NQA-1 Standard Applied to Services rather than Items for Nuclear Power

D

DonovanJr

#1
Our company provides Rigging and Transport services for companies that are involved in the maintenance and construction of nuclear power facilities (including the Utilities themselves). To this end we have a QA program modeled after NQA-1 and invoke certain controls based on contract requirements for the design & procurement controls detailed in the NQA-1 Standard.

Over the years we have found that even for our non-nuclear jobs we are utilizing the same regulatory standards (AISI Steel Construction Manual, ASME B30 Standards etc.), Procurement and Product trace ability requirements identified as required in NQA-1 Sub-part 2.15 to control our designs and procurement activities.

Unfortunately our QA program is written specifically to define procedures to be used when a job is required to be NQA-1 Compliant (i.e. using the requirements of NQA-1 - Part 1) to control the job activities. Meaning special forms and additional approval processes in design activities, procurement activities and Fabrication activities. We have developed processes independent of these projects that we feel cover some of these requirements and have been performing those support activities regardless of a contract specifying NQA-1 controls.

We are working on making our QA program more all inclusive of these process and plan on pushing or eliminating the "uniqueness" of the processes & forms utilized and refer to these departmental procedures and policies, while defining in our manual how the NQA-1 requirements shall be incorporated into those procedures.

The question is since to show compliance with Part 1 we modeled our program after the NQA-1 standard and we now want to include a more global process approach to QA enforcement (similar to ISO), to what extent does compliance to Part 1 apply as we are a service company and only "handle" items designed and built by others for nuclear plants.

In Sub-Part 2.15 it specifically states: "Sub-Part 2.15 supplements the requirements of Part I and shall be used in conjunction with applicable Requirements of Part I when and to the extent specified by the organization invoking Sub-part 2.15. Half the time our contracts "invoke" us to have an NQA-1 compliant QA program and only detail any pass through inspection, testing and access rights for our procurement controls, but don't give any guidance on any other requirements of Part 1 in the contracts. (It's left up to interpretation)

Essentially we plan to maintain the same processes for a commercial project as a Nuclear project in terms of Design Control, Procurement Control, Item Control, Non-Conformance etc. and eliminate Quality Program specific procedures for these activities in lieu of departmental procedures to better streamline the support activities.

Sorry for the long rambling post, but looking for insight into what would need to be considered from Part 1 to support an NQA-1 acceptable QA program to our Customers requireing by Contract NQA-1 programs.
 
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Steve Prevette

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#3
I am reasonably familiar with NQA-1, both services and components. Yes, I've seen sub contractors get into issues with having two different levels of QA requirements depending on what the job is. To a certain extent, there are benefits to just going with NQA-1 for all work, but potentially this could add expense where ISO would be "sufficient". A 'graded approach' can be used, but it needs to be very transparent as to what standard you are following.

In my experience, when I've seen a group not following NQA-1 requirements, they likely weren't following ISO either.

Must admit, I don't really understand what is the question you are asking . . .
 
N

Norm Moreau

#4
Been a while since I've been on this site, so my apologies if you've already gotten the answer you were looking for. Many of the companies I have worked with have NQA-1 programs that have integrated ISO 9001 into their program and reverse. What you might want to review is NQA-1-2012, Part IV, 4.1.1 Guidance to Modification of an ISO 9001:2008, Quality Management Systems Standard for Compliance With NQA-1–2008, Part I With the NQA-1a–2009 Addenda. I will also note that the 2017 edition will probably have a comparison to ISO 9001:2015.
 
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