[Exclusions] 7.3 Design and development vs. Thermal Powerplant

[x-files]

Hi,

I remember one unofficial observation of an External Lead Auditor, who said that we should immediatelly exclude "7.3 Design and development" from our QMS.

It's about Thermal Powerplant's QMS.

Our final product is 220V, 50Hz, 110/400kV transmision, and that could never be changed.

What do you think?



Best regards,
Vladimir Stefanovic

 

[Jen Kirley]

Good day Vladimir,

It seems your auditor is correct. If you are not designing services or products then you can exclude 7.3.

 

[somashekar]

Hi,

I remember one unofficial observation of an External Lead Auditor, who said that we should immediatelly exclude "7.3 Design and development" from our QMS.

It's about Thermal Powerplant's QMS.

Our final product is 220V, 50Hz, 110/400kV transmision, and that could never be changed.

What do you think?



Best regards,
Vladimir Stefanovic

I think your external lead auditor was not correct.
It is not about designing of THE THERMAL POWER PLANT, but about YOUR THERMAL POWER PLANT.
Your final product is 220V, 50Hz, 110/400kV transmision would never change, however there is the capacity requirement in the design and the controls necessary for voltage frequency stabilization.
The technology is there perhaps with many world renowned companies and you would be making the best selection for your plant. As you erect, install and commission and sync with the grid you begin to own several responsibilities for the supply and uninterrupted grid feeding. You may want to commit increased capacity or make improvement in your thermal plant over time with new technology or try your own innovative ideas. All these and more are a part of your design and design changes. A thermal power plant is never started without first its design and development. Note again it is not research and development of power generation. The basics are done long long back and thank the scientists, Thomas Edison and others.

 

[AndyN]

If the organization who runs the power plant provide power, to that specification - and it can't be changed - there's no design in it! The scope of the QMS should be as a service. Whomever built the power plant has a different scope - including design, no doubt. To suggest there's design involved here is not correct, IMHO!

 

[somashekar]

My take is that the one who runs the power plant, owns the power plant, and whoever built the power plant for the one who operates, now no more owns the design of it, apart from the take-way learnings. The design and the design change process is outsourced and so an inclusion into the Thermal power plant QMS. The scope as service or providing electric power would not keep the design and development out.

 

[Jen Kirley]

X-files, I feel at a distinct disadvantage here because I have never seen your system and your lead external auditor has - and then advised you to exclude 7.3. So my question now is: why do you question his advice?

 

[x-files]

X-files, I feel at a distinct disadvantage here because I have never seen your system and your lead external auditor has - and then advised you to exclude 7.3. So my question now is: why do you question his advice?

The external auditor I mentioned was the one of those, who gave us many useful recommendations in the past. I consider him as authority, so when he said to exclude 7.3 - I've accepted that very seriously.

Now, I wanted to hear what do you think of that.

He said, mentioning 7.3 could produce big non-conformance to us.

 

[somashekar]

The external auditor I mentioned was the one of those, who gave us many useful recommendations in the past. I consider him as authority, so when he said to exclude 7.3 - I've accepted that very seriously.

Now, I wanted to hear what do you think of that.

He said, mentioning 7.3 could produce big non-conformance to us.

Please take time to inquire with that external auditor the justification for suggesting exclusion, and what exactly is the big NC with design and development included ?
If design and development is excluded, then is the design from customer ? Who customer.
The electricity distribution company or the electricity consumer .... ???

 

[AndyN]

I'm concerned that auditors give recommendations. It's not their job! Plus, why now - it appears to be after some time has passed - that they are only now commenting on this? Is this auditor the only one you've had?

Frankly, I fail to see, if you are simply generating electricity, what design has to do with it, so how could you have been audited and this never come up before? What was the original concept when the organization included it? What was shown as evidence of a design process?

 

[x-files]

First, I want to thank you all for participation in this thread. Your comments are very useful to me.

I'm concerned that auditors give recommendations. It's not their job! Plus, why now - it appears to be after some time has passed - that they are only now commenting on this? Is this auditor the only one you've had?

Frankly, I fail to see, if you are simply generating electricity, what design has to do with it, so how could you have been audited and this never come up before? What was the original concept when the organization included it? What was shown as evidence of a design process?

All your observations are quite logical and honest. I'm afraid that I have not good answers to your questions, because obviously someones business survival is superior to profession

In fact, I have another question, which could be relevant to this thread.

4.2.2
The organization shall establish and maintain a quality manual
that includes
a) the scope of the quality management system, including details of and justification for any exclusions (see 1.2),
b) the documented procedures established for the quality management system, or reference to them, and
c) a description of the interaction between the processes of the quality management system.

Now, I'm in dilemma. What is the scope of our QMS?!

There is a coded list of business activities that our company can do. That list is coded by government and assigned to a company when established.

Our legal list says something like this /bad translated/:

Primer activeness:
1. Thermo-electric generation

Secondary activenesses:
2. Digging up coal
3. ...
4 ...
5 ... Computer programming, hosting...
...
15 ...

As you can see, we really are involved in 1 and 2, and our "interaction between the processes of the quality management system" is spontaneously talking about 1 and 2.

Our other legal activities are just options, and we in practice have nothing to do with "Computer programming, hosting" and similar, which is I don't know how and why associated.

Our procedures are focused on 1 and 2. We do not sell programs and we are not Internet providers...

So can we say that the scope of our QMS is 1 and 2?

I assume this may be relevant to my first question about Exclusions, that's why I pointed this.


Best Regards,
Vladimir Stefanovic