Where to save an ITAR policy?

Quality_Goblin

Involved In Discussions
Hi All,

We are implementing an ITAR policy since our company is ITAR registered. Essentially the document discusses what ITAR is and goes over any guidelines and procedures to ensure we are in full ITAR compliance. We are having a hard time deciding what section of the standard it would apply to and therefore which one of our Quality Procedures we would save this under. Does anyone have any suggestions?

We were debating between 4.0 Context of the Organization, 5.0 Leadership, 6.0 Planning

Thank you!
 

Quality_Goblin

Involved In Discussions
It isn't part of the AS9100 scheme. Instead of trying to fit it in like a square peg in a round hole, give it its own home.
I totally see what you're saying. I know ITAR isn't part of AS9100, but they do go hand in hand (from what I understand). So wouldn't it be considered part of 4.2 Understanding the Needs and expectations of Interested Parties? Some of our customers do require us to be ITAR registered because of the nature of their industry.