Recruiting and Staffing Firm - Exclusions Question

[samarley]

Struggling with exemptions here are my initial thoughts; however, the more I review, the less I am convinced I am correct...looking for advice.

1.1 Clause 7.3.3 b and d: 3 Design and Development Outputs

PTI outputs of design and development cannot be provided in a form that enables verification against the design and development input and are not approved prior to release. Our design process is not appropriate for b and d of this clause. Specifically, Design and development outputs do not provide for:
b) appropriate information for purchasing, production and for service provision,
d) the characteristics the product that are essential for its safe and proper use.
1.2 Clause 7.3.5 Design and Development Verification

PTI does not perform verification in accordance with planned arrangements (see 7.3.1) to ensure the design and development outputs have met the design and development input requirements.
1.3 Clauses 7.5.1 and 7.5.2, Production and Service Provisions:

Each PTI product is developed specifically for the customer, and therefore these production and service provisions do not apply.
1.4 Clause 7.5.5, Preservation of Product:

Conformity of the PTI products cannot be impacted due to identification, handling, packaging, or storage.
1.5 Clause 7.6: Control of Monitoring and Measuring devices:

PTI does not manufacture or distribute any product therefore PTI does not utilize any measuring equipment for verification of conformity of product.
1.6 Applicability of all Other clauses of the ISO 9001:2000

All other standard apply to PTI operations, and have been addressed within the quality system.

 

[Coury Ferguson]

Re: Recruiting and Staffing Firm-Exclusions Question

I have moved this post to this Forum, since it specifically asking about exclusions regarding ISO9001:2000. I have also retitled the thread to better define your question.

If you prefer that the title be changed back to the original, just let any Moderator know and they will be happy to assist you.

 

[Wes Bucey]

Getting moderator help

Actually, clicking on the "Report post" button will send a simultaneous message to ALL moderators and the first available one will address any question, comment, or problem the person reporting may have. Since the moderators are located around the globe, at least one is always available 24/7.

 

[freelovefest]

I have dealt with similar situations in the past. Overall these look pretty good. However, if you are going to leave in 7.3 at all, you will most likely need to follow all the required elements of the clause related to design. I am not sure what you design, but certainly, you would need to be able to provide "purchasing" information. If it is a candidate profile that in essence would allow you to know what to "purchase". Any design would generally tell you what makes something safe. You can infer that element (d) is met through the design process. Unless the auditor demonstrates you have not addressed this you should be alright. The same goes with Verification. If you design anything you will need to have a review, and you can use this as your verification. If you create a profile based on what the customer's requirements are, anything that shows why this person meets those qualifications could be considered "verification".

Without seeing exactly what you design this is a tough one, but in my opinion you either have design or your don't meaning all the requirements in 7.3 can be met or you don't do design.

You almost certainly will not be able to exclude 7.5.1. This is the core of how you do what you do. Whether you are producing something or offering a service, 7.5.1 is where you tell how you do this. If you are a business of any type this will apply to you. It simply means you have a plan for your operations and you adhere to this; that everyone in the company can't just willy nilly do what they want. You should have an idea of how your service goes from a to b and that what this is about.

I hope this helps and I will be glad to answer any questions that my assessment might raise. Good luck with the project; I hope it goes well for you.

 

[Coury Ferguson]

Struggling with exemptions here are my initial thoughts; however, the more I review, the less I am convinced I am correct...looking for advice.

1.1 Clause 7.3.3 b and d: 3 Design and Development Outputs

PTI outputs of design and development cannot be provided in a form that enables verification against the design and development input and are not approved prior to release. Our design process is not appropriate for b and d of this clause. Specifically, Design and development outputs do not provide for:
b) appropriate information for purchasing, production and for service provision,
d) the characteristics the product that are essential for its safe and proper use.
1.2 Clause 7.3.5 Design and Development Verification

PTI does not perform verification in accordance with planned arrangements (see 7.3.1) to ensure the design and development outputs have met the design and development input requirements.
1.3 Clauses 7.5.1 and 7.5.2, Production and Service Provisions:

Each PTI product is developed specifically for the customer, and therefore these production and service provisions do not apply.
1.4 Clause 7.5.5, Preservation of Product:

Conformity of the PTI products cannot be impacted due to identification, handling, packaging, or storage.
1.5 Clause 7.6: Control of Monitoring and Measuring devices:

PTI does not manufacture or distribute any product therefore PTI does not utilize any measuring equipment for verification of conformity of product.
1.6 Applicability of all Other clauses of the ISO 9001:2000

All other standard apply to PTI operations, and have been addressed within the quality system.

