Perhaps you are right. Although, the term "process" bears a lot of weight in the standard because of the emphasis on "The Process Approach." It would be a lot clearer if...
...they said controlled program.
I'm not sure you need KPI's for calibration. (We do at the machine shop, but that's just us. Because we let it go too many times in our distant past.)
Thanks Peter. Whenever the standard uses this phrase, it is always in connection with a few isolated requirements. I have always thought of processes as being much larger in scope than that.
They have been refining the "process approach" for a long time now. In ISO 9001:2000\AS9100 Rev. B, it was a whisper. It got a little louder in Rev. C, and more prescriptive in Rev. D, yet it's still not 'effective,' IMO.
The standard touches upon "Processes" in several places:
0.1 General, 0.2 Quality Management Principles, 0.3.1 Process Approach: General, 4.4.1 QMS and its Processes, 5.1.1 Leadership and Commitment: General, 5.3 Organizational Roles, Responsibilities and Authorities, 6.1.2 Planning: Actions to Address Risks and Opportunities, 7.1.4 Environment for the Operation of Processes, 8.1 Operational Planning and Control, 9.2.2 Internal Audit, 9.3.2 Management Review: Inputs
Where the standard fails is in 0.3.1 where they say the standard "promotes the adoption of the process approach." Why not say "system must be in conform with the process approach" in 4.4.1? Why not reference
ISO9001_2015_Guidance_on_the_Process_Approach?
Auditors will request to see where the above is addressed. What evidence will you show them you're in compliance in the above scenario?
If you have a controlled program for keeping devices calibrated or verified (IAW AS9100 7.1.5, and it can pass an (effective) internal audit, then you should be good.