ISO 9001:2000 Interpretations: RFI's #16 and 17 - Clause 8.3

[D.Scott]

My 2 cents worth

If the interpretation stands it will cause all sorts of problems for our company and others like us. Here's why -

Production parts are not to be shipped to the customer until confirmation is made that they pass all performance tests required by the specification we are using. Some of these tests require days (and in a few cases weeks) to complete the test. We obtain a waiver from the customer to ship the parts prior to completion of testing. No customer in their right mind will sign a waiver if there is a chance we won't tell them of a failure.

This means our plants will be filled with customer parts waiting for results before they can be shipped. There is no room for doing this as we are a "job shop" and parts are in and out every day.

Customers require a quick turn on their parts and would never tolerate waiting for results. As it is now, we have a positive recall if there is a failure and we could certainly continue doing so but if we weren't REQUIRED to notify them .........?

This wouldn't be the first time they have created an unintended loophole.

JMHO

Dave

 

[Mike S.]

Dave,

I understand your concern, and agree with it. Seems like the customer again needs to protect themself by stating something on the PO or contract like the TS guys did: Customers shall be informed promptly in the event that nonconforming product has been shipped.

ISO 9001 once again gives users a reason to denigrate it.

 

[howste]

My first impression is the same as everyone else's above. It really sounds ridiculous, and seems to go against the spirit of another interpretation (RFI-018). It ties back to clause 5.2 requiring that customer requirements are determined and are met.

ISO 9000 does define a difference between a nonconformity and a defect, though. There can be nonconformities that don't affect the intended or specified use of the product. Perhaps they could include examples of where they think it might not be necessary to inform the customer??? :

 

[Sidney Vianna]

The implication is there in ISO9K2K; the expressed statement is included in ISO/TS-16949:2002:
8.3.3 Customer information. Customers shall be informed promptly in the event that nonconforming product has been shipped.

And here it is the AS9100 Rev. B requirement:
In addition to any contract or regulatory authority reporting requirements, the organization's system shall provide for timely reporting of delivered nonconforming product that may affect reliability or safety. Notification shall include a clear description of the nonconformity, which includes as necessary parts affected, customer and/or organization part numbers, quantity, and date(s) delivered.

 

[howste]

I just noticed that the second one (RFI-017) actually is talking about 7.2.1c which is statutory and regulatory requirements related to the product, not customer specified requirements. Does this interpretation say that a company could have broken the law, and are not required to report it? This sounds like a 5th ammendment issue...

 

[Claes Gefvenberg]

Does this interpretation say that a company could have broken the law, and are not required to report it?

Yes, as far as I can see that is exactly what it's saying. Thus, you could also cause your customer to unknowingly break the law. Brilliant piece of work from TC176, eh?


/Claes

 

[Sam]

I think the key words are "requirements specified by the customer" or as Howste pointed out "statuary requirements". But are we talking about requiirements specifically relating to the form, fit and function of the product, or are we talking about ANY requirement specified by the customer.
Some of the things that come to mind are; major finding during an internal audit, auditor not qualified, operator not trained, failure to perform R&R, etc. Do these items make a defective product. In the eyes of two auditors that I know, the answer is yes.
There may be some nonconformances that do not warrant notifying the customer. I believe this may fall in the catagory of "appropriate action".
In any event, I would notify the customer if it was determined that the performance of the product did not meet requirements.

 

[Pennington]

I would agree with all those above that on the face of it TC 176 is stupid but perhaps they are answering the question. ISO 9001:2000 does not specifically require the customer to be informed that a nonconforming product has been delivered. An auditor would therefore not 'ding' you against this clause if he found you had not informed the customer. However, there is more than one way of 'dinging' the supplier. Clause 5.2 requires top management to ensure that customer requirements are determined and are met with the aim of enhancing customer satisfaction. If top management were to ask themselves, what affects our ability to enhance customer satisfaction, I am pretty sure they would agree that telling the customer that they had shipped nonconforming product is farely important. So the company that did not inform the customer would be nonconforming against clause 5.2 rather than 8.3.

That apart, it would be contrary to the intent of ISO 9000 not to inform the customer but TC 176 were not asked what the intent was - they were asked if the standard required the customer to be informed - which is rather different.

 

[Mike S.]

ISO 9001:2000 does not specifically require the customer to be informed that a nonconforming product has been delivered. An auditor would therefore not 'ding' you against this clause if he found you had not informed the customer.
That apart, it would be contrary to the intent of ISO 9000 not to inform the customer but TC 176 were not asked what the intent was - they were asked if the standard required the customer to be informed - which is rather different.

Pennington,

Welcome aboard!

What makes the least sense to me is the fact that, based on the interpretation below, they DO require you to either inform the customer and get a concession or else not ship the product if the nonconformance is found prior to shipment. Doesn't that make the latest interpretation seem kinda silly?

ISO 9001:2000 Interpretation Reference RFI – 018
ISO/TC 176 N742
Request: ISO 9001:2000 Clause(s 8.3
A product is at the final stage of realization and a nonconformity is found on a product related requirement which had been specified by the customer (ISO 9001:2000 7.2.1 a)). The organization believes that the best solution is to accept and deliver the product as is, i.e. with a nonconforming characteristic. The customer has not issued instructions on the reporting of
nonconformities.
Does Clause 8.3 require a concession by the customer for the use, release or acceptance as is of
the product?

Interpretation: Yes
Rationale: Clause 8.3 identifies three different ways to deal with nonconforming products. Clauses 8.3 a) and c) do not apply in this case. Clause 8.3 b) specifies that the use, release or acceptance shall be authorized. In this case authorization involves a concession by the customer.
Furthermore, Clause 5.2 requires that customer requirements are determined and are met.

 

[Claes Gefvenberg]

Great first post Pennington. Welcome to the Cove

/Claes