We are currently an ISO-9001 Certified Design and Manufacturing supplier of integrated assembly and welding systems for the automotive and general industrial industries. I have prepared our QMS and documentation for an upcoming AS9100 audit scheduled for April. The executive management has recently made the decision to outsource all of our Mechanical and Controls Engineering. The people who recently worked for the engineering departments are still here, however do not work directly for our company any longer.
So, here's my dilemma:
How do I address this with my new AS9100 auditor?
Currently they are still under our roof, working to our Design and Development Procedures and requirements, so do I treat them as though they are still internal departments?
Am I now exposed to a non-conformance, if it becomes known and I don't have them included within my approved supplier system?
How should I develop the system for this in the future?
We use suppliers of course for purchased components, temp. contractors and special process manufacturing, however, this is different for us, since it's so close to our audit, we are little nervous as to how to handle the situation.
Curiously, we have several threads revolving around the issue of "employee status" vis a vis ISO auditor opinion this week.
In general, my take on this is: "on-site workers, regardless of who actually signs a paycheck, are engaged in a task for the organization, and thus under the "control" of the organization."
Usually, it's pretty easy to differentiate a supplier who performs work off-premises from an external worker (salesman, field engineer, SQA), regardless if the off-premises worker is on a direct payroll for the organization or works for a "temp agency."
Similarly, it seems to me easy to differentiate between a roofing installer, a process machine repairman, a plumber, etc. and a flock of inspectors hired from a temp agency or a room full of CAD people making working engineering drawings from sketches drawn up by in-house engineers. The outside contractors/suppliers are providing a product or service based on THEIR skill and experience and the organization has little control over HOW the task is performed even if the WHEN and WHERE of access is limited.
Conversely, the draftsmen, inspectors, engineers, assemblers, and others hired from a temp agency are specifically bound by the temporary contract to be under the control of the organization for the HOW as well as the WHEN and WHERE. Each individual worker, of course, regardless of whether an outside supplier or a captive temporary worker, brings certain skills and experience to the job which allows him some latitude in how easily or efficiently he performs the task at hand. Your organization is spared the expense of training/retraining a whole crop of new temp employees. (That's why the organization agreed to keep the same workers rather than insisting on a new crop from the temp agency.)
In the specific case, the fact the paycheck signer has changed, but the workers are the same, is merely an accounting detail, NOT an indicator of loss of function or control over their activities.
Think of this whole apparent change as something as trivial as changing bank accounts for the payroll and designating a new organization person as the check signer. From your description, nothing more has changed, nor should anything change in the way you interact on a day-to-day basis with these workers.
BOTTOM LINE:
you still have the same control you had when they were direct employees.
