J
JShell55
Hi, Forum:
I have a bit of a question this morning.
A company that I am working for has received a surveillance audit non-conformance under AS9101D for "not taking an exclusion" from certain clauses in the standard.
As far as I was always trained, scope exclusions, a.k.a "reductions in the scope of the quality system" are supposed to be voluntary, at the option of the organization, and "as applicable". I know that typically this is used to exclude 7.3 design-type activities. In either case, the exclusions are supposed to be justified by the organization.
In this case, I guess in the opinion of the auditor, we should have/could have taken a scope exclusion for some of the post-delivery clauses (7.5.1.4) of AS-9101D but did not. The clause does say "as applicable" for this section. We are not out of conformance with the customer requirements, to any extent that we are able to tell, because our agreements with the customers do not require us to do any of these activities.
There is a clause in the auditing standard that allows a registrar to reduce the scope of a client's quality system under certain circumstances:
9.6.5 The certification body shall reduce the client's scope of certification to exclude the parts not meeting
the requirements, when the client has persistently or seriously failed to meet the certification requirements for
those parts of the scope of certification. Any such reduction shall be in line with the requirements of the
standard used for certification.
I can't see where this applies to this case in any sense. I think this one applies if we are doing a variety of activities, the auditor finds out that in the back corner of our shop we are doing one that is not anywhere close to our normal scope, and the registrar is compelled to exclude these activities from our scope of certification to keep us from claiming otherwise.
But, I am hard pressed to find a single place in either the 17021 auditing standard or the AS-9101D Standard that requires a company to exclude any particular clause from its quality system, and allows an auditor to write a non-conformance because we did not exclude a clause that at the time of the audit appeared to be not applicable.
As far as I can tell, it does work the other way in that if we are required to do X, and we have a scope exclusion that says that we do not do X, the auditor can write a non conformance in the other direction, in that we have improperly taken an exclusion from a clause that was applicable to us. Example: We exclude clause 7.3, the auditor finds out that we are doing some of the activities of 7.3, and so we have improperly taken the exclusion... I can see that one pretty easily.
I do some third party auditing myself, and I have an example the other way: I did a readiness review the other day and the client company wanted to claim 7.6 as an exclusion, since they have no measuring devices on site that require calibration. I told them to clear it with the registrar but I thought the exclusion was unnecessary, because if I were auditing it, I would see that there was no requirement, and just shrug and move on. Far be it from me to tell them to either exclude it or not, it is up to them, and up to me to audit the standard and facts as I saw them.
Either way, I would never write them a non conformance because the clause says "the organization will determine the monitoring and measuring activities and measuring equipment needed", and if they determine "none" that is okay by me, and it all comes to the same. Unless, that is, I find out by inspecting a customer PO that some kind of measuring is required.
Anyway, Please, experienced forum participants, try to straighten me out this morning. No amount of caffeine is helping this make sense to me.
I have a bit of a question this morning.
A company that I am working for has received a surveillance audit non-conformance under AS9101D for "not taking an exclusion" from certain clauses in the standard.
As far as I was always trained, scope exclusions, a.k.a "reductions in the scope of the quality system" are supposed to be voluntary, at the option of the organization, and "as applicable". I know that typically this is used to exclude 7.3 design-type activities. In either case, the exclusions are supposed to be justified by the organization.
In this case, I guess in the opinion of the auditor, we should have/could have taken a scope exclusion for some of the post-delivery clauses (7.5.1.4) of AS-9101D but did not. The clause does say "as applicable" for this section. We are not out of conformance with the customer requirements, to any extent that we are able to tell, because our agreements with the customers do not require us to do any of these activities.
There is a clause in the auditing standard that allows a registrar to reduce the scope of a client's quality system under certain circumstances:
9.6.5 The certification body shall reduce the client's scope of certification to exclude the parts not meeting
the requirements, when the client has persistently or seriously failed to meet the certification requirements for
those parts of the scope of certification. Any such reduction shall be in line with the requirements of the
standard used for certification.
I can't see where this applies to this case in any sense. I think this one applies if we are doing a variety of activities, the auditor finds out that in the back corner of our shop we are doing one that is not anywhere close to our normal scope, and the registrar is compelled to exclude these activities from our scope of certification to keep us from claiming otherwise.
But, I am hard pressed to find a single place in either the 17021 auditing standard or the AS-9101D Standard that requires a company to exclude any particular clause from its quality system, and allows an auditor to write a non-conformance because we did not exclude a clause that at the time of the audit appeared to be not applicable.
As far as I can tell, it does work the other way in that if we are required to do X, and we have a scope exclusion that says that we do not do X, the auditor can write a non conformance in the other direction, in that we have improperly taken an exclusion from a clause that was applicable to us. Example: We exclude clause 7.3, the auditor finds out that we are doing some of the activities of 7.3, and so we have improperly taken the exclusion... I can see that one pretty easily.
I do some third party auditing myself, and I have an example the other way: I did a readiness review the other day and the client company wanted to claim 7.6 as an exclusion, since they have no measuring devices on site that require calibration. I told them to clear it with the registrar but I thought the exclusion was unnecessary, because if I were auditing it, I would see that there was no requirement, and just shrug and move on. Far be it from me to tell them to either exclude it or not, it is up to them, and up to me to audit the standard and facts as I saw them.
Either way, I would never write them a non conformance because the clause says "the organization will determine the monitoring and measuring activities and measuring equipment needed", and if they determine "none" that is okay by me, and it all comes to the same. Unless, that is, I find out by inspecting a customer PO that some kind of measuring is required.
Anyway, Please, experienced forum participants, try to straighten me out this morning. No amount of caffeine is helping this make sense to me.
