AS9100D - Updating Scope Exclusions

[MrOctober]

I would like some help with our scope and the exclusions written in it. Our next audit will have to be to rev AS9100D and our scope is written to rev C, what would our scope be to the new revision?

Background:
My company is a sub-tier machining vendor to a prime aerospace supplier, we only provide a machining service for their parts that they manufacture and design by removing flash and gating from their lost wax processes.

Since we are only a vendor we have exclusions written into our scope. It appears the from the correlation matrix provided by IAQG that section 7.3 Design and Development is now 8.3 Design and Development of products and services. Now, that the 8.3 clause now includes “services” does it apply to our company?

7.5.1.4 a, c, d, and e, a lot was added to this clause; 8.5.5 a) is now f), c) is now g), d) is now rolled into possibly g), finally e) is now h).

AS9100C Scope:
Electrical Discharge Machining, CNC Milling, CNC Grinding, CNC Turning, CMM Inspection, and Building of Gauges & Fixtures; Excluding Design (AS 9100 rev C sec 7.3) and Post Delivery Support (AS9100 rev C sec 7.5.1.4 a, c, d, e)

AS9100D Scope:
Electrical Discharge Machining, CNC Milling, CNC Grinding, CNC Turning, CMM Inspection, and Building of Gauges & Fixtures; Excluding Design and Development (AS9100D sec 8.3) and Post Delivery Activities (AS9100D sec 8.5.5 f, g, h)

 

[dsanabria]

I would like some help with our scope and the exclusions written in it. Our next audit will have to be to rev AS9100D and our scope is written to rev C, what would our scope be to the new revision?

Background:
My company is a sub-tier machining vendor to a prime aerospace supplier, we only provide a machining service for their parts that they manufacture and design by removing flash and gating from their lost wax processes.

Since we are only a vendor we have exclusions written into our scope. It appears the from the correlation matrix provided by IAQG that section 7.3 Design and Development is now 8.3 Design and Development of products and services. Now, that the 8.3 clause now includes “services” does it apply to our company?

7.5.1.4 a, c, d, and e, a lot was added to this clause; 8.5.5 a) is now f), c) is now g), d) is now rolled into possibly g), finally e) is now h).

AS9100C Scope:
Electrical Discharge Machining, CNC Milling, CNC Grinding, CNC Turning, CMM Inspection, and Building of Gauges & Fixtures; Excluding Design (AS 9100 rev C sec 7.3) and Post Delivery Support (AS9100 rev C sec 7.5.1.4 a, c, d, e)

AS9100D Scope:
Electrical Discharge Machining, CNC Milling, CNC Grinding, CNC Turning, CMM Inspection, and Building of Gauges & Fixtures; Excluding Design and Development (AS9100D sec 8.3) and Post Delivery Activities (AS9100D sec 8.5.5 f, g, h)

Observation: The word Excluding has been replaced with non applicable.

The Post Delivery activities is know as warranty and they are covered under 8.2 so if all you do is provide a product that does not have a warranty (i.e. this product will work for so long or for so many times) take the complete 8.5.5 and make it not applicable.

Finally, include a justification for not applicable items. For example, design & development - explain why it does not apply.

 

[nacnack]

dsanabria

What if part of a clause 8.5.5 is not applicable? let say f,g,h & i. Do you write those into the scope or just inform the auditor that not all parts of the clause are applicable? If we cherry pick the standard, the NA's in the scope would be huge.

Second question

I have a company that is a machine shop (aerospace) and also manufactures machines that do various automated functions (Commercial). My question is, when it comes to design and post-delivery or basically any place in AS9100D, can those Aerospace requirements be determined as “Not Applicable” for the commercial side even though its an Aerospace company. If so, can you point me to an IAQG, IAF, AAQG, some sort of reference ?

 

[howste]

Second question

I have a company that is a machine shop (aerospace) and also manufactures machines that do various automated functions (Commercial). My question is, when it comes to design and post-delivery or basically any place in AS9100D, can those Aerospace requirements be determined as “Not Applicable” for the commercial side even though its an Aerospace company. If so, can you point me to an IAQG, IAF, AAQG, some sort of reference ?

Your AS9100 scope can be written to not include commercial products, but if commercial products are included in the AS9100 scope you can't exclude those requirements just for commercial products. If you also have an ISO 9001 certificate it could include the commercial products, and then your AS9100 could include only your aerospace products.

