As I remember it, Element 4.19 and 4.19.1 (of QS) had nothing to do with "producing service parts" and was, specifically, related to your "servicing contract" with the customer (sorry, I'm just too lazy to run up to our library to look at the QS-9000 manual to review the verbage). To me "Service parts" fall under one of the production elements.
Hope that helps,
Bill