AS9100D, Clause 8.4.1.1d - actions to take when external providers do not meet requirements

Kronos147

Trusted Information Resource
Then the auditor has no business auditing government contractors if he doesn't understand the relationship between contractors, the organization being served, the contract itself and the government contracting offices & regulations. Actually pretty typical for an auditor to be as lost as a blind folded duck in a duststorm.

That sounds like a risk to the organization.

How to mitigate the risk? Perhaps document it in the manual or procedure and help an "relevant interested party" (an auditor that doesn't have experience with government contracts) understand the boundaries of responsibility.
 

Randy

Super Moderator
That sounds like a risk to the organization.

How to mitigate the risk? Perhaps document it in the manual or procedure and help an "relevant interested party" (an auditor that doesn't have experience with government contracts) understand the boundaries of responsibility.
Count the number of auditors you know, that have actual, hands on, multiple year experience in US Government contracting.......Experience is one of those things we find necessary for "Competence". I've got 18 years or so on Cost+ and Cost+ Award Fee contracts myself, in GOCO operations, as opposed to COCO. If the contract mandates the use of the Federal Supply System the contactor has absolutely no choice in anything, supplier selection, material qualification, everything is out of their hands, an most of the time it's to lowest bidder and not best quality. (Experienced myself many times in US Government aircraft maintenance)

Of course this entire subject falls in line with my somewhat disdain for the AS9100 auditing field itself as a good many auditors have never, ever touched an airframe other than as a commercial passenger (Having twisted wrenches isn't an absolute of course, but what could be the harm?)
 

Sidney Vianna

Post Responsibly
Leader
Admin
Of course this entire subject falls in line with my somewhat disdain for the AS9100 auditing field itself as a good many auditors have never, ever touched an airframe other than as a commercial passenger (Having twisted wrenches isn't an absolute of course, but what could be the harm?)
To imply that touching an airframe would make anyone a better aerospace management system auditor is pretty shortsighted in my opinion. Heck, one of the big problems in “professional management system auditing” we have is the fact that people who spent 3 decades as inspectors make it to the job. We have too many CB auditors out there do not comprehend systems approach to anything and get bogged down in minutiae and silly technicalities, incapable of understanding the big picture.
 

Jim Wynne

Leader
Admin
...a good many auditors have never, ever touched an airframe other than as a commercial passenger (Having twisted wrenches isn't an absolute of course, but what could be the harm?)
Most obstetricians are males who have never been pregnant.
Added in Edit: I was wrong. In the US most OB/GYNs are female today, but hopefully have not twisted any wrenches at work. :)
 
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Randy

Super Moderator
To imply that touching an airframe would make anyone a better aerospace management system auditor is pretty shortsighted in my opinion. Heck, one of the big problems in “professional management system auditing” we have is the fact that people who spent 3 decades as inspectors make it to the job. We have too many CB auditors out there do not comprehend systems approach to anything and get bogged down in minutiae and silly technicalities, incapable of understanding the big picture.

Yep but it would sure help, besides, what would it hurt? Isn't having a background in something required by 17021 before one can audit that area? I guess my nearly 40 years of being an A&P would be a hinderance to my being an aerospace auditor? Shucks.
 

LincolnQA

Starting to get Involved
Then the auditor has no business auditing government contractors if he doesn't understand the relationship between contractors, the organization being served, the contract itself and the government contracting offices & regulations. Actually pretty typical for an auditor to be as lost as a blind folded duck in a duststorm.
Randy, this was a big issue during my AS9100 Pre-Assessment and during the Stage 1. We spent a lot of time trying to get the Auditor to understand our business. If often felt like we were jamming a square peg in a round hole...
 

LincolnQA

Starting to get Involved
If there was a particular finding based on a particular incident, you could respond to that specifically. If the audit finding is more generic, "for not addressing Clause 8.4.1.1d ", then I think the appropriate response will be broad and generic. In your operational procedure, when there is a problem encountered, point to your Control of Non-Conforming Outputs procedure (whatever you have written to address 8.7). Section 8.7 gives a pretty good outline what steps to take. Our company uses the 8-D form, which outlines a sequence to take for any problem - including define, contain, root cause determination, correction and corrective action. We use the same 8-D outline of steps for hardware problems, software, and procedural problems.
John, thank you for your response/guidance. I am going to look into the 8D form. Right now, we use a simple 5 Why Approach but feel that something more robust is needed. Thank you!
 

Randy

Super Moderator
Randy, this was a big issue during my AS9100 Pre-Assessment and during the Stage 1. We spent a lot of time trying to get the Auditor to understand our business. If often felt like we were jamming a square peg in a round hole...
As I said, if the auditor had no concept of government contracting, it's obligations, requirements, and differences with what we call normal business relationships, you should have shown him the door.

Right now, we use a simple 5 Why Approach but feel that something more robust is needed. Thank you!
CAUTION! Better review your contract, depending on how it's written, in many times you're obligation to use the quality system of the branch or organization you're serving. We always had to abide by Army Quality and build our QMS around it. Examples below -

https://armypubs.army.mil/epubs/DR_pubs/DR_a/pdf/web/ARN13723_R702_11_CertifiedCurrent_FINAL.pdf

https://bits.de/NRANEU/others/amd-us-archive/FM55-411(81).pdf
 
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