The AS9101 SDR will bring this up for this discussion and the next AS9101D FAQ document should clarify this issue. In the meantime, the feedback I got from someone very involved with the development of the AATT course material states:Sidney;
Can this be clarified on "FAQ - AS9101D" - on the IAQG website?
A non-conformity identified due to not conforming to a requirement in the AQMS standard does not mean a second non-conformity must be written against section 4.1 c and f. The only time a non-conformity is required to be written against 4.1 c and f is if a PEAR rating of 1 or 2 is noted. If we remember that a rating of 1 or 2 requires at a minimum the lack of action to improve a process it would seem logical that many processes will not be fully effective but actions will be underway. In this case the PEAR rating should be a 3 which does not require a non-conformity to be written.