Exclusion of AS9100C Clause 7.1.1 and Clause 7.1.3 for a Small Shop

[dsanabria]

We just had our upgrade to AS9100 Rev C and the auditors told us that because we are a small shop (12 individuals) and all we do is cut large pieces to small shape (per print) that we could invoke the exclusion requirements of 7.1.1 Project Management and 7.1.3 Configuration Management.

Just wanted to know if any small shops have a different take on this requirements.

 

[DannyK]

Re: Exclusion of AS9100C 7.1.1 and 71.3 for a small shop

We just had our upgrade to AS9100 Rev C and the auditors told us that because we are a small shop (12 individuals) and all we do is cut large pieces to small shape (per print) that we could invoke the exclusion requirements of 7.1.1 Project Management and 7.1.3 Configuration Management.

Just wanted to know if any small shops have a different take on this requirements.

I totally disagree with excluding Project Management & Configuration Management.
When the small shop gets an order, isn't there any configuration information provided?
Does anyone in the shop plan the production to ensure that the required resources are available and the schedule is being met?

 

[Sidney Vianna]

Re: Exclusion of AS9100C 7.1.1 and 7.1.3 for a small shop

We just had our upgrade to AS9100 Rev C and the auditors told us that because we are a small shop (12 individuals) and all we do is cut large pieces to small shape (per print) that we could invoke the exclusion requirements of 7.1.1 Project Management and 7.1.3 Configuration Management.

Just wanted to know if any small shops have a different take on this requirements.

Personally, I do agree with the exclusions in that scenario. However, the "authors" of AS9100 seem to think that PM and CM must apply to ALL AS&D organizations, irrespective of size, product, etc... At least, that is what I conclude after reading the IAQG 9100 Change & Rationale document, which stipulates:

Project management is an important new topic introduced at this update- important because every type and size of organization carries out ‘project management’ in some form or other. Project management is included in clause 7.1 because its requirements apply to all phases of the lifecycle

and

Configuration management is included now in clause 7.1 because its requirements apply to all phases of the lifecycle of products realization and use

I have repeatedly voiced my request for guidance on the scalability of PM, RM & CM for AS9100/9110 users that fit the Small & Medium size category. So far, nobody has listened.

It will be interesting to see if your CB will be able to identify PM and CM as non-applicable when they are entering the organization's data into OASIS.

 

[Sidney Vianna]

Re: Exclusion of AS9100C 7.1.1 and 71.3 for a small shop

Does anyone in the shop plan the production to ensure that the required resources are available and the schedule is being met?

Wouldn't an ISO 9001-compliant machine shop have to do that, as well? ISO 9001 has no requirements for CM nor PM.

 

[dsanabria]

Re: Exclusion of AS9100C 7.1.1 and 71.3 for a small shop

I totally disagree with excluding Project Management & Configuration Management.
When the small shop gets an order, isn't there any configuration information provided?
Does anyone in the shop plan the production to ensure that the required resources are available and the schedule is being met?

Section 7.1 covers that point completely in a small shop

And I quote
"The organization shall plan and develop the processes needed for product realization. Planning of product realization shall be consistent with the requirements of the other processes of the quality management system (see 4.1).
In planning product realization, the organization shall determine the following, as appropriate:

a) quality objectives and requirements for the product;
NOTE Quality objectives and requirements for the product include

consideration of aspects such as
- product and personal safety,
- reliability, availability and maintainability,
- producibility and inspectability,
- suitability of parts and materials used in the product,
- selection and development of embedded software, and
- recycling or final disposal of the product at the end of its life.
b) the need to establish processes and documents, and to provide resources specific to the product;
c) required verification, validation, monitoring, measurement, inspection and test activities specific to the product and the criteria for product acceptance;
d) records needed to provide evidence that the realization processes and resulting product meet requirements (see 4.2.4);
e"end of Quote) configuration management appropriate to the product;

Furthermore, if you read the note on 7.1.3 - it makes a reference to ISO 10007. After reading that spec, you will realize that an exclusion is justifiable.

This is what the 3rd party was pointing out - and we are taking it.

 

[Hodgepodge]

We just had our upgrade to AS9100 Rev C and the auditors told us that because we are a small shop (12 individuals) and all we do is cut large pieces to small shape (per print) that we could invoke the exclusion requirements of 7.1.1 Project Management and 7.1.3 Configuration Management.

Just wanted to know if any small shops have a different take on this requirements.

As far as configuration management goes, the small shop making items to print is using the configuration defined by the customer. The product designer is maintaining/managing the configuration and the small shop is using it.

You may say this small company is exempt from this requirement but in reality, they still care about it. If there is a B/P change to work in progress and the change is flowed down, your company will make a change to the configuration of the part. If parts in WIP have already been completed and cannot be altered to match the new configuration, you will use the customer's configuration designations to communicate any issues to the customer. The supplier is not at fault when a change is made halfway through. “Sorry, 15 pieces were already completed to Rev A, the remaining 15 can be made to the new Rev B print but the cost will be an additional $XX.XX.”

The small company in this example does not need to document the configuration management process; it will be easily understood and easy to prove. The idea of claiming exemption from the requirement seems more difficult than proving use of the customer's preexisting configuration management.

 

[dsanabria]

As far as configuration management goes, the small shop making items to print is using the configuration defined by the customer. The product designer is maintaining/managing the configuration and the small shop is using it.

You may say this small company is exempt from this requirement but in reality, they still care about it. If there is a B/P change to work in progress and the change is flowed down, your company will make a change to the configuration of the part. If parts in WIP have already been completed and cannot be altered to match the new configuration, you will use the customer's configuration designations to communicate any issues to the customer. The supplier is not at fault when a change is made halfway through. “Sorry, 15 pieces were already completed to Rev A, the remaining 15 can be made to the new Rev B print but the cost will be an additional $XX.XX.”

