I say - Over the years I've seen some pretty stupid stuff. Let's say you have an anodized part and it is dropped and dented or scratched at a station. Is that "nonconforming product" which needs a corrective action?

I always went to the numbers. If dropping parts at a station was frequent, scrap or rework numbers would rise or be high to begin with which would drive a corrective action. But if it was infrequent to rare, and as such cost was negligible, it may be something to improve but the priority would be low.

You probably just have an anal customer representative. I remember doing some work for a company which had a real anal customer supplier QA guy. The customer rejected a lot of parts (lot as in a shipment) , so it was on the dashboard. After it was determined that their receiving people had not used the correct print to check the part, the guy wouldn't take it off the dashboard until he made a 2 day visit to "review practices and processes" at the company I was helping. This was in automotive and was the type of cr*p which made me hate automotive QA.

The best thing I can say at this point is it will force you to take a good look at your procedure.

BTW - I apologise for the "war stories" I tend to tell... I'm getting old.
 

Marc

Hunkered Down for the Duration
Staff member
Admin
#6
Looking back over this, I see this difference between:

AS9100 Rev C clause 8.5.2 b)
A documented procedure shall be established to define requirements for... b) determining the causes of nonconformities...
and

AS9100 Rev D clause 10.2.1.b.2
When a nonconformity occurs, including any arising from complaints, the organization shall... b. evaluate the need for action to eliminate the cause(s) of the nonconformity, in order that it does not recur or occur elsewhere, by... 2. determining the causes of the nonconformity...
which I tried to express in Post 3 above.

When I look at it, they added some words, but then again the content of AS9100 Rev D clause 10.2.1.b.2 is pretty standard in a nonconformance system, isn't it?
 

howste

Thaumaturge
Super Moderator
#7
When I look at it, they added some words, but then again the content of AS9100 Rev D clause 10.2.1.b.2 is pretty standard in a nonconformance system, isn't it?
Yes, cause determination is standard when we decide corrective action is needed. Don't get me wrong - cause analysis and determination are key in the corrective action process, and I know that many companies don't do it well. I don't want to end up with the tail wagging the dog though.

By the way the "customer's representative" in this case is DCMA. We have an onsite team of DCMA representatives and the lead representative is the one pushing this issue.

I would contact the IAQG document representative via OASIS feedback loop and ask for a clarification.

I don't remember seeing anything which could be used as jurisprudence over this issue.
Thanks. I've submitted a ticket to the document representative requesting an interpretation/clarification for this issue.
 

Eredhel

Quality Manager
#8
"a. react to the nonconformity and, as applicable:"

I would lean on "as applicable" not being a "- 'shall' indicates a requirement" statement. Doesn't the organization define what is "applicable"?
 

howste

Thaumaturge
Super Moderator
#9
"a. react to the nonconformity and, as applicable:"

I would lean on "as applicable" not being a "- 'shall' indicates a requirement" statement. Doesn't the organization define what is "applicable"?
I would love to use the "as applicable" text in a, but I don't believe it carries over to b. I believe it only applies to items 1 and 2 below a.
...the organization shall:

a. react to the nonconformity and, as applicable:
1. take action to control and correct it;
2. deal with the consequences;

b. evaluate the need for action to eliminate the cause(s) of the nonconformity, in order that it does not recur or occur elsewhere, by:
1. reviewing and analyzing the nonconformity;
2. determining the causes of the nonconformity, including, as applicable, those related to human factors;
3. determining if similar nonconformities exist, or could potentially occur;
 

Eredhel

Quality Manager
#10
Gotcha, that's probably true. I'll be curious to hear what you get back from your ticket. I feel like section b. is not so cut and dry as they're trying to make it but that conversation can be a lot different with an auditor than a customer.
 
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