Re: Early lessons learned from the AS9100 Rev. C Transition Process
Thanks for the thorough reply. I find somewhat amusing that (apparently) some of the ICOP Scheme stakeholders don’t either understand the fundamentals of the process or don’t believe that they need to be a part of the solution to make this industry controlled other party process work. I have attached a file with an executive overview of the ICOP Scheme.
As I mentioned more than once here, the primes have “sold” the ICOP process to the Regulatory Agencies (e.g. the FAA) as a viable component of the mandatory supplier oversight expectation. FAA Order Number 8120.12A, dated 07/16/2010 and titled Production Approval Holder Use of Other-Parties to Supplement Their Supplier Control Program stipulates:
That is still true. As made it clear by the FAA order mentioned above, the PAH are the ones that have responsibility for supplier oversight. They can’t and are not absolving themselves of the responsibility for monitoring suppliers. ICOP Certification is NOT (AND WAS NEVER INTENDED TO BE) a replacement for prime’s responsibility of performing adequate supplier oversight. It is supposed to be a COMPONENT of the supplier oversight process.
If the INDUSTRY (OEM’s and regulators) reaches a conclusion that CB’s are incapable of maintaining the credibility and trustworthiness of the AS certificates they issue and maintain, then, we should NOT be part of the aero supply confidence chain.
If the primes can do anything and everything, then, and once again, there is no place for CB’s in this game. CB's are only involved in the ICOP scheme because some people believe that we can do a better job of assessing management systems against standards. But that, in itself, is not sufficient in terms of supplier assessments. Actually the poorly-written note in AS9100C 7.4.1 reminds us of that
Once again, if any CB auditor believes s/he has no impact over the registrant’s QMS, they should recuse themselves from the process. If an auditor does not believe s/he can make a professional assessment of an aerospace supplier QMS and deny certification (putting teeth) to undeserving systems, then they can’t add value to the primary stakeholders in the process.
AS9101D makes it very clear that the CB auditor MUST delve into the complaints and feedback from customers. If the customers fail to do proper supplier management, as you infer, and fail to communicate with suppliers about their failures, obviously, the CB auditor can not use a crystal ball to figure out what is going wrong. But, in those cases where the customers have provided feedback, that DATA MUST be used by the CB auditor, as part of the planning and focusing of the audit process.
I think many people must wake up and realize the new reality of the North American Automotive Industry. Some paradigms have substantially shifted in the last couple of years, including a perception of product quality, reliability and supplier relationship. The IATF has come on the record, more than once, showing dppm data from certified suppliers and showing TREMENDOUS improvement on supplier hardware quality improvement. From 400-500 to 10-15 dppm in less than a decade. TS-16949 certification is one of the attributed contributors to the performance improvement.
As I said above, if an auditor believes s/he is irrelevant in terms of supplier QMS performance, then they should find another profession. AS auditors that are interested solely in the revenue stream of the audits, but don’t want co-share responsibility for the certified QMS performance, don’t want to be co-accountable for the aero-supply chain collective improvement are not part of the solution of the ICOP process.
In my dealings with the AAQG folks, I meet a lot of people (from the OEM’s) interested in IMPROVING the process, not pointing fingers. I think we MUST all realize that it is a collective effort. Only with collective accountability at all levels, any industry-controlled oversight process, be it the IAQG ICOP or the IATF TS programs will bring about the performance improvements we all want to see.
To be honest, when I read your post, as passionate and eloquent as you are, I could only see finger pointing in the other direction. As long as auditors, CB’s, AB’s, OEM’s, training providers, regulatory bodies, etc… keep pointing fingers in all directions, but the mirror, we are not working towards a sustainable ICOP program.
Thanks for the thorough reply. I find somewhat amusing that (apparently) some of the ICOP Scheme stakeholders don’t either understand the fundamentals of the process or don’t believe that they need to be a part of the solution to make this industry controlled other party process work. I have attached a file with an executive overview of the ICOP Scheme.
However, I agree with dsanabria in that the “PRIME love the ICOP system” and it is not going away, but for a slightly different reason. Essentially, ICOP was sold to the “regulating bodies” in civil aviation and to the military as a way to control suppliers in a more cost effective fashion that would produce the same or better results and costing less.
PAHs are required by part 21 to have a quality system that ensures articles produced by suppliers conform to the approved design and are in a condition for safe operation. The use of other-party organizations to perform supplier surveillance and assessments and to provide supplier registration may be part of a PAH’s supplier control program if appropriate controls are in place as described in this order. A description of these other-party services is provided in the following paragraphs.
a. Contracted other-party supplier surveillance and assessments is a method whereby a PAH contracts with an other-party, such as a consulting firm or contract quality assurance company, for the purpose of surveilling and/or assessing a PAH’s supplier. Standards to be used by the other-party are agreed upon in advance by the PAH and the other-party.
