ISO 9001:2000 Clause 7.6 - Chemical company? Controls are Visual Observations

[Trolle]

7.6 for a chemical company?

I’m busy setting up a QMS (9001) for a very minute company. Mainly they trade and distribute chemicals but there is some mixing and diluting activities going on. The only type of “controls” they do is visual observation.

Now, my question to you learned gents and ladies is this: Can they do without clause 7.6? After all they have been in business for some years and complaints have been few if any.

How would you guys argue in such a case?

Cheers!

 

[Claes Gefvenberg]

Mainly they trade and distribute chemicals but there is some mixing and diluting activities going on. The only type of “controls” they do is visual observation.

Hej Trolle,

As long as you use no measuring equipment there should be no need for 7.6. Just one question: When you mix and dilute your chemicals, how do you know that you get it right? See 7.2.1c.

/Claes

 

[Trolle]

Well what happens is basically this. They receive, from their supplier ready made mixes in containers that they fill up mostly with water but on occasion, yes also with other chemicals.

This they have done fore years without customer complaints, (almost). Now I’d like to see tests being done here but I don’t think the manager will concur. Its been working fine so far has it not? And why change a working formula just for the sake of change? The function of the product is validated. They do visual control. Such controls are not subject to 7.6.

Although I’m not altogether sure I want to buy this line of thought and I suspect nor will the registrar. However the manager is the boss. I’d much appreciate any good arguments that would serve him.

Cheers!

 

[David Hartman]

Well what happens is basically this. They receive, from their supplier ready made mixes in containers that they fill up mostly with water but on occasion, yes also with other chemicals.

This they have done fore years without customer complaints, (almost). Now I’d like to see tests being done here but I don’t think the manager will concur. Its been working fine so far has it not? And why change a working formula just for the sake of change? The function of the product is validated. They do visual control. Such controls are not subject to 7.6.

Although I’m not altogether sure I want to buy this line of thought and I suspect nor will the registrar. However the manager is the boss. I’d much appreciate any good arguments that would serve him.

Cheers!

Unfortunately ignorance truly is not bliss! Just because you've "almost" not had any customer complaints, does not alleviate your responsibility for ensuring that the product you provide meets customer requirements.

Additionally, when you do receive customer complaints: What actions are taken to ensure that these nonconformities never recur? Do you not address the lack of proper measuring standards at that time?

I can't even believe that visual confirmation will suffice for compliance to 8.2.4 (especially paragraph 2 "Evidence of conformity with the acceptance criteria shall be maintained." [emphasis mine] In many processes visual confirmation would be perfectly adequate, but I believe that this would be a hard sell when it comes to mixing chemicals (unless you are mixing to a color comparison chart or something similar, but even that seems iffy).

The impression that I'm getting is that your company is wanting to receive the perceived benefits of ISO certification - without expending any additional time, effort, or money to truly ensure the quality of the product. Secondarily, I would think that you would want to base your customer satisfaction measurement on something more concrete than 'we've gone for years without complaint' (in-fact I'm not sure that this would pass as meeting the requirements of 8.4a).

Please believe me that my aim here is NOT to ridicule, but to illustrate some of the perceptions that your ISO assessors may come away with.

 

[Cari Spears]

...some mixing and diluting activities going on. The only type of “controls” they do is visual observation...

Hi Trolle -

What is the visual observation? Measuring cups or something? Color?

 

[Cari Spears]

...They receive, from their supplier ready made mixes in containers that they fill up mostly with water but on occasion, yes also with other chemicals...

Continuing from above (because I haven't figured out how to insert more than one quote ). Do these containers have a "fill to here with water" line? Is that what the visual observation is?

 

[ben sortin]

A procedure is required to evaluate measurement systems even if they currently do not measure anything. Maybe they could have everbody's eyes checked once a year.

 

[Claes Gefvenberg]

Trolle, I agree with Dave here. This may not fly... Your registrar could find reason to voice pretty strong opinions about 8.2.4, 8.4b and for that matter also 7.1c, 8.2.3 and 8.2.4.

Continuing from above (because I haven't figured out how to insert more than one quote ).

Cari, All you have to do is to copy and paste the "

" tags to appropriate places to start and end quotes.

/Claes

 

[Cari Spears]

...Cari, All you have to do is to copy and paste the "

" tags to appropriate places to start and end quotes...

Thank you!

 

[Graeme]

What happens if they get the mixing or dilution wrong? Would it be SAFE? Would it meet customer requirements? I guess if it doesn't matter if they get it wrong, then everything is OK. (But I hope I don't live downwind or within the "BOOM" radius!)

Surely the suppliers and/or customers have some sort of requirements. (concentration? pH? % dissolved solids? conductivity? color? mass? specific gravity? salinity?) Those are just a few that come to mind instantly. There are measuring instruments available for all of them. All of the measuring instruments can and should be calibrated.

As well as the customers, other interested parties include the friendly folks at Occupational Ssafety & Health, Environmental Protection and equivalent local agencies. (Which reminds me, is this client integrating ISO 14000 into the 9000 system?)