Is this a scope statement nonconformity? (Clause 4.3)

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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
 
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Well, you're missing a sense of mixing colours. Your original post has a light yellow font on a white background for most of its content, and is consequently illegible. Would you like to edit it and choose a font colour with greater contrast to the background please?
 
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
My opinion, this is why people hate this auditing stuff. That is clearly a "nit pick" -- finding something that doesn't exist. Nowhere in the standard does it state you have to have a single "scope statement." Having a simple "Reduction in Scope" section is an adequate way to cover it, and is actually very clear. We basically do it the same way. Paragraph 1: "Scope." Paragraph 2: "Exclusions."

I would move on to something way more important. Good luck.
 
I agree with Sidney that there is nothing wrong here. That said, it does suffer from good writing standards. It is overly worded. That is it is not terse. It's painfully hard to follow. The only real issue here is that it is poorly written, not that any requirement of AS9100 / ISO 9001 has been violated.
 
Put your geographical location (address) in it somewhere.....And edit out the goofy colors
 
Well, you're missing a sense of mixing colours. Your original post has a light yellow font on a white background for most of its content, and is consequently illegible. Would you like to edit it and choose a font colour with greater contrast to the background please?
Put your geographical location (address) in it somewhere.....And edit out the goofy colors

My bad, I am using dark mode, didn't realize it would look awful. And it seems like I'm past the editing time frame, oops!


My opinion, this is why people hate this auditing stuff. That is clearly a "nit pick" -- finding something that doesn't exist. Nowhere in the standard does it state you have to have a single "scope statement." Having a simple "Reduction in Scope" section is an adequate way to cover it, and is actually very clear. We basically do it the same way. Paragraph 1: "Scope." Paragraph 2: "Exclusions."

I would move on to something way more important. Good luck.

Appreciate your response, I will move on

I agree with Sidney that there is nothing wrong here. That said, it does suffer from good writing standards. It is overly worded. That is it is not terse. It's painfully hard to follow. The only real issue here is that it is poorly written, not that any requirement of AS9100 / ISO 9001 has been violated.

If you mean the manual, it gets even harder to follow

Here's one of the worst sentences I found:

"Resource and on-time delivery requirements are monitored to ensure control of processes consistent with defined criteria and ensure consistent output, with instruction sufficient to achieve same are also taken into consideration during planning."

Anyways,

Thanks everyone for chiming in, I appreciate the advice
 
There have been some good points as to the length of the scope statement.

The issue as I see it is the scope references "exclusions", and the standard got rid of the term. "Non-Applicability" is the new phrase.
 
A "terse" scope would look something like this: "Scope: Precision sheet metal and machined components including bending, forming, milling and assembly for aerospace and military applications."
A non-applicable statement could look something like this:
[Company Name] has determined the following requirement is not applicable to the operations at their site and are documented as exclusions as per the most current revision of AS9100.

AS9100 8.3 Product Design. This element is excluded from the scope as [Company Name] produces parts according to customer drawing and specifications. [Customer Name] develops, processes, and maintains systems to support and meet customer’s design manufacturability of products.

[Company Name] has also determined that AS9100 is not applicable to commercial, non-aerospace and non-military) operations at their site.
 
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