Existing process never included in AS9100 scope of certification

[hockeyhead]

This is my first post, and need to ask for guidance please.
I work for an AS9100/ISO9001/Nadcap accredited plating & coatings shop. We manufacture a coating substance which we sell to aerospace customers, some of which are customers of our plating/coatings processes as well and therefore falls under our AS9100 scope of operations.

The dilemma is that this manufacturing process has never been included in our scope of AS/ISO registration. Our next AS/ISO assessment is this coming September.

Understanding that this is a significant issue, how should we go about notifying our Registrar of this? Do we bring it up during our audit in September or contact the Registrar now, prior to the audit? Need tactful guidance please. Thank you!

 

[Cari Spears]

Hi,

What is your current scope?

 

[hockeyhead]

On our certificate it simply states, "Providing Metal Finishing and Coating Services."

 

[Sidney Vianna]

On our certificate it simply states, "Providing Metal Finishing and Coating Services."

So, based on the scope of certification, the PRODUCTION of the coating material is out of bounds for your AS9100 CB auditor.

The decision on including that part of the business in the scope of certification, or not, is yours. Obviously, your customers might have expectations. Check Dying a slow SCOPE death - NEW ISO APG Paper on Scope and Applicability May 2020.

 

[hockeyhead]

So, based on the scope of certification, the PRODUCTION of the coating material is out of bounds for your AS9100 CB auditor.

The decision on including that part of the business in the scope of certification, or not, is yours. Obviously, your customers might have expectations. Check Dying a slow SCOPE death - NEW ISO APG Paper on Scope and Applicability May 2020.

Thank you Sidney! I will print this document and review with our Quality Manager tomorrow. We don't want to get into trouble with our Registrar, receive a finding, possibly be required to notify our customers, etc.

 

[Sidney Vianna]

We don't want to get into trouble with our Registrar, receive a finding, possibly be required to notify our customers, etc.

The CB cannot impose a scope of certification onto you. Do not act subserviently to the external auditor and acquiesce to their whims. If your organization made a conscious decision NOT to have the production of the coating material in the scope of certification, the CB cannot force you otherwise.

On the other hand, if you want to include the production side of the business in the scope of certification, this can be achieved via a scope extension audit, but the timing for that to happen is up to you.

 

[hockeyhead]

So, based on the scope of certification, the PRODUCTION of the coating material is out of bounds for your AS9100 CB auditor.

The decision on including that part of the business in the scope of certification, or not, is yours. Obviously, your customers might have expectations. Check Dying a slow SCOPE death - NEW ISO APG Paper on Scope and Applicability May 2020.

This process was not intended to be out of bounds, it was just never identified to be included in the scope of AS9100 registration. In fact, the manufacture of this substance is not even mentioned in our Quality Manual.

 

[Cari Spears]

...I work for an AS9100/ISO9001/Nadcap accredited plating & coatings shop. We manufacture a coating substance which we sell to aerospace customers, some of which are customers of our plating/coatings processes as well and therefore falls under our AS9100 scope of operations. ...

As Sidney said, your registrar doesn't determine your scope. Your customers are the ones who will be interested in which of your services and products do or don't fall under your scope.

Do you manufacture this coating and use it to perform the service of coating, and you also sell it sometimes?

 

[hockeyhead]

The CB cannot impose a scope of certification onto you. Do not act subserviently to the external auditor and acquiesce to their whims. If your organization made a conscious decision NOT to have the production of the coating material in the scope of certification, the CB cannot force you otherwise.

On the other hand, if you want to include the production side of the business in the scope of certification, this can be achieved via a scope extension audit, but the timing for that to happen is up to you.

Wow, that's good news. I will cover this with our Quality Manager tomorrow. If I have any other concerns, I will definitely post in this thread. Thank you again.

 

[hockeyhead]

As Sidney said, your registrar doesn't determine your scope. Your customers are the ones who will be interested in which of your services and products do or don't fall under your scope.

Do you manufacture this coating and use it to perform the service of coating, and you also sell it sometimes?

Yes, we do both (we coat customer's parts with it and we do sell it). It is a proprietary formulation of dry film lubricant.