NOTE: Contracted other-party supplier surveillance and assessments does not include persons with the same responsibilities and chain of command as those directly on the PAH’s payroll or who work exclusively to the PAH’s supplier surveillance group’s procedures. These persons are considered part of the PAH’s supplier surveillance group.
b. Other-party registration is a method whereby a supplier contracts with an appropriately
recognized or accredited other-party for the purpose of obtaining a registration. The recognized or accredited other-party organization is normally a professional society, such as the Society of Automotive Engineers, the National Aerospace and Defense Contractors Accreditation Program, the American Society of Mechanical Engineers, or an ISO 9000 registrar accredited by a group such as the ANSI-ASQ National Accreditation Board (ANAB). Registration indicates that the supplier has satisfactorily demonstrated an inspection and quality control system or manufacturing process that meets the requirements of the other-party on a continuing basis.
c. With other-party registration, the supplier is placed on the other-party’s list of registered organizations or receives a certificate of registration identifying the requirements that have been met. Periodic follow-up evaluations are conducted by the other-party to verify continued compliance with its requirements. A PAH may contract to obtain registration for its own specific functions and may also contract to obtain registration of one or more of its suppliers for specific functions. In most cases, however, a supplier initiates its own contract for registration.
a. Contracted other-party supplier surveillance and assessments is a method whereby a PAH contracts with an other-party, such as a consulting firm or contract quality assurance company, for the purpose of surveilling and/or assessing a PAH’s supplier. Standards to be used by the other-party are agreed upon in advance by the PAH and the other-party.
NOTE: Contracted other-party supplier surveillance and assessments does not include persons with the same responsibilities and chain of command as those directly on the PAH’s payroll or who work exclusively to the PAH’s supplier surveillance group’s procedures. These persons are considered part of the PAH’s supplier surveillance group.
b. Other-party registration is a method whereby a supplier contracts with an appropriately
recognized or accredited other-party for the purpose of obtaining a registration. The recognized or accredited other-party organization is normally a professional society, such as the Society of Automotive Engineers, the National Aerospace and Defense Contractors Accreditation Program, the American Society of Mechanical Engineers, or an ISO 9000 registrar accredited by a group such as the ANSI-ASQ National Accreditation Board (ANAB). Registration indicates that the supplier has satisfactorily demonstrated an inspection and quality control system or manufacturing process that meets the requirements of the other-party on a continuing basis.
c. With other-party registration, the supplier is placed on the other-party’s list of registered organizations or receives a certificate of registration identifying the requirements that have been met. Periodic follow-up evaluations are conducted by the other-party to verify continued compliance with its requirements. A PAH may contract to obtain registration for its own specific functions and may also contract to obtain registration of one or more of its suppliers for specific functions. In most cases, however, a supplier initiates its own contract for registration.
The requirement to control suppliers was always up to the primes. They could never delegate the responsibility “that it wasn’t our fault but the suppliers” from the regulations nor the contracts. Essentially this was and still is “supplier control”.
But, it is very sad to say that ICOP has no teeth. The 3rd party auditor goes into a facility once or twice a year and can be conveniently ignored through a variety of methods if they raise issues that are not acceptable to the company. You may take issue with this, but I have seen it many times over.
The Primes, or the companies that hold the contract with the supplier, do have teeth. They are buying from the company and are receiving material sometimes on a daily basis from them. They have entire QA departments set up for supplier management and processes in place to remove suppliers that are not performing. And yet, they are receiving nonconforming product from their suppliers and they can’t do anything about it?
NOTE One factor that can be used during supplier selection and evaluation is supplier quality data from objective and reliable external sources, as evaluated by the organization (e.g., information from accredited quality management system or process certification bodies, organization approvals from government authorities). Use of such data would be only one component of an organization’s supplier control process and the organization remains responsible for verifying that purchased product meets specified purchase requirements.
And then the primes indicate that the ICOP system is not working well enough! How is this possible? It is not the responsibility of the 3rd party auditor to control the supplier. It is the responsibility of the contract holder/prime to control them!!! It always has been by law as in the regulations or by contract in the case of the military. As a 3rd party auditor, I am disgusted by the number of times “the ICOP” process has come back to me and said I have missed something in my audit that was of importance to some member company of the IAQG. I do not have the time to look at every single contract and requirement of each aerospace company that the supplier deals with. I can only take a realistic sample that is true to the safety of the aerospace industry and the integrity of an audit. I am bound to miss something. However, as I said above, it is the contract holder’s responsibility to manage the supplier not mine.
So if I missed something, why did they not raise it as an issue with the supplier and make it visible to me (3rd Party Auditor) before I came to do the audit. Because, they did not look at it! They failed to manage their own suppliers and make visible a problem they had with them.
Yes, ICOP will stay around because it is cost effective for the primes. Is it effective and efficient? Well, North American Automotive manufactures believed in QS/TS. The transplants like Toyota/Honda never required it. Did QS/TS save GM? Is there an elephant, or elephants, in the Aerospace room that look like GM? The ICOP TS auditor recertification process is a mess. What did the Aerospace community model its recertification process around?
Sidney, in the end when economic times are tuff somebody has to take the heat. In the Aerospace community, I have found that it is the 3rd party auditor that is blamed for poor performance from companies and oversight systems. So here we are. Retraining the 3rd party auditors to go into companies once or twice a year and effect change. Come on, who are we kidding
In my dealings with the AAQG folks, I meet a lot of people (from the OEM’s) interested in IMPROVING the process, not pointing fingers. I think we MUST all realize that it is a collective effort. Only with collective accountability at all levels, any industry-controlled oversight process, be it the IAQG ICOP or the IATF TS programs will bring about the performance improvements we all want to see.
To be honest, when I read your post, as passionate and eloquent as you are, I could only see finger pointing in the other direction. As long as auditors, CB’s, AB’s, OEM’s, training providers, regulatory bodies, etc… keep pointing fingers in all directions, but the mirror, we are not working towards a sustainable ICOP program.
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