Exclusions - Clauses: 8.2, 8.3 & limiting 8.4 ???

[Stefan Mundt]

As a manufacturer of mechanical components and assemblies we are going from a corporate Certification to a local ISO9001 certification.
I have experience with excluding Engineering from the scope, but in our case Corporate is responsible for so many functions:
- All our key suppliers are selected, developed and assessed by corporate.
- Supplier Quality
- Design Engineering
- Customer Service is to 80% corporate.
- Strategic Development
- Sales & marketing

I am thinking about excluding clauses: 8.2, 8.3 & limiting 8.4.

I assume I have to treat those aspects that are corporate like outside processes and apply controls. (8.4.1 C) I would of course describe this in my manual and provide justification.

My brain struggles with those aspects that are mostly corporate. Our customer service might process the orders that come in from corporate but is not really in contact with the customer. While most of our suppliers are dictated, we still have some that we select and assess. And even fewer of those provide material that we incorporate into our products and those are not strategically important.
Simplified:
Corporate sends us the drawings and we create the processes necessary and start manufacturing.
There is reporting to corporate regarding KPIs that are used to assess suppliers etc.
What do you think???
Does anyone of you have experience with excluding so many aspects of the standard?

Thank you so much!

 

[Randy]

1st, you're not allowed to "exclude" anything, you can claim "non-applicable" but you have to provide justification.

You'd be hard pressed with 8.2 (in total), if the goal is to achieve customer satisfaction, and you have to commit to it in your policy, how can you justify eliminating most of the customer specific stuff from the equation? That duck ain't gonna quack!

As to what I think? As a 3rd party auditor you've now provided me some potentially juicy audit trails from the git-go.

 

[Stefan Mundt]

Thank you, Randy - I appreciate your response!

 

[Stefan Mundt]

1st, you're not allowed to "exclude" anything, you can claim "non-applicable" but you have to provide justification.

You'd be hard pressed with 8.2 (in total), if the goal is to achieve customer satisfaction, and you have to commit to it in your policy, how can you justify eliminating most of the customer specific stuff from the equation? That duck ain't gonna quack!

As to what I think? As a 3rd party auditor you've now provided me some potentially juicy audit trails from the git-go.

Thank you, Randy!
I would then describe those corporate functions as outside services and have controls in place to assess and monitor their capabilities.

Understanding my customer needs is limited to what is put in the system by corporate or by the prints we receive from corporate engineering. We don't even get to see the original POs. corporate translates those into internal orders.
Occasionally we do PPAPs for customers but that is rare. Most of our portfolio is catalog parts. In those cases, there is limited communication.
Complaints from sister plants come directly to us, but other customers would contact customer service which is corporate; they would communicate with us the 8D expectations and present the results to the customer.
It is quite complicated to describe this in a single management system from a single plant perspective.

I am grateful for any suggestions.

 

[Randy]

I would then describe those corporate functions as outside services and have controls in place to assess and monitor their capabilities

You'd be hard pressed to tell your corporate folks that they are wrong. You'd be best served to describe what they do for you and that their offerings are requirements that you must adhere to (obligation you meet). Anything corporate does is most likely out of your control or even influence.

It is quite complicated to describe this in a single management system from a single plant perspective.

That's a bad assumption, I just did a recertification audit this week under pretty similar circumstance, and I do I couldn't even start to say during the course of a year.

 

[Stefan Mundt]

You'd be hard pressed to tell your corporate folks that they are wrong. You'd be best served to describe what they do for you and that their offerings are requirements that you must adhere to (obligation you meet). Anything corporate does is most likely out of your control or even influence.


That's a bad assumption, I just did a recertification audit this week under pretty similar circumstance, and I do I couldn't even start to say during the course of a year.

Am I overthinking this then??? I have to describe my own management system.
I only see the two possibilities:
A) what corporate does is outside of my influence and therefore not applicable to my management system
B) I describe what corporate does as an outside service. If it doesn't meet my criteria I could request corrective action or complain to one level above on the corporate hierarchy. I would define the criteria of control.

I appreciate your help!

I always have to assume that one day I will have a "Letter Of The Law" auditor at my doorstep.

 

[Randy]

I always have to assume that one day I will have a "Letter Of The Law" auditor at my doorstep

Then send him packing because he has his head up his bu**. When an auditor starts saying "I like, I want, I hope, I wish, I prefer, or anything with I like that stuff" he's making his own garbage up and you don't have to pay for garbage, you toss that stuff to the curb.

You need to clearly define what your corporate does or does not do for you and they need to make sure they do as well. More often that not they are a combination of customer & supplier of services, and definitely they are an interested party. Odds are corporate isn't budging to "meet your criteria" so don't hold your breath, but surely you've got an internal process for organizational created problems that could effect you and the "cash paying customers" and your corporate whoever needs to understand and agree.

Will corporate respond to corrective action requests? Nobody at your location woke up one morning with a warm fuzzy thinking "Today I'm gonna make a QMS happen".........No way! Someone at the top has made that decision and flowed the message down "You will do this"....Why? Because it's a capitol investment (CI) with expectation of return (ROI). Nobody on the planet does a MS for fun or kicks. It is all done for $$$$$$$$$$$$$$, and if $$$$$$$$$$$$$$$$$ wasn't involved nobody would give a cra*. And the $$$$$$$$$$$$ it takes to "establish, implement, and maintain a MS has to be approved, and I'm pretty sure it's not the janitorial staff that provides an approval. You can't make corporate do anything, but the guy that signs the checks and expects to make $$$$$$$$$ out of the process can and that's where a good internal communication process is a must.

 

[Kronos147]

It is quite complicated to describe this in a single management system from a single plant perspective.

It does sound complicated.

Who ships the product to the end customer? If corporate, you could tailor the system to service your "one customer" (a.k.a. corporate). That's the best I got at this point.

 

[Sidney Vianna]

but in our case Corporate is responsible for so many functions:
- All our key suppliers are selected, developed and assessed by corporate.
- Supplier Quality
- Design Engineering
- Customer Service is to 80% corporate.
- Strategic Development
- Sales & marketing

Technically, in scenarios such as this, and in fairness, your site should ONLY be able to claim compliance (and be certified) to ISO 9001 if the corporate functions that perform processes covered in the 9001 standard were audited by a CB, just like in the IATF 16949 scheme.

You deeming the processes performed by the corporate office as “outsourced” would immediately bring up the question of how can a subordinate site truly exercise any command and control over HQ. Everyone in the business world know that it does not work like that.

Those were the bad news. The good news are: with (literally) hundreds of accredited certification bodies out there, you will, without a question, find several who would be more than willing to take your money and certify whatever you present to them.

Good luck.