 

[nacnack]

howste

So are you saying that the company should have a split scope, and separate certs if they do not want to include Aerospace requirements into their commercial product?

AS9100 - Aerospace Machining

ISO 9001 - Commercial Automated product

 

[howste]

howste

So are you saying that the company should have a split scope, and separate certs if they do not want to include Aerospace requirements into their commercial product?

AS9100 - Aerospace Machining

ISO 9001 - Commercial Automated product

That's an option. Or if the commercial doesn't require any certification it could be scoped out of AS9100 and have no ISO 9001 certificate. If you do have both certifications the ISO 9001 could also include both aerospace and commercial.

 

[dsanabria]

dsanabria

What if part of a clause 8.5.5 is not applicable? let say f,g,h & i. Do you write those into the scope or just inform the auditor that not all parts of the clause are applicable? If we cherry pick the standard, the NA's in the scope would be huge.

Second question

I have a company that is a machine shop (aerospace) and also manufactures machines that do various automated functions (Commercial). My question is, when it comes to design and post-delivery or basically any place in AS9100D, can those Aerospace requirements be determined as “Not Applicable” for the commercial side even though its an Aerospace company. If so, can you point me to an IAQG, IAF, AAQG, some sort of reference ?

What if part of a clause 8.5.5 is not applicable? let say f,g,h & i. Do you write those into the scope or just inform the auditor that not all parts of the clause are applicable? If we cherry pick the standard, the NA's in the scope would be huge.

You need to make a statement as to what is not applicable to the standard and you need to provide justification so that when the auditor shows up - they are able to review and agree.

I have a company that is a machine shop (aerospace) and also manufactures machines that do various automated functions (Commercial). My question is, when it comes to design and post-delivery or basically any place in AS9100D, can those Aerospace requirements be determined as “Not Applicable” for the commercial side even though its an Aerospace company. If so, can you point me to an IAQG, IAF, AAQG, some sort of reference ?

When you have a company that has multiple tasks... You can have multiple certificate. So to your question - can I have a certificate for aerospace with section of the company doing commercial product? - the answer is yes, However... You need to make sure that individuals in the commercial section do not cross over and do aerospace products - that will cause you and the auditor to increase the scope of the audit and include that section into the aerospace scope.

Let me know if this helps...)

 

[Big Jim]

Observation: The word Excluding has been replaced with non applicable.

The Post Delivery activities is know as warranty and they are covered under 8.2 so if all you do is provide a product that does not have a warranty (i.e. this product will work for so long or for so many times) take the complete 8.5.5 and make it not applicable.

Finally, include a justification for not applicable items. For example, design & development - explain why it does not apply.

There is more to 8.5.5 than just warranty. Please see the NOTE at the end of 8.5.5.

The AS9100D clarifications also provides some more illumination on the topic.

Additionally, according to my business law professors, and my attorney friends, if you deliver product with the understanding that you will take care of it if something is wrong, that is a warranty. That would make 8.5.5 difficult to ever exclude.

However, there is no reason to exclude it. It is in essence an "as appropriate" clause.

"The organization shall meet requirements for post-delivery activities associated with the products and services. In determining the extent of post-delivery activities that are required, the organization shall consider . . . " (Emphasis added)

So this would mean that you don't do any of the a - l requirements unless needed and even then that you consider them, not necessarily act on them.

 

[dsanabria]

Based on the clarification from IAQG

Quote:
"If an organization provides any post - delivery activities (such as, clause 8.5.5
cannot be excluded in its entirety. At a minimum, the portion “When problems are detected after delivery, the organization shall take appropriate action
including investigation and reporting.” would be applicable.

Product that is found to be nonconforming after delivery to the customer require actions to be taken, including investigation and reporting; therefore 8.5.5 is applicable. The organization may utilize the Control of Nonconformity Outputs
Process and Corrective Action process as the method for implementing
this requirement; however, Clause 8.5.5 would not be excluded in its entirety."

I have included in the Business Management Manual the following:
Not Applicable:
8.5.5 Post Delivery Activities (a through i) – Jonal provides a product based on customers print.

Note: When problems are detected after delivery, the organization shall take appropriate action including investigation and reporting, which will be done through the non-conforming process.

 

[Marie Cavanaugh]

Clause 8.5.5 would be f-I with justification that you do not perform outside work once it leaves your establishment. You need justification for 8.3 as well.. Company ABC is exempt from Clause 8.3 as we do not design, if we chose to, in the future, we will become compliant to this clause.. etc.