Exclusions allowed in AS9100

M_Auditor

Registered
Hello,

I have a question on the Exclusions allowed in AS9100
Can a company exclude 8.5.5 (A, C &D)?
the company provide service (Special process)
My understanding is that those clauses are mandatory and applicable to every client certified with AS9100
please correct me if I am wrong
Please advise
 

Funboi

On Holiday
A service (special process)? Do you mean like heat treatment? “Exclusions” are based on scope of the QMS.
 

M_Auditor

Registered
A service (special process)? Do you mean like heat treatment? “Exclusions” are based on scope of the QMS.
It's a heat treatment yes
and they are excluding something like customer requirements (which include PO requirements)
in my opinion, those (A Thru E) are applicable to all organizations
they can exclude F thru I and that's very common
 

Randy

Super Moderator
There are no exclusions, but you can claim "non-applicability" with valid justifications that you can demonstrate or prove
 

Sidney Vianna

Post Responsibly
Leader
Admin
they are excluding something like customer requirements (which include PO requirements)
This makes no sense whatsoever. How would an organization justify non applicability of customer requirements, IF INDEED, they might be involved with any post-delivery activity? On the other hand, a special process house organization might have a good path to justify non applicability of the whole of 8.5.5.
 

M_Auditor

Registered
This makes no sense whatsoever. How would an organization justify non applicability of customer requirements, IF INDEED, they might be involved with any post-delivery activity? On the other hand, a special process house organization might have a good path to justify non applicability of the whole of 8.5.5.
They are saying in their manual 8.5.5 (A, C &D) is not applicable to us and that's it. that's their justification.
what is really surprised me that they are not only won the appeal but as you can see here, auditors and experts agree with them

not sure how heat treat company says (a. statutory and regulatory requirements;c. the nature, use, and intended lifetime of its products and services, d. customer requirements) are not applicable to us

Applicable = Exclusion is the same thing, rev D change the word but both means (I do not comply with this clause).

who made this change is the new QM that have no experience in AS9100 and I guess it works for him
 

Sidney Vianna

Post Responsibly
Leader
Admin
I am confused in what capacity you are involved with this organization, but assuming you are working on their behalf somehow, you call their CB aerospace program manager and ask him/her to explain how such exclusions were blessed by their auditors. Further, in OASIS, all exclusions shall be identified. Have you checked there?
 

M_Auditor

Registered
I am confused in what capacity you are involved with this organization, but assuming you are working on their behalf somehow, you call their CB aerospace program manager and ask him/her to explain how such exclusions were blessed by their auditors. Further, in OASIS, all exclusions shall be identified. Have you checked there?
I am their third party auditor. I wrote those finding but the client won the appeal and they are closed now. I have talked to the appeal team and manager, 2 agree and 2 dis agree. I m confused and that's why I came here to clarify

thanks
 

Randall Beck

Involved In Discussions
As the Quality Manager of a commercial heat treat organization registered AS9100 and NADCAP I'm also not sure how someone can claim to exclude statutory/regulatory and customer requirements. Every one of our aerospace customers, at a minimum, require record retention and post-delivery notification of non-conforming product if it is found to be non-conforming for any reason after delivery at a minimum. I include these activities as part of 8.5.5 in our QMS. Do they also exclude ITAR/EAR requirements for record retention or just not accept it in their building? I guess it could be possible if it was an extremely small shop with an extremely small scope. but its puzzling....and seems like there is more to it.
 
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