Effect on Registration: Changing Buildings

[Marc]

Received this:

Marc,

Our plant in Mexico was told that if you change buildings after you plant was registered, you lose your registration and must re-apply. Is this true?

Please advise

Thanks,

Not as I understand it. I believe all you do is change the registration scope / location or other applicable detail.

Experts?

 

[Cari Spears]

I'm no expert - but that does not sound right. I've sent an email to the technical guy at our registrar. I'll let you know what he says.

 

[Marc]

I guess my assumption is that it's just a building change. The word 'facility' wasn't used, so I assume it's on the same plot of land - the same plant location.

Maybe Jeff will come here and join in and give us more information.

 

[ATeam Central 01]

Question regarding moving sites

I just had this question answered from technical. It all depends on if the activity that is moving into the new facility is simply being MOVED or if it is being re-tooled.

If it's being fully moved, then NO. Your registrar may need to perform an additional day to fully assess the site. (Registrar also needs to take into account the time that it will take to move the site. If it's a stepped approach you may need an extension to scope to cover those activities while in limbo).

If it's being re-tooled and additional product will be manufactured there then it may be considered a "greenfield" site - this is tricky because now it depends on which standard you are registered to.

With ISO/TS 16949 Greenfield sites cannot be registered until there is 12 mos. of data/history. -straight from the IATF rulings.

With ISO 14001 you will probably need a special assessment equal to a surveillance visit to ensure your new site is meeting all regulatory requirements, etc.

Obviously, you could ask 3 different registrars and possibly get 3 different answers. I'd challenge the answer if it required more than just a couple of days. I hope this helps.

 

[obaraguy]

Changing Locations

Hello All,

Thanks for the replies. As I currently understand our situation, our plant (which has approximately 20~25 employees) is in fact moving to a different location. But, this location is just down the street. They are still going to make their standard products with no change in scope. They were planning to be registered at the original location before they move.

I guess the real question is should they wait to gain registration until after they move? or would it even matter since it's just down the street?

Thanks for any help!

 

[Cari Spears]

I posed the question to the Technical Manager at our registrar in terms of ISO only - it didn't occur to me to ask about TS.

His response:

Factors that would require a re-registration or additional time on the surveillance:

1) Change in procedures
2) New management or personnel
3) New equipment, product or processes

A registrar should consider the impact of the change based on the factors listed above.

Notice he said "or additional time on the surveillance". He also went on to mention that the company will need to "follow the notification requirements in the sanctioned interpretations. R7." I don't know what R7 is, but there it is.

 

[Cari Spears]

...depends on if the activity that is moving into the new facility is simply being MOVED or if it is being re-tooled...

...Obviously, you could ask 3 different registrars and possibly get 3 different answers. I'd challenge the answer if it required more than just a couple of days...

Sounds like our technicals agree. That's actually pretty "comforting".

 

[Marc]

Which Standard

I guess the real question is should they wait to gain registration until after they move? or would it even matter since it's just down the street?

This is ISO 9001:2000, correct?

 

[obaraguy]

Changing Buildings

Yes, we are talking about ISO 9001-2000

Thanks

 

[Aaron Lupo]

I posed the question to the Technical Manager at our registrar in terms of ISO only - it didn't occur to me to ask about TS.

Notice he said "or additional time on the surveillance". He also went on to mention that the company will need to "follow the notification requirements in the sanctioned interpretations. R7." I don't know what R7 is, but there it is.

Cari-

It would be the same for TS as well. R7 is IASG sanctioned interpretations www.qs-9000.org.


R7
"Joint Ventures, Mergers, Acquisitions (07/01/01)
A supplier shall notify its registrar of the following site changes: closure, transfer of ownership
including merger, acquisition or joint venture. Notification shall be provided by the supplier to the
registrar of record within 30 days from the time such site change was announced. Failure of the
supplier to comply with the notification requirements shall result in a major non-conformity issued
from the registrar of record, a major nonconformance which can only be closed by the registrar
conducting a special on-site surveillance audit, up to and including a full audit.
Within 60 days of supplier notification to the registrar of record, such registrar shall complete the
following: determine the timeliness, scope and extent of surveillance audit requirements; and if
necessary, conduct a special surveillance assessment, up to and including a full audit."