TS 16949 External Lab for Raw Material Certs for PPAPs

[Jim Wynne]

Jim,

I think our comments may be missing each other. I am not suggesting expensive requirements. An organization does not have to use an outside lab, unless the customer specifies it, or they do not have capability. I agreed the auditor was incorrect in that view.

But, when it comes to automotive, the TS rules and requirements apply. TS requires a supplier to be certified to ISO at a minimum, AND compliant to TS. One TS requirement is to have a lab scope document detailing their lab capabilities, ...to be compliant to TS, and because PPAP will require it. It is not expensive to make a lab scope document.

Further, an ISO certified supplier to automotive is required to meet the customer's product approval process. Assuming that is AIAG PPAP, one of the required documents is the lab scope document. The auditor is correct in that part.

2.2.12 of the 4th edition PPAP manual, in part: Inspection and testing for PPAP shall be performed by a qualified laboratory as defined by customer requirements (e.g., an accredited laboratory). The qualified laboratory (internal or external to the organization) shall have a laboratory scope and documentation showing that the laboratory is qualified for the type of measurements or tests conducted.

My emphasis. There is no requirement for suppliers to be compliant with TS 16949. There is a requirement for the organization to develop suppliers with a goal of compliance, and there is considerable leeway as to how and when this takes place.

Note the bit above about "as defined by customer requirements." What if there are no customer requirements? What if the organization claims approval by merit of approved PPAP submissions? How would the organization go about "...showing that the laboratory is qualified..."? Failure to include that in PPAP submissions should also be a nonconformity, but nowhere is it defined beyond that one vague statement.

The whole set of requirements for material test reports is vague. I already mentioned the fact that the PPAP manual requires the organization to do the testing, a requirement that's never been enforced as far as I know. The fact is that in cases of metalworking--machining, stamping, etc.--test data from a mill or distributor has historically been considered acceptable, and I have never heard of an instance where an auditor asked for a scope document from a raw material supplier.

 

[Helmut Jilling]

The steel mill is supposed to do a PPAP? Right, they won't even take the call from us peons. Let alone do a bunch of paperwork.

1. I don't make the rules, I was just reporting the requirement.

2. That would be strange, because most mills I have any interaction with are already certified.

3. Whenever, there is a PPAP issue, the default is to discuss with your customer, work out a solution that meets their satisfaction, and get it in writing. Most auditors will accept that.

 

[Jim Wynne]

1. I don't make the rules, I was just reporting the requirement.

2. That would be strange, because most mills I have any interaction with are already certified.

3. Whenever, there is a PPAP issue, the default is to discuss with your customer, work out a solution that meets their satisfaction, and get it in writing. Most auditors will accept that.

The PPAP requirements for material test reports are fraught with ambiguity. This is a well-known fact. My guess is that it would be possible to find nonconformity in of one kind or another in 90% of all PPAP MTRs that have ever been submitted and approved since the beginning of time.

As an auditor you have to be pragmatic and understand where the value to the customer lies in identifying nonconformity. In this case, and in most cases of material test reports, customers signify their satisfaction with the documentation by signing the PSW and approving a PPAP submission.

 

[Helmut Jilling]

The PPAP requirements for material test reports are fraught with ambiguity. This is a well-known fact. My guess is that it would be possible to find nonconformity in of one kind or another in 90% of all PPAP MTRs that have ever been submitted and approved since the beginning of time.

As an auditor you have to be pragmatic and understand where the value to the customer lies in identifying nonconformity. In this case, and in most cases of material test reports, customers signify their satisfaction with the documentation by signing the PSW and approving a PPAP submission.

Agreed on all points, my friend... you could make a career on PPAPs if you chose to. Most of us try to be pragmatic and value added.

However, it should be noted, and deviation or discrepancy from requirements is required to be noted on the front of the warrant, where it has a section for "exceptions." It can not be buried on page 74, and claim the signature on the warrant approved the out-of-spec dimension buried on pg 74.

 

[Jim Wynne]

Agreed on all points, my friend... you could make a career on PPAPs if you chose to. Most of us try to be pragmatic and value added.

However, it should be noted, and deviation or discrepancy from requirements is required to be noted on the front of the warrant, where it has a section for "exceptions." It can not be buried on page 74, and claim the signature on the warrant approved the out-of-spec dimension buried on pg 74.

I agree about declaring nonconformities on the PSW. I'll take it a step further and say that those things should be cleared up before PPAP is submitted. What this discussion is about, however, is not declaration of nonconformity, but rather whether a thing related to material test reports should be considered a nonconformity at all.

 

[Helmut Jilling]

I agree about declaring nonconformities on the PSW. I'll take it a step further and say that those things should be cleared up before PPAP is submitted. What this discussion is about, however, is not declaration of nonconformity, but rather whether a thing related to material test reports should be considered a nonconformity at all.

Right...and, I have previously agreed that the statement that "material tests had to be performed by an accredited external lab" is not a TS requirement, unless the customer requires that (in some rare cases).

 

[rjkozak]

Check with your customer(s) on PPAP requirements. The PPAP manual is one of the Core Tools manuals that is a requirements manual . It says right in the PPAP manual to ask your customer. Hope this helps .