AS9100 Rev D Clause 10.2 - Is Cause always required?

howste

Thaumaturge
Trusted Information Resource
Good news. I had some dialog through OASIS with Buddy Cressionnie, the Americas IAQG 9100 Leader. The end result is he said to determine if action is necessary first, then "...if action is not necessary then there is no need for either cause analysis nor corrective action." :agree1:

He also mentioned that they will publish this clarification on the IAQG website after the meeting this month.
 

dsanabria

Quite Involved in Discussions
Had many spirited conversation over the same 10.2 requirements.

Thanks for persisting on getting a clarification.

Looking forward for the official release of the interpretation.
 

howste

Thaumaturge
Trusted Information Resource
This morning the IAQG published the first AS9100D clarifications on their website. The issue above is one of 53 clarifications published in the document. I haven't read them all, but here's the breakdown of clarifications per clause:

Clause 4 - 5 clarifications
Clause 5 - 2
Clause 6 - 1
Clause 7 - 3
Clause 8 - 34
Clause 9 - 5
Clause 10 - 3

It's found on the IAQG deployment support materials page. (broken link removed).
 

Big Jim

Admin
Thank you very much for posting this. There is a lot of common sense in the approach to the clarifications. There are a few that will probably trigger some interesting conversations though.

Since I'm sitting in an airport waiting to start my trip home for the weekend, I did a quick read.

There is one big error though and should be addressed. When answering a question about would it be OK for a quality assurance manager to audit quality assurance question I found the following:

"It also states that auditors shall not audit their own work to ensure an
independent set of eyes are being used to conduct the audit."

My copies of both ISO 9001:2015 and AS9100D do not include "auditors shall not audit their own work" as the prior versions did.

That puts the entire response in question.
 

dsanabria

Quite Involved in Discussions
Thank you very much for posting this. There is a lot of common sense in the approach to the clarifications. There are a few that will probably trigger some interesting conversations though.

Since I'm sitting in an airport waiting to start my trip home for the weekend, I did a quick read.

There is one big error though and should be addressed. When answering a question about would it be OK for a quality assurance manager to audit quality assurance question I found the following:

"It also states that auditors shall not audit their own work to ensure an
independent set of eyes are being used to conduct the audit."

My copies of both ISO 9001:2015 and AS9100D do not include "auditors shall not audit their own work" as the prior versions did.

That puts the entire response in question.

Totally agree..

Why was that response allow to be published.

Makes you wonder if any one reviews the answer that they put out.


It looks like the IAQG is contradicting the standard...
 

Sidney Vianna

Post Responsibly
Leader
Admin
It looks like the IAQG is contradicting the standard...
How so?

There is a process in place for the review of such clarifications, so this is not the work of a single individual.

We have to remember the context of AS9100. One of the major stakeholders in the process are Regulatory Bodies such as the FAA and EASA, and the people there tend to be old fashioned traditional when it comes to quality. If we had an interpretation that would be deemed too lenient, such agencies might question (as they do from time to time) the value of 9100 and the ICOP process.

If we remember the normative definition of the term audit, it has to be an independent assessment. So, I don't see how the clarification contravenes the intent of AS9100. I think it is critical to always remember the context.
 

Big Jim

Admin
How so?

There is a process in place for the review of such clarifications, so this is not the work of a single individual.

We have to remember the context of AS9100. One of the major stakeholders in the process are Regulatory Bodies such as the FAA and EASA, and the people there tend to be old fashioned traditional when it comes to quality. If we had an interpretation that would be deemed too lenient, such agencies might question (as they do from time to time) the value of 9100 and the ICOP process.

If we remember the normative definition of the term audit, it has to be an independent assessment. So, I don't see how the clarification contravenes the intent of AS9100. I think it is critical to always remember the context.

I understand what you are saying Sydney, but they misquoted the standard and that is not defendable. It is inexcusable. If they feel they need to emphasize the need to be impartial and objective then they should do so without misquoting the standard and adding something in that isn't there.

If they wanted to put back in that auditors cannot audit their own work they had that opportunity before it was released just as they added back about the management representative.

This portion of the advisory is a clinker.
 

dsanabria

Quite Involved in Discussions
How so?

There is a process in place for the review of such clarifications, so this is not the work of a single individual.

We have to remember the context of AS9100. One of the major stakeholders in the process are Regulatory Bodies such as the FAA and EASA, and the people there tend to be old fashioned traditional when it comes to quality. If we had an interpretation that would be deemed too lenient, such agencies might question (as they do from time to time) the value of 9100 and the ICOP process.

If we remember the normative definition of the term audit, it has to be an independent assessment. So, I don't see how the clarification contravenes the intent of AS9100. I think it is critical to always remember the context.

AS9100D States - and I quote
9.2 Internal Audit

9.2.1 The organization shall conduct internal audits at planned intervals to provide information on whether the quality management system;

a. conforms to:

1. the organization’s own requirements for its quality management system;

NOTE: The organization’s own requirements should include customer and applicable statutory and regulatory quality management system requirements.

2. the requirements of this International Standard;

b. is effectively implemented and maintained.

NOTE: When conducting internal audits, performance indicators can be evaluated to determine whether the quality management system is effectively implemented and maintained.


From the IAQG website: IAQG 9100 :2016 Clarifications

9.2.2c Does the IAQG 9100 standard allow the Quality Assurance manager be the lead auditor in an Internal Audit and audit QA specific questions?

No. The requirement in IAQG 9100 is "select auditors and conduct audits to ensure objectivity and the impartiality of the audit process." This ISO 9001 text is in place to ensure an effective internal audit by having an objective and impartial auditor. It also states that auditors shall not audit their own work to ensure an independent set of eyes are being used to conduct the audit.


Where is this requirement in the ISO or AS Standard?

The IAQG is quoting the previous standard and that is misleading the audience that is not aware of the requirement.
 
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