Rule 5.2h - Site Separation - Audit Manday Calculation (IATF 16949)

[QualitySpirit]

Hello friends,

Once again I have a headache topic which should actually be clear and understood uniformly among all IATF certified auditors. But I found each CB/auditor has so much different interpretation.

The concern is about rules 5.2h site separation as quoted below.


if a portion of the site is dedicated to automotive, then the headcount from that portion can be used to determine audit time when the following conditions are met:

- all automotive manufacturing processes are physically separated from non-automotive manufacturing (e.g. separate building, permanent barrier in between auto and non- ' automotive lines/machines, etc.),
- personnel working in the automotive manufacturing process areas are completely dedicated,


Note: If automotive manufacturing processes are integrated on the manufacturing floor with nonautomotive manufacturing processes, then this requirement cannot be applied.

Example scenario:
A client has two buildings that is obviously physically separated from each other. This is called building no.1 and building no.2.

In building no.1, there are metal pressing process of an automotive product, and also the same operators and machines are used for pressing process of a nonautomotive product too. There is not any physical separation in this building. Total headcount of building no.1 is 150 persons.

In building no.2, there are metal casting process of nonautomotive product 100%. There is completely no activities related to automotive in building no.2. Total headcount of building no.2 is 5000 persons.

In this scenario: I have been told different opinions regarding 5.2h applicability to this site.

Opinion 1: In this case, rules 5.2h cannot be applied to any portion of the site. The audit manday shall be calculated from the total headcount of both buildings e.g. 150 + 5000 = 5150 persons.
The reason of this opinion is that
1) as rule requires that "a portion of the site is dedicated to automotive" in this site we can not find such portion, building no.1 is a mixed area of automotive and nonautomotive and thus not a portion dedicated to automotive" .
2) for the requirement that all automotive manufacturing processes are physically separated from non-automotive manufacturing, although building no.1 and building no.2 are physically separated to each other. As a result all automotive manufacturing processes are physically separated from non-automotive manufacturing in building no.2 e.g. non automotive metal casting. However the automotive manufacturing processes are not physically separated from non-automotive manufacturing in building no.1 itself e.g. nonautomotive pressing. Therefore rule 5.2h definitely cannot be applied to this site and the whole headcounts in both building must be included.

Opinion 2: In this case, rules 5.2h can be applied to separate building no.1 and building no.2. The waiver must be requested. The audit manday shall be calculated from the total headcount of building no.1 only e.g. 150 persons.
The reason of this opinion is that
1) Since all automotive pressing manufacturing processes are physically separated from nonautomotive metal casting processes in building no.2. We can apply rule 5.2h here.
2) For the inside building no.1 where there is a mixed automotive/nonautomotive manufacturing processes we will not apply rule 5.2h here. All headcounts within building no.1 must be included but we can exclude headcounts within building no.2.
As the conclusion, waiver must be requested to separate building no.1 and building no.2. And headcounts of building no.1 only will be used for manday calculation.

Opinion 3: In this case, you don't even have to request for a waiver. You can proceed to use headcounts of only building no.1 of 150 persons in manday calculation and ignore completely building no.2.
The reason for this opinion is that: refer to Rules FAQ no.3. IATF gives examples of a client with 20 sites of which 9 sites producing nonautomotive, and another client has two locations across the street of which one is producing nonautomotive. In such scenarios, in this situation, an application form for “portion of the site dedicated to automotive” is not required.

Could you let me know you opinion which one is the right one and acceptable at your CB?

Thank you very much.

 

[Peters]

Rather difficult question.
But in my opinion - definitely "Opinion 2".
Of course: "all support activity personnel are included in the headcount"

 

[QualitySpirit]

Thank you for your input.

Do you know if it is ok that I contact to the oversight office for judgement directly?
I know this is normally performed by a CB representative.
But in the case, CB did not ask to the oversight office directly about this and used their own internal interpretation to give me the instruction which sounds to me not a reasonable/logical interpretation.

I think it is very risky for me, if their instruction is wrong and the oversight finds it out during a witness audit.

