AS9100D - 8.3 is in scope for Contract Manufacturer's

[rmuncer]

Hi All, We are currently going through an audit with PJR for AS9100. We are a contract manufacturer (Make to print). Our customers provide tooling dollars, and some require asset tags on the tools (Progressive Dies). Our audit team is saying that since the tooling is customer owned, they are considered a deliverable and as such, section 8.3 is in scope for our QMS. This seems to be coming from a new sanctioned interpretation. Is anyone else experiencing this? Is this a valid finding?

 

[Randy]

At what point are you considered to be designing anything?

 

[rmuncer]

When we design the tooling. Since the customer is providing tooling dollars through a Non-Recurring Engineering Fee. It has been a standard practice to charge the customer for tooling when beginning a new program to manufacture a customer designed part. According to the interpretation, since it is a billable item, it is a deliverable. Thus 8.3 is invoked. See page 2, second from the bottom. I can't post the link, but if you search for IAQG clarifications for AS9100D, the document will be near the top.

 

[Sidney Vianna]

Is this a valid finding?

Tooling is a “non deliverable” product, even if it is customer property. So, in principle, 8.3 would not apply since it is meant specifically for the product. Also, you did not mention what type of audit is this. A stage 1, 2 or a surveillance audit. At best this should have been discussed at a stage 1 audit, but at those events, no nonconformity would be issued. If you are dealing with an auditor, escalate the discussion to a PJR manager. Or, engage with the AS9100 sector document representative via OASIS.

In my experience, tooling design was not required to be covered under 8.3.

Thinking about it, it could also be the case of an automotive auditor getting the wires crossed; in automotive, the IATF mandates that the registrant includes PROCESS DESIGN as part of the QMS scope.

 

[Randy]

In my experience, tooling design was not required to be covered under 8.3.

Not seen it either. So that's probably 45-50+ years combined experience, but what would we know?

The only thing I can think of is if the OP's own internal documentation states they will do it, or if (big if), the customer actually specifies it. If either occurs, all bets are off.

 

[rmuncer]

Thanks. For clarification, the audit is a scope extension from ISO 9001:2015 up to AS9100 with Design as Not Applicable. We have a robust process for Planning of Production activities which has covered us for 8.1. We have an Engineering department that creates the processes and any tooling or fixturing designs necessary. This is for a stamping operation.

 

[ChrisM]

Our audit team is saying that since the tooling is customer owned, they are considered a deliverable and as such, section 8.3 is in scope for our QMS.

Which audit team - financial, legal, quality or other?
Years of experience have taught me to be ultra-cautious when tooling is involved - not just questions over its ownership and acceptance for use, but what happens when it wears, who is responsible for maintenance, refurbishment etc etc? How should it be stored and checked when in storage (and a whole lot more)

 

[Randy]

Thanks. For clarification, the audit is a scope extension from ISO 9001:2015 up to AS9100 with Design as Not Applicable.

I'm only guessing here, but reductions in duration can be justified when clauses (requirements/shall's) aren't applicable (excluded), and there is always a possibility of increasing audit duration (ergo revenue) by keeping 8.3 in scope.

Just saying, no proof mind you.

 

[Golfman25]

Tooling is a “non deliverable” product, even if it is customer property. So, in principle, 8.3 would not apply since it is meant specifically for the product. Also, you did not mention what type of audit is this. A stage 1, 2 or a surveillance audit. At best this should have been discussed at a stage 1 audit, but at those events, no nonconformity would be issued. If you are dealing with an auditor, escalate the discussion to a PJR manager. Or, engage with the AS9100 sector document representative via OASIS.

In my experience, tooling design was not required to be covered under 8.3.

Thinking about it, it could also be the case of an automotive auditor getting the wires crossed; in automotive, the IATF mandates that the registrant includes PROCESS DESIGN as part of the QMS scope.

Yeah, that was my thinking -- automotive creep.

Who's sanctioned interpretation? Can you view the sanctioned interpretation and see what it says?

 

[Randy]

Who's sanctioned interpretation?

The goofy auditor's probably.