Is ITAR fair game for audit during AS9100 Registration

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Sidney Vianna

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Staff member
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#3
Yes, it's a regulatory requirement.
Not all regulatory requirements fall in the context of a QMS. Only those PRODUCT-RELATED legal requirements.

Sarbanes Oxley is a regulatory requirement, but totally outside of the scope of a QMS. If you "allow" a QMS auditor start delving into any and every regulatory requirement, including OSHA, EPA, SOX, FISMA, ADA, etc., you are "asking for trouble".

Having said that, AS9101D requires CB auditors to check on the organization's ITAR and EAR issues.

AS9101D said:
4.3.2.3 Review of the Organization
During the Stage 1 audit, the subjects listed in clause 4.3.2.2 plus the following items shall be addressed, as applicable:
 number of employees (i.e., full time, part time, contract, temporary) dedicated to aviation, space, and defense;
 number of shifts and shift patterns specific to production and/or maintenance;
...SNIP...
 any customer specific organization approval statuses, e.g., limited approval, probation, suspension, withdrawal;
 customer restricted areas or proprietary information/confidentiality;
 exclusions from 9100-series standards (exclusions must be limited to clause 7) and supporting justification;
export limitations/controls [e.g., International Traffic in Arms Regulations (ITAR), Export Administration Regulation (EAR)];
 

Al Rosen

Holed-up in a Hotel in South Florida
Staff member
Super Moderator
#8
So the answer is no for B, yes for C?:thanx:
Sidney quoted from 9101D, but Statutory and Regulatory requirements are referred to throughout B. I don't think ITAR is specifically addressed in the AS9101C checklist, but it's a regulatory requirement.
 
J

Jeff Frost

#9
Of course it depends if it is applicable but having just completed the online module to AS9100 AATT the following could be fair game during audit in the US:

Code of Federal Regulations (CFR)
Federal Acquisitions Regulations (FAR)
DFAR
ITAR
EAR
 
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