The small company in this example does not need to document the configuration management process; it will be easily understood and easy to prove. The idea of claiming exemption from the requirement seems more difficult than proving use of the customer's preexisting configuration management.

Agree, this is why the auditor didn't want us to ignore the configuration management in section

7.1 e) configuration management appropriate to the product.

Companies that have design and development clause:

7.3.6.1 c) the correct configuration is submitted to the test

must incorporate clause 7.1.3 and use ISO 10007 for guidance.

Thanks for the feedback

 

[Sidney Vianna]

As far as configuration management goes, the small shop making items to print is using the configuration defined by the customer. The product designer is maintaining/managing the configuration and the small shop is using it.

You may say this small company is exempt from this requirement but in reality, they still care about it. If there is a B/P change to work in progress and the change is flowed down, your company will make a change to the configuration of the part. If parts in WIP have already been completed and cannot be altered to match the new configuration, you will use the customer's configuration designations to communicate any issues to the customer. The supplier is not at fault when a change is made halfway through. “Sorry, 15 pieces were already completed to Rev A, the remaining 15 can be made to the new Rev B print but the cost will be an additional $XX.XX.”

The small company in this example does not need to document the configuration management process; it will be easily understood and easy to prove. The idea of claiming exemption from the requirement seems more difficult than proving use of the customer's preexisting configuration management.

I still don't buy this. What you refer to as configuration management in , to me, is nothing more than product conformity to requirements. As I said before an ISO 9001 compliant machine shop would be required to do the same thing without having to comply with CM. Yesterday I emailed the AS9100 SDR asking for clarification on this subject since this very question about the possibility of excluding PM, RM and CM has been already asked and the answer in the 9100:2009 clarifications document is inconclusive: the first half of the answer says that the exclusions would be possible while the second half of the answer states that all organizations in the ASD sector would be expected to demonstrate some form of CM, PM & RM. . I think it is time for people offering interpretations clarifications to come off the fence.

 

[dsanabria]

I still don't buy this. What you refer to as configuration management in , to me, is nothing more than product conformity to requirements. As I said before an ISO 9001 compliant machine shop would be required to do the same thing without having to comply with CM. Yesterday I emailed the AS9100 SDR asking for clarification on this subject since this very question about the possibility of excluding PM, RM and CM has been already asked and the answer in the 9100:2009 clarifications document is inconclusive: the first half of the answer says that the exclusions would be possible while the second half of the answer states that all organizations in the ASD sector would be expected to demonstrate some form of CM, PM & RM. . I think it is time for people offering interpretations clarifications to come off the fence.

Thank you Sidney, our third party auditor has accepted the exclusion and we will support the appeal process (if it comes to that cross road). Furthermore, there are a few ANAB auditors that might be interested in the application of those requirements.

 

[dsanabria]

I still don't buy this. What you refer to as configuration management in , to me, is nothing more than product conformity to requirements. As I said before an ISO 9001 compliant machine shop would be required to do the same thing without having to comply with CM. Yesterday I emailed the AS9100 SDR asking for clarification on this subject since this very question about the possibility of excluding PM, RM and CM has been already asked and the answer in the 9100:2009 clarifications document is inconclusive: the first half of the answer says that the exclusions would be possible while the second half of the answer states that all organizations in the ASD sector would be expected to demonstrate some form of CM, PM & RM. . I think it is time for people offering interpretations clarifications to come off the fence.

My auditor just gave me this piece of information from the

Configuration Management Guidelines
Supply Chain Management Handbook (SCMH)

http://www.sae.org/servlets/registr...HGeneral&PAGE=getSCMHBOOK&vgenNum=115&scmhs=5

This is a brief introduction to the Configuration Management (CM) materials provided in this chapter.

Introduction:

The Aerospace Standards (e.g. 9100:2009) call for the implementation of Configuration Management (CM) and documents control throughout the entire life cycle of product realization.

Configuration Management is a discipline widely used in the acquisition of defense systems, as well as commercial products and services. A disciplined CM process ensures that products conform to their requirements and are identified and documented in sufficient detail to support the product life cycle. CM assures accurate product configuration information and enables product interchangeability and safe product operation and maintenance to be achieved.

When Configuration Management principles are applied using effective practices, return on investment is maximized and product life cycle costs are reduced. The small investment in resources necessary for effective Configuration Management is returned many folds in cost avoidance.

Instructions for use:
The chapter includes the following materials:

• Configuration Management Introductory Presentation – Executive summary intended to introduce in general terms the reasons and benefits resulting from CM process implementation.

• Configuration Management Guidelines - a presentation describing Configuration Management functions and principles and defining CM terminology for use with AS&D product line. The guidelines recommend implementation of appropriate processes and tools to establish and maintain consistency between the product and the product requirements and attributes defined in product configuration information.

• CM Process Implementation Self Assessment checklist – a detailed checklist that can be used by an organization to validate that the implemented CM process complies with customer expectations and may provide clues for CM process improvement actions.

Note: Since there is a relationship between Configuration Management and engineering changes management, it is recommended that the reader be acquainted with the Notification of Change (AAQG AS9016) guidelines and tools. Those are included in the IAQG Supply Chain Management Handbook, Chapter 8.1.

Disclaimer:
The intention of this section is to assist organizations with understanding the concept and process of SRCI management and control and is not intended to be a requirement, nor auditable.

SCMH Strategy Committee and Project Team
October 2010