Help to understand and response to API AAR during the re-certification audit

J

Jigyasa

On Holiday
Hello Covers,

Hope you all are doing great. My thanks in advance to all of you.

I am writing down the exact wordings of API for better understanding.

Audit type - Recertification
Finding type - Minor Nonconformance
Product impact - Potential
Requirement/ MS standard - Program Agreements

Description - A Licensee agrees not to use the API Monogram on products in a fashion likely to confuse customers as to the identity of the actual Monogram Licensee. If another entity’s name is marked on the product, the Licensee’s name and Monogram license number shall be closer to the Monogram than any other marking, and the Licensee’s name shall be larger than the name of any other entity.

Objective Evidence - Product: Ring Joint Gasket - RX50
Job code ref.: XXXX Supplied to customer M/s. ABCD, was marked with customer name ABCD on the product.
The size of marking used for punching the licensee and the customer was 3 mm, which lead to the confusion.
The facility having 2 dot punching machine fitted with 3 mm punch only, no lesser size punch was available with facility.
The marking procedure ref.: XXXX Rev 6 Issue 4 Date 1 Jan 2019 does not address the control on part 2 requirements.

Nonconformance description - API Monogrammed Ring Joint Gaskets do not conform to requirements of Part-2 of the API Monogram Licensing Program Requirements.
 
C

Confidential

On Holiday
Your corrective action includes - Revise your process for internal communication that includes discussion on API monogram update and any other relevant update from API in weekly meetings. Verify the effectiveness of implementations in MRM as well. Communicate this revised process with concern users with MOM.

Correction includes - You have to revise your procedure for API monogram marking to includes the requirements of Part-2 of the API monogram licensing program requirements. Awareness training for the revised procedure. Measure the effectiveness of given training.

Root cause - Of course, you are the one who can tell us this better. Thank you.
 
J

Jigyasa

On Holiday
Confidential - thanks for your suggestion.

Justification:-

Please note that, for ring gaskets, in order to maintain the identity of the actual Monogram Licensee i.e. Company A, we have marked our name and monogram license number closer to the Monogram as required by Part-2 of the API Monogram Licensing Program Requirements.

However, customer name i.e. ABCD was marked with equal punch size but at location isolated to the rest of the marking and in a fashion not to confuse the customer.

Please note that customer marking was never in the vicinity of the monogram or license number plus the place of origin was also reflected.

Also, note that we have marked customer name i.e. ABCD only on ring gaskets. For rest of the API monogram products we have dispatched, we have not marked any customer name marking.

Root Cause:-

Internal communication controls regarding API Monogram updates are inadequate due to which marking requirement is not implemented in our QMS documentation.
 
T

Thee Bouyyy

Multiple Personalities
No, No, It's not so easy as you guys are talking @Confidential and @Jigyasa. Just let me know,

Part 2 of the API Monogram Licensing requirements states "the Licensee's name shall be larger than the name of any other entity."

Please provide a root cause analysis as to why your organization was not meeting the requirement to begin with. Why did you not implement correct communication controls regarding API. This part 2 of the licensing requirements is not a new update. Why was it not followed? Once you have an updated root cause analysis, provide an updated correction and corrective action related to the root cause.

In your root cause you state that the name of the customer was marked with "equal punch size," per the statement in the beginning, this is not allowed. You must correct this error before sending the product to the customer. If you have sent the product to the customer, you must provide customer notification (in English) and remove the API Monogram Mark from those products. You must evaluate if other products were affected by this non-conformance. If there were other products impacted, you must provide customer notification and remove the monogram mark.
 
lanley liao

lanley liao

Lingli Liao
Hi, Jiayasa, I agree with Thee Bouyyy and Confidential.
Correction:
1. You first should investigate this problem and how many products were used for this nonconformance, whether these products were delivered to the customer, removing them and re-marking these products using correct ways that your company name`s size shall be larger than the customer name`s. Records of removing and re-marking shall be maintained.
2. Organize related functional departments to review together this nonconformance if other products were affected by this nonconformance, if there were other products being impacted, you should notify (in English) the customer of Ring Joint Gaskets monogrammed not conform to requirements of Part-2 of the API Monogram Licensing Program Requirements, and maintain records of such notification.
Root Cause:
In August 2019, we received an email updating the API monogram licensing program requirements (version 13), and we have identified, controlled, and conducted training regarding these requirements only to management personnel other than operational personnel. Meantime. The API Monogram Marking Procedure does not specify clearly the requirements of Part-2 of the API Monogram Licensing Program Requirements. So led to this nonconformance.
Correction Action：
1. Revise the API Monogram Marking Procedure that incorporated the requirements of Part-2 of the API Monogram Licensing Program Requirements into this procedure documented.
2. Perform the training to related departments and personnel.
FYI.
 
J

Jigyasa

On Holiday
Thee Bouyyy said:
Please provide a root cause analysis as to why your organization was not meeting the requirement to begin with. Why did you not implement correct communication controls regarding API. This part 2 of the licensing requirements is not a new update. Why was it not followed?
Click to expand...

@Thee Bouyyy you are completely correct and we understand the concern that was raised.

The root cause of this specific AAR was our fair unbiased interpretation of the marking requirements. We believed that the intent of the marking requirements from API is to ensure that there is no deceptive or confusion as to who the licensee is and who the monogrammer is.

This is exact reason we mark the ring gaskets as you can see with all pertinent information (monogram in conjunction with the license number, product description, identification date and origin). We have never marked customer related information anywhere close to the monogram or associated the marking with the monogram.

The customer marking is on the opposite side of our marking and they required that marking to be able to differentiate the products that we sell them from the products we sell anybody else. Typically we not get request from the customer to include any additional tracking information.

Please note that we previously requested clarification in the past from API. We were confident that the practice would have been acceptable as is.
 
J

Jigyasa

On Holiday
lanley liao said:
1. You first should investigate this problem and how many products were used for this nonconformance, whether these products were delivered to the customer, removing them and re-marking these products using correct ways that your company name`s size shall be larger than the customer name`s. Records of removing and re-marking shall be maintained.
Click to expand...

Customer has been notified about the non-conforming API 6A monogram ring gaskets supplied to them. We have asked the customer to return products already received. We have received the ring gaskets from the customer and re-stamped the customer required information with smaller stencil and it is located on the opposite side of the ring.
 
You must log in or register to reply here.
Top Bottom