Sanity Check - Audit of Distribution Centers required by New Registrar

Dan M

Involved In Discussions
#1
We've been registered to 9001 since 1998. We are switching to a new registrar and this new registrar says they will need to include all 10 of our non-manufacturing sites (distribution centers) in the sampling plan. This is unprecedented for us. Our prior registrar never required this; traditionally we've only had our 6 manufacturing plants in the scope of our audit and listed on the ISO cert. Was our prior registrar in error to not require that our 10 distribution centers also be included in the scope? Is our new registrar being overly prescriptive?
 
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Phiobi

#2
Thats a tough one - who is right and who is wrong?!? I guess if you supply your scope of approval we could take a guess?
 

Big Jim

Trusted Information Resource
#3
You get to choose which sites are in your scope of registration, not the registrar. Talk to them, and if they will not comply, find another registrar.

There could be another factor here IF you include all the sites in your registration, and that is if you are then classified as a CAMPUS structure or a MULTI-SITE structure. In a campus structure, all sites need to be audited at least once a year. In a multi-site, sampling is allowed so that headquarters is audited at least annually and the other sites sampled.

Campus is where the individual sites cannot function on its own and multi-site is where the individual sites do stand on their own.
 

Dan M

Involved In Discussions
#4
We did choose to include our 6 manufacturing plants in a multi-site registration, many years ago. Some background: we manufacture chemical products and some of those products are shipped directly to the customer and some are transported to one of our distribution warehouses. The argument is that because the distribution warehouses can impact the customer thus it can't be excluded from the scope. Apparently ISO 9001:1994 allowed exclusions but ISO 9001:2000 does not. The distribution warehouse is acting as a remote supporting location. Similar to if we had a remote design centre we would not be able to exclude product design.
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#5
Apparently ISO 9001:1994 allowed exclusions but ISO 9001:2000 does not.
Not really.
The distribution warehouse is acting as a remote supporting location. Similar to if we had a remote design centre we would not be able to exclude product design.
The language you are using here is reminiscent of the TS16949 Automotive Scheme, but the IATF rules don't apply to ISO 9001 certification programs.

ISO 17021 CLEARLY stipulates that the registrant (NOT THE registrar) decides WHICH sites would be covered under the scope of certification. Obviously, the scope of certification has to be truthful and not mislead anyone. That's why precise definition of the scope of certification and clear identification of the sites covered under the certificate are required in the certification documents.

Without knowing the registrar's side of the story, it seems to me that they are unilaterally trying to increase the size of the sample, which in turn would mean more audit day$ for them. I am not $ure why....
 

Randy

Super Moderator
#6
Sidney is correct about 17021, you guys are the determining factor, but there is one really, really big provision to consider....

Do you list "warehousing" "storage" or "distribution" in the certificate scope?

If you do, have fun;)

Oh yeah, 7.5.5...Preservation of Product especially if you tie your centers into how you make it happen.
 

Dan M

Involved In Discussions
#7
Our scope currently has the manufacture and distribution of blah blah blah...

When I asked our registrar if I remove the word distribution would that then negate the need to audit our warehouse he said no I don't think that would make any difference.

I think it's time to get myself a copy of ISO 17021
 
#8
We've been registered to 9001 since 1998. We are switching to a new registrar and this new registrar says they will need to include all 10 of our non-manufacturing sites (distribution centers) in the sampling plan. This is unprecedented for us. Our prior registrar never required this; traditionally we've only had our 6 manufacturing plants in the scope of our audit and listed on the ISO cert. Was our prior registrar in error to not require that our 10 distribution centers also be included in the scope? Is our new registrar being overly prescriptive?
It seems to me that's it's a case of your previous Registrar being 'asleep at the wheel', if you had distribution in your scope when under their certificate!

It's not entirely appropriate to visit all dist. sites - or manufacturing for that matter - under a 'common' QMS with HQ oversight (if that's what you really have). I'm guessing that either it wasn't clear to them what you had, or that both of them are not giving you the service you really need...
 

Big Jim

Trusted Information Resource
#9
Not really. The language you are using here is reminiscent of the TS16949 Automotive Scheme, but the IATF rules don't apply to ISO 9001 certification programs.

ISO 17021 CLEARLY stipulates that the registrant (NOT THE registrar) decides WHICH sites would be covered under the scope of certification. Obviously, the scope of certification has to be truthful and not mislead anyone. That's why precise definition of the scope of certification and clear identification of the sites covered under the certificate are required in the certification documents.

Without knowing the registrar's side of the story, it seems to me that they are unilaterally trying to increase the size of the sample, which in turn would mean more audit day$ for them. I am not $ure why....
LOL

You $ure made it clear enough $
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#10
It seems to me that's it's a case of your previous Registrar being 'asleep at the wheel', if you had distribution in your scope when under their certificate!...
A manufacturing/blending site also does distribution of their products. Further if I have manufacturing in my scope of certification, that does not mean that all manufacturing sites have to be under the scope of certification.

I repeat that it is up to the organization to decide which sites they want under the coverage of the certificate. The registrar can not force them to include sites in the scope of certification if the registrant does not want that. That is why ISO 17021 requires the certification documents to list the locations that are covered. A curious and knowledgeable customer might ask the certified supplier why not all sites are listed, which could make for an uncomfortable conversation.
 
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