Upon reviewing and auditing the quality manual that was written by our consultant against clause 4.3, I noticed something that looks to me like a nonconformity. Hoping to get second opinions on this.
Here's the entry in the quality manual:
2.1 Scope – [organization] provides precision sheet metal and machined components to the aerospace and defense industries. All work is performed in accordance with customer designs, specifications, and requirements. This quality management system applies to aerospace and defense work that requires compliance with AS9100 and customer-specific standards.
2.1.1 Commercial and non-aerospace or defense work are outside of the scope of this AS9100 quality management system. These activities are managed through separate commercial controls that ensure conformity to applicable customer requirements without imposing the additional regulatory or documentation requirements of the aerospace quality management system. The use of color-coded travelers ensure that personnel can clearly differentiate aerospace work from commercial work throughout all stages of production.
(notice how there are no clause exclusions)
2.2 Policy / Mission Statement – [organization] is committed to [...]
2.3 The success and reputation of the company may be measured by the high standing of its customers. A consistent approach of continuous self-appraisal and attention to detail has ensured the expansion of its customer base.
2.4 The company has implemented a quality management system to demonstrate its ability to provide a consistent service that meets customer and applicable statutory and regulatory requirements. This enables the company to address and achieve customer satisfaction through the effective application of the system, including processes for continual improvement and the prevention of nonconformity.
(then the clause exclusion is found 2 sections later)
101. 3 Reduction in Scope
3.1 All elements of the ISO9001:2015 and AS9100D Standards apply to [organization], with the exception of 8.3 Product Design. Since the organization does not provide design or product development services, this exclusion does not affect the organization’s ability, or responsibility to provide products and/or services that meet customer and applicable statutory and regulatory requirements.
The internal audit finding:
The scope statement found in section 2.1 of the quality manual does not address exclusion of 8.3 directly.
This is a nonconformity against the following requirement:
"4.3 - The scope shall state the types of products and services covered, and provide justification for any requirement of this International Standard that the organization determines is not applicable to the scope of its quality management system."
Although justification and exclusions are provided in Section 3.1 of the quality manual, it is not a part of the scope statement, and therefore violates clause 4.3.
Would like to know if there is something I'm missing here, any advice is appreciated
Here's the entry in the quality manual:
2.1 Scope – [organization] provides precision sheet metal and machined components to the aerospace and defense industries. All work is performed in accordance with customer designs, specifications, and requirements. This quality management system applies to aerospace and defense work that requires compliance with AS9100 and customer-specific standards.
2.1.1 Commercial and non-aerospace or defense work are outside of the scope of this AS9100 quality management system. These activities are managed through separate commercial controls that ensure conformity to applicable customer requirements without imposing the additional regulatory or documentation requirements of the aerospace quality management system. The use of color-coded travelers ensure that personnel can clearly differentiate aerospace work from commercial work throughout all stages of production.
(notice how there are no clause exclusions)
2.2 Policy / Mission Statement – [organization] is committed to [...]
2.3 The success and reputation of the company may be measured by the high standing of its customers. A consistent approach of continuous self-appraisal and attention to detail has ensured the expansion of its customer base.
2.4 The company has implemented a quality management system to demonstrate its ability to provide a consistent service that meets customer and applicable statutory and regulatory requirements. This enables the company to address and achieve customer satisfaction through the effective application of the system, including processes for continual improvement and the prevention of nonconformity.
(then the clause exclusion is found 2 sections later)
101. 3 Reduction in Scope
3.1 All elements of the ISO9001:2015 and AS9100D Standards apply to [organization], with the exception of 8.3 Product Design. Since the organization does not provide design or product development services, this exclusion does not affect the organization’s ability, or responsibility to provide products and/or services that meet customer and applicable statutory and regulatory requirements.
The internal audit finding:
The scope statement found in section 2.1 of the quality manual does not address exclusion of 8.3 directly.
This is a nonconformity against the following requirement:
"4.3 - The scope shall state the types of products and services covered, and provide justification for any requirement of this International Standard that the organization determines is not applicable to the scope of its quality management system."
Although justification and exclusions are provided in Section 3.1 of the quality manual, it is not a part of the scope statement, and therefore violates clause 4.3.
Would like to know if there is something I'm missing here, any advice is appreciated