Hi All,
This question has had great responses and I appreciate everyone helping. Here is what I have learned since the original post:
What can be excluded if we are not Design Responsible:
- Anything related to “product design” can be excluded. Anything related to “process design” cannot be excluded (as Duke mentioned).
- therefore, 7.3.2.1 and 7.3.3.1 are the only two clauses that can be excluded.
- so as you can see most of 7.3 still applies, as "Manufacturing Process Design and Development"
- even if an organization is registered with 7.3 as an exclusion, then you get one contract as Design Responsible, the organization needs to re-register with all of 7.3 included asap.
Design Responsible Clarification:
There are only 2 options regarding “design responsible”.
(1) The client or supplier is responsible to design and manufacture the widget for a customer.
(2) The customer retains responsibility for the design and only contracts the supplier to manufacture the widget.
So, currently we do have one contract as design responsible, with one customer, so by default that means the scope of our registration needs to include all of 7.3. In other words 99% of our business is awarded as customer is DR, 1% is we are DR.
As Sidney mentions this is a go/no-go (or attribute) decision; and...we are DR. I have since talked with our registrar and they have helped clear all of this up for us too.
Initially, we had lots of DR work with our customers/OEM's and included 7.3 in our scope (before my time in this role) but since 2004 our business has changed drastically as has the entire North American automotive market. We were thinking there would be an advantage to exclude 7.3 "Product Design and Development" but now, based on all of this information, it seems like too much of a hassle to exclude being you only need one job as DR and you need to re-register again....a waste of everyone's time and money.
Thanks again all, I appreciate your great feedback.
Dave
