Re: Missing Contract Review Records on big contracts
I have performed second party audits of repair stations when I was QM of an aerospace firm. My own experience of the TOP executives at these facilities is they are intimately familiar with capability and capacity and don't make commitments they can't keep. When dealing with commercial aircraft, the cardinal sin is to have a POG (plane on ground) one minute longer than absolutely necessary. Repair stations which make time completion commitments which are broken soon find the customers few and far between. (failure to meet a time commitment can be due to many factors, but most are controllable (spare parts, adequate supplies and tools, adequate staffing with competent, efficient personnel, sufficient hangar space, etc.))
It's an interesting question. For the sake of clarity and for those who might not have immediate access to the standard, here is 7.2.2, in part:
The question at hand is, "Can a management person's signature on a contract satisfy the "shall" with regard to maintaining records of contract review?"
Maybe. If there is system documentation that states explicitly that the signature is applied only after the requirements in 7.2.2 have been met, and there have been no changes to the contract as originally tendered for which records were kept, then the signature might suffice. I'm not sure at all though, whether implied consent is a valid answer to a "shall." If it were, all kinds of doors would be open to allow weaseling out of requirements. I would be particularly suspicious if I could find no records at all of any sort of contract amendments or questioning of "the organization's" ability to meet the requirements.
If this strategy meets the letter of the standard, I don't think it meets the intent, by any stretch, especially given that top managers are, in my experience, likely to accept work first and then try to figure out how to get it done. As far as an audit NC is concerned, I would want to review the records (if there are any) more closely before determining whether 7.2.2 has been met or not.
The question at hand is, "Can a management person's signature on a contract satisfy the "shall" with regard to maintaining records of contract review?"
Maybe. If there is system documentation that states explicitly that the signature is applied only after the requirements in 7.2.2 have been met, and there have been no changes to the contract as originally tendered for which records were kept, then the signature might suffice. I'm not sure at all though, whether implied consent is a valid answer to a "shall." If it were, all kinds of doors would be open to allow weaseling out of requirements. I would be particularly suspicious if I could find no records at all of any sort of contract amendments or questioning of "the organization's" ability to meet the requirements.
If this strategy meets the letter of the standard, I don't think it meets the intent, by any stretch, especially given that top managers are, in my experience, likely to accept work first and then try to figure out how to get it done. As far as an audit NC is concerned, I would want to review the records (if there are any) more closely before determining whether 7.2.2 has been met or not.