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Can ITAR Registration and procedures be audited during AS9100B Registration audit
Yes, it's a regulatory requirement.Can ITAR Registration and procedures be audited during AS9100B Registration audit
Not all regulatory requirements fall in the context of a QMS. Only those PRODUCT-RELATED legal requirements.Yes, it's a regulatory requirement.
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)];
We can not forget the product related statutory requirements.Change that to product related regulatory requirements.
NOTE 2 Statutory and regulatory requirements can be expressed as legal requirements.
And, all the other requirements in the standard which are indirectly addressed.We can not forget the product related statutory requirements.
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.So the answer is no for B, yes for C?