ISO 14001 and Product Certification or Reporting Peroduct Material Content

C

Chris Harden

Hello All,

I had a general question for everyone. For those of you who are ISO 14001, 9001 or TS 16949 certified, have you been requested during audits to provide proof that you have met your customers requirements concerning material content reporting or certifying your product was compliant to the RoHS Directive? Or if you are in the auto industry that you have reported all your parts in IMDS? Do you know do auditors view failing to have this complete as a major or minor non-conformance?

Any info is appreciated.

Thanks,

Chris Harden

:thanx:
 

Wes Bucey

Prophet of Profit
I kept copies of all the material certs from producers and physical and chemical analysis reports from independent laboratories (which were ordered and/or sent to meet customer requirements) with the product file for either standard or contracted retention period. In addition, I kept material "coupons" in the file as well. It was just part of my own obsessive CYA thinking - it never occurred to me to worry whether an "auditor" would want proof. I fretted about possible SNAFU down the line so I wanted all traceability I could maintain.

If you are not contractually required to maintain a record, no auditor can say you must. A 3rd party auditor usually asks for your procedure to satisfy customer-specific requirements, then asks for the record required (if any) in your own procedure. If none required in your own procedure, then no record can be requested by auditor.
 
J

jmurph01

Chris - I just noticed this thread and wanted to add my 2cents....sorry i'm so late in replying!

On our list of "Legal and Other Environmental Requirements" we have added the customer requirements to submit information on the IMDS or their own systems on the restricted/reportable substances in our part. Since we have defined it as an "other" requirement, I would expect our auditors could audit us to ensure submission has occured. I would think it would be a minor NC not a major if one report was not filed. If we had not submitted any at all, maybe that would be a major.

also i don't think all companies are defining this as an environmental requirement. (I get this sense from the different types of people I have met in training sessions - engineers, quality, purchasing.) if they do not look at it as an environmental requirement then no NC could be issued on an ISO 14001 audit. but it deffinately is a customer requirement, so on a TS 16949 audit yes it would be an NC.
 

Sidney Vianna

Post Responsibly
Leader
Admin
Chris Harden said:
have you been requested during audits to provide proof that you have met your customers requirements concerning material content reporting or certifying your product was compliant to the RoHS Directive?
While Management System Audits are not regulatory compliance audits, both ISO 9001 and 14001 require commitment to regulatory compliance. Failure to comply with European regulatory requirements will lead an organization to be ousted from the single largest consumer market in the World. So, a minor or major non-conformity would be insignificant, compared to the consequences of being banned from selling into the EU.

The issue of enforcing the Directives is a whole other story, though.:eek:
 
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