 

[Golfman25]

Totally Stupid strikes again. 2 years ago, I was fighting to keep 2 buildings next to each other as a single facility. Now you're being told they are a single facility.

I think you have two options. First, argue that they are two separate locations - i.e.; two addresses. Since TS certs are site specific, you only want to certify the site, building 1, that does automotive work.

Second, maybe you can handle it with your scope statement. Your scope will be limited to metal pressing. Thus, the entire casting operation is beyond the scope of the audit and shouldn't be included in a man day calculation.

Thus, I would go with opinion 3. Before going to the oversight body, go higher up your CB's chain until you find someone with some sense.

 

[QualitySpirit]

Hello Golfman25, Thank you for your reply.

In my case, the two buildings are in the same address. So it can't be argued they are at two different locations. Also they belong to the same company with a single company legal registration. So it can't be argued either that they are in two different legal entities.

In my understanding, I consider opinion 3 the most risky option to take. Assuming if the building no.1 were pure automotive (no mixing with nonautomotive), then 5.2h approval by the oversight would clearly be required to separate building no. 1 and building no. 2. It would be very funny when building no.1 is a mixed auto/non-auto, then we can completely ignore to get 5.2h approval to separate building no.2.

I think the consequence if a witness auditor finds out we did not have any approved waiver and considers the case as unapproved site separation would be very disastrous.

 

[Peters]

Answer from my 3 colleagues, automotive auditors -> definitely "Opinion 2"
I know that some of our auditors contact to oversight directly, usually they know oversite personnel (for example they know witness auditors).

 

[QualitySpirit]

Hi Peters, have you ever seen the oversight waiver application form for rules 5.2h?

In the application form, it reads

1) Please list all products produced at the client's site.
Automotive products:_______________
Non-automotive products:____________

Here you would have to write in Automotive products as pressed parts for automotive and in Non-automotive products as pressed parts for nonautomotive and casting parts for nonautomotive.

2) Check applicable conditions below that apply for all process steps from incoming products to final packaging including all manufacturing processes for all automotive products:
here you have 5 check boxes
# Separate building
# Separate level (floor) of the site
# Separated on the manufacturing floor by a permanent barrier (e.g. walls)
# Dedicated employees for automotive only
# Any exceptions? Explanation is required.

- with Note: By checking these boxes the certification body is attesting the information is accurate!

I think none of the check boxes could be chosen here because as we declared in question 1) nonautomotive products also include pressed parts then there is no separated building (it is not separated from nonautomotive press, and no dedicated employees for automotive only (employees are common with nonautomotive press.)

If you choose any check boxes it is giving inaccurate information to the oversight.

How would you fill in this waiver application form if you choose the opinion 2?

 

[Peters]

have you ever seen the oversight waiver application form for rules 5.2h?

Never

As for me:
Automotive products: metal pressed parts
Non-automotive products: metal casting parts

We can't separate non-automotive pressed parts because these are in the same building. So we declare: automotive parts only in pressing process. And no automotive parts in the casting process. So we want to separate non-automotive casting process with the whole second building. We don't want to separate any pressed parts, any pressing processes because it's forbidden in this situation.

 

[QualitySpirit]

If I declared like that I am afraid that it is a false statement to the oversight because the application form requires to write "ALL" products produced at the client site. And it will appear that another nonautomotive product is intentionally not declared.

How would you answer a witness auditor if he samples this site and finds onsite that nonautomotive products produced at the site are actually pressed parts for refrigerators and casting parts for motors? While it was declared in the approved waiver that nonautomotive product is only casting parts.

 

[Peters]

Very few automotive companies don't have any nonautomotive products in production (f.e. off-road vehicles).
If you want a guarantee of no problems with the witness auditor don't split the production in this company or get acceptance of your CB office to your description of the subject in the application, or contact your oversight and decribe the problem.
Option 2 is consistent with the intent of the Rules 5.2h, but if someone treats it stiffly/rigorously then may come to strange conclusions.