Rights of Access per ASME/NQA-1 2000

A

atreyu915

#1
Hi guys,
Our QA manual has been written to mirror ASME/NQA-1 2000. A few of our customers require that we meet ASME/NQA-1 2000 basic requirements.
Per NQA-1 2000 Requirement 4:204
"The procurement documents shall provide for access to the supplier's and subtie supplier's facilities and records for surveillance, inspection, or audit by the purchaser, its designated representative, and others authrorized by the purchaser"
We have always "flowed" this requirement down through verbiage stated directly on our PO's to our suppliers. Top management has just had this verbiage removed from our PO's. Unannounced, no explanation given. If I have an auditor come in, how am I going to show that I'm compliant with this portion of the standard? I'm trying to sell to top mgt that this verbiage should remain on there, but I'm not 100% sure that it should. Nor am I able to round up any firepower to back up my claims.
Even though it is still in our manual/procedures, how are we conveying to the customer that we still retain these rights? :confused:
Thanks for your help
 
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Coury Ferguson

Moderator here to help
Trusted Information Resource
#2
Re: Rights of Access

Hi guys,
Our QA manual has been written to mirror ASME/NQA-1 2000. A few of our customers require that we meet ASME/NQA-1 2000 basic requirements.
Per NQA-1 2000 Requirement 4:204
"The procurement documents shall provide for access to the supplier's and subtie supplier's facilities and records for surveillance, inspection, or audit by the purchaser, its designated representative, and others authrorized by the purchaser"
We have always "flowed" this requirement down through verbiage stated directly on our PO's to our suppliers. Top management has just had this verbiage removed from our PO's. Unannounced, no explanation given.
Ask the question to your Management. If they have removed this requirement, they could be in violation of the Contract/Purchase Order.
 

Jim Wynne

Leader
Admin
#3
Re: Rights of Access

Ask the question to your Management. If they have removed this requirement, they could be in violation of the Contract/Purchase Order.
Not only that, but there must have been a reason for removing it. People don't usually mess with the boilerplate unless there's a compelling reason to do so. It could be a case of the left hand not knowing what the right is doing--whoever caused the PO language to change might not have been aware of other contractual obligations. Some kind of upper-level review is needed.
 

Coury Ferguson

Moderator here to help
Trusted Information Resource
#4
Re: Rights of Access

Not only that, but there must have been a reason for removing it. People don't usually mess with the boilerplate unless there's a compelling reason to do so. It could be a case of the left hand not knowing what the right is doing--whoever caused the PO language to change might not have been aware of other contractual obligations. Some kind of upper-level review is needed.
That is true Jim. It needs to be reviewed.

To the OP:

Are the POs reviewed by anyone other than the Purchasing Manager? Is there a second set of eyes that look at them before they are released? Maybe a quick discussion with the Management might be necessary to identify specific requirements of the Customers.
 
A

atreyu915

#5
Re: Rights of Access

That is true Jim. It needs to be reviewed.

To the OP:

Are the POs reviewed by anyone other than the Purchasing Manager? Is there a second set of eyes that look at them before they are released? Maybe a quick discussion with the Management might be necessary to identify specific requirements of the Customers.
Thanks guys for the responses. I review the POs to make sure the item being ordered is compliant to whatever customer/component it is being ordered for. Left hand not knowing what the right is doing is very much the case around here. IMHO I don't really think upper mgt is familiar enough with ASME/NQA-1:2000 to realize that "Rights of Access" is even in there.

My greatest confusion is still that. If we say in our Manual section 4 that we retain the rights to supplier facilities..., if we have removed that from the only document our supplier is provided, how then are we satisfying our OWN manual? Does that question make sense? There is a very good possibility that I'm missing something.

Again, The persons involved in removing this from the PO's most likely does not realize what NQA-1 states nor what our QA manual states. Would that scare you guys?
 

Jim Wynne

Leader
Admin
#6
Re: Rights of Access

My greatest confusion is still that. If we say in our Manual section 4 that we retain the rights to supplier facilities..., if we have removed that from the only document our supplier is provided, how then are we satisfying our OWN manual? Does that question make sense? There is a very good possibility that I'm missing something.
Your quote from the standard says that the provisions must be cited in "the procurement documents." This usually means the PO, so your own manual is probably irrelevant. If your customer's "procurement documents" specify compliance with the standard, then you have to comply with the standard--it's as simple as that.

Again, The persons involved in removing this from the PO's most likely does not realize what NQA-1 states nor what our QA manual states. Would that scare you guys?
No, it would make me feel right at home.:D As I said earlier, upper-level review is needed. You might kick that off by informing someone (the purchasing manager, perhaps) that the PO boilerplate doesn't comply with your customer's requirements.
 

Coury Ferguson

Moderator here to help
Trusted Information Resource
#7
Re: Rights of Access

Thanks guys for the responses. I review the POs to make sure the item being ordered is compliant to whatever customer/component it is being ordered for. Left hand not knowing what the right is doing is very much the case around here. IMHO I don't really think upper mgt is familiar enough with ASME/NQA-1:2000 to realize that "Rights of Access" is even in there.
Than that is one problem. Training of Management needs to be accomplished.

My greatest confusion is still that. If we say in our Manual section 4 that we retain the rights to supplier facilities..., if we have removed that from the only document our supplier is provided, how then are we satisfying our OWN manual? Does that question make sense? There is a very good possibility that I'm missing something.
The bottom line here is that irregardless (the nomenclature that some covers don't like) of what your manual states, it is a legal and binding requirement by your customer(s) Management must understand the possible implications.

Again, The persons involved in removing this from the PO's most likely does not realize what NQA-1 states nor what our QA manual states. Would that scare you guys?
I'm with Jim on this answer. It doesn't scare me a bit, only the potential ramifications that could result from not complying with the PO requirements.
 
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A

atreyu915

#9
Let me make sure I'm understanding you. Irregardless of what our internal manual states. Since our customer requires that we meet this standard (asme/nqa-1:2000) and since requirement 4.204 of that standard cites the requirements for Rights of access, then it must remain on our PO's? Where do legalities come into play?
I apologize if you have to hold my hand through this one. But i'm utterly confused. If our manual is irrelevant, then how are we displaying compliance to any of the standard? (from an auditors point of view)
If our customers PO cites the spec that states we must be meet NQA, how else besides the verbiage on OUR po's to OUR suppliers would we flow down the requirements?
As I asked earlier, if an auditor were to come in and ask "Show me how you're satisfying the requirements of 4.204" What would I say?
Sorry again if I'm making this more difficult
 

Coury Ferguson

Moderator here to help
Trusted Information Resource
#10
Let me make sure I'm understanding you. Irregardless of what our internal manual states. Since our customer requires that we meet this standard (asme/nqa-1:2000) and since requirement 4.204 of that standard cites the requirements for Rights of access, then it must remain on our PO's? Where do legalities come into play?
I apologize if you have to hold my hand through this one. But i'm utterly confused. If our manual is irrelevant, then how are we displaying compliance to any of the standard? (from an auditors point of view)
If our customers PO cites the spec that states we must be meet NQA, how else besides the verbiage on OUR po's to OUR suppliers would we flow down the requirements?
As I asked earlier, if an auditor were to come in and ask "Show me how you're satisfying the requirements of 4.204" What would I say?
Sorry again if I'm making this more difficult
The Face of the Purchase Order from your customer is the binding document.

The order of precedence is: (What I remember from Contract Law, but talk with your company's attorney, since I am not an attorney)

1. The face of the PO/Contract

2. The drawings

3. The standards/specifications

The purchasing document is the legal driver.

A. The statement as flowed down through the binding document (PO) requires this standard.

B. The standard requires that this clause be referenced on your Purchasing documents

C. The purchasing document needs to have this requirement on it.

:caution: Note: This is my opinion (based upon basic contract law from college) and is not legal guidance. Talk with your Company's Attorney.
 
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