New QS-9000 Sanctioned Interpretations - 1 July 2001


Randy Stewart

The audit can be done by any of the subcontractor's 2nd tier customers (who meet the approval criteria).

I agree Dave, tried that option. Since we are a "wholly owned subsidiary" of our customer (in this case), guess who the responsibility falls on!

I am looking for a waiver from the customer/parent company but at this time no one wants to take the responsibility of signing it. I have told our buyer that we are in jeopardy of receiving a major if this isn't cleared up. When I hear anything I'll let you know.



I think I would question the independence of the auditor for you to do a 2nd party audit on an associate company. It almost screams of conflict of intrest in that both parties have a stake (other than the normal auditor/auditee relationship) in the outcome of the audit. I certainly agree that you could do a readiness audit, but I wouldn't think your end user would accept a recommendation for approval.

It seems to me that would be equivilent to me doing 2nd party certifications for each of our 9 other plants. Somehow, that just doesn't seem right.

Of course that is just my opinion and if you are allowed, all the more power to you.


John Swartz

Is my interpretation correct?

After reading this thread and a number of others relating to this subject, I still don't get the warm fuzzies regarding my interpretation.

As a TE supplier (we supply systems: conveyors, paint systems, environmental, etc.) I don't think that we fall into the category of providing, "a) production materials, b) production or service parts, or c) ....other finishing services, directly to Chrysler..."

We don't supply production materials (as defined), nor production or service parts (as defined), nor any of the identified services. Therefore, I take the stand that we are not required to perform Subcontractor Development (QS9000TE) [TE says suppliers must comply with QS9000 but change QS9000 to QS9000TE].

My registrar has not returned any of my calls or e-mails (I've been trying for only a few days). So I offer myself to the gods of these forums for a little sage advice.



Quite Involved in Discussions
I either posted in the wrong place or it don't go thru.

My manager wants to submit to our OEM customers that we will PPAP subcontractor parts ourselves if they are supplied by non QS9000 subcontractors who have no intent on becoming QS9000.

1. what do you think an OEM's response to this would be?
2. what do you think a 3rd party auditor's response would be?


The requirement for subcontractor development is one that, at first blush seems to be an extremely burdensome task that might serve to eliminate some of our supplier base because of the language in, stating that (we) shall perform subcontractor development with the goal of subcontractor compliance to Section One of QS-9000 as their fundamental quality system. The language in the first note that follows this clause further states that acceptance of ISO 9001 or 9002 registration is not intended to limit more specific supplier / subcontractor quality system development.

The weight of this requirement both on our supplier base and internally because of the impacts on staff to track and execute and conduct on-site audits and the cost of these activities would be very high.

Now, there is an additional guidance of subcontractor development in Appendix I, Additional QS-9000 Registration Requirements, paragraph 4, page 112 of the Quality System Requirements, QS-9000, Third Edition. It offers that when small subcontractors do not have adequate resources to develop a system according to QS-9000, the supplier, may waive certain specified QS-9000 sub-elements of their subcontractor’s effort / requirement. To wit, we as the supplier to Tier One, have the right to relax the requirements. It specifically states in the last sentence of that paragraph that a simpler approach could be used for the smaller subcontractors.

To that end, I have developed a set of Supplier Quality Guidelines, for use with our Supplier Development Program. These guidelines are formalized into a handbook with examples of paperwork that is used in our own program for our supplier’s to use as examples to integrate into their own programs. It embraces elements 4.7, 4.8, 4.9, 4.10, 4.11, 4.12 and 4.13 of ISO-9002 without many of the requirements for extensive documentation.

When I submitted this idea to the Manager and Lead Auditor at our registrar and argued my case for the “simpler system” that embraces the international standard, there was agreement that it would meet the requirement(s) of QS-9000 in spirit.


Subcontractor Development

Welcome to the Cove Hank! Post like yours is what the Cove is all about. :bigwave:

The Sanctioned Interpretations do NOT negate the Appendix I stuff! Your idea of setting up a set of rules for those who you will apply note 4 to is good idea. It shows that you are not arbitrarily dismissing stuff. You have thought about it and created a plan. It also gives your subcontractor an idea of what you will be requiring. I would suggest (and it is only a suggest from the standpoint of giving you and others something to think about) not having all the requirements tied down. By using your plan as the base, you can modify it for each subcontractor, as their circumstances dictate.

Once again…thanks for the post!


How about tool suppliers? Do they have to have at a minimum a documented quality manunal? or because it is not the actual part, they do not have to comply?


Subcontractor Development

Whether or not a tooling supplier is covered under sub-contractor development or not is an issue that is sure to get a lot of differing opinions. Considering the requirement within § to have a system to track and follow-up on tooling related activities if gage design, fabrication and full dimensional inspection if those activities are contracted out, I personally want to know that they have a quality system of sorts. It is important that they control what type of product they purchase, can control anything that my organization send there, that they have documented systems to provide for any required traceability and documentation we might need in return and have the ability to provide statistical data and a design record, if applicable, on new tooling. Any supplier that may get from $10,000 to $100,000 of my organization’s money for a product that we stake our product quality and hence reputation on, is worth the effort to make sure that they are with the program. It is also worth noting that if there are situations where there is a shared cost of tooling with one of the big three, you might have to provide a letter of compliance with certain requirements in order to get the money from your customer.


QMI in its automotive newsletter write about intrepretations
The first step to unsrestanding this requiriment i to read section of third edition os QS9000, including de defintion of a subcontractor on page 113 and apendix 1.4.
To meet the requiriment the subcontractor must become registrered to an ISO based system, excluding ISO 9003, plus and specific requiriment of customer. An assessment to QS9000 section 1, or ISO/TS 16949 by OEM customer, OEM approved second party or an accredited thrid party registrar will be the only alternative.
If a tier 1 supplier decides to conduct a second party audti to therir subcontractor, approval from each OEM customer is required. A record of the customer approval and audit results will be made available.
Top Bottom