Bear with me while I go thru a thought pattern:

Product would be the person (s) or anything that is appropriate (e.g; Resume, Contract, ect.)... the Service would be Employment... your Customers would be both Client and Candidate... the Design would be a modified resume (removing the actual candidates personal info or creating [designing] another resume for the candidate) and/or the Candidates database... measurement would be satisfaction (Client/Candidate) and output of results... the distribution would be the Candidates Resume... the impact could be inaccurate information received or submitted, by your Client, Candidate or your Office...

This is just some of my thought pattern, but it appears that there might not be some exclusions as has been suggested.

This thought pattern is going to take a little longer then I expect. I will think about it over the weekend and try and provide more insight to your question, from my point of view.

 

[samarley]

Thanks all. I think I am going with excluding 7.3, 7.5.5, 7.5.4, and 7.6 for now. Of course this is all subject to change as I learn more.

 

[freelovefest]

I am glad this was of some help. I would, however, refrain from excluding 7.5.4. There really usually isn't too much benefit to excluding it and if customer property ever shows up you have to do a rewrite to change your scope. It is a very easy requirement to meet. Just make sure you notify the customer if there is ever any issue with their property.

Sure, you are a recruiting firm, what customer property could you have? Intellectual property counts, and so does personal or personnel information. ISO13485 already makes this distinction, and the ISO9001:2008 standard is beefing this up to be more explicit. So if you have access to any proprietary information of your customers, and you certainly do, or any information of theirs relating to specific personnel, which you might at some point, then you have customer property. This is done to protect people's personal information from being improperly used or distributed. In this day and age I am sure the importance is evident.

You might be able to argue with a less astute auditor and get out of it, but most people, even more so over the next few years, are going to say it is invalid. Almost every company I have worked with has had customer property of some sort show up at one time or another, and often without prior knowlede. It just shows up.....

 

[w_grunfeld]

Thanks all. I think I am going with excluding 7.3, 7.5.5, 7.5.4, and 7.6 for now. Of course this is all subject to change as I learn more.

Samarley,
I support your decision wholeheartedly.
As a recruiting and staffing firm, you are definitely not dealing with design.
Calling the removal of some personal data from a resume "design" is far-fetched (understatement). So 7.3 is definitely not applicable.
Your product is a service plain and simple.
I don't believe in writing in a QMS procedures that are "just in case". A QMS is supposed to be reviewed anyway periodically and should anything change in the future then you will make the necessary additions.
I also second the decision to exclude 7.5.4. The information you receive from your customers is not "customer property" in the sense of 7.5.4. This is data that is just as data in any purchase order. Your customers contract you to provide them a service and the info/data they provide is nothing more than a full description of the service they require.
When someone orders from a supplier 100 screws, specifying the material and dimensions, this is not customer property!
It should be included in the PO review process.
While intelectual property may be "customer property" I don't think any company is revealing IP by describing the qualifications of a candidate to fill a position.
Your decision is just fine.

 

[AndyN]

Samarley,
I support your decision wholeheartedly.
As a recruiting and staffing firm, you are definitely not dealing with design.
Calling the removal of some personal data from a resume "design" is far-fetched (understatement). So 7.3 is definitely not applicable.
Your product is a service plain and simple.
I don't believe in writing in a QMS procedures that are "just in case". A QMS is supposed to be reviewed anyway periodically and should anything change in the future then you will make the necessary additions.
I also second the decision to exclude 7.5.4. The information you receive from your customers is not "customer property" in the sense of 7.5.4. This is data that is just as data in any purchase order. Your customers contract you to provide them a service and the info/data they provide is nothing more than a full description of the service they require.
When someone orders from a supplier 100 screws, specifying the material and dimensions, this is not customer property!
It should be included in the PO review process.
While intelectual property may be "customer property" I don't think any company is revealing IP by describing the qualifications of a candidate to fill a position.
Your decision is just fine.

Willy - thanks for your straightforward, no-nonsense, practical advice! We could do with more of it!! Just what smarley needed, IMHO - not some hypotheses of what might happen......

 

[Big Jim]

I would think that it would be appropriate to exclude 7.5.2 as you have no physical product and no "special processes".

I would also have a harder look at excluding 7.5.4 as customer property includes intellectual property. I'm not saying that you should not claim it, but that you should look harder at it. If you do claim it, you should be prepared to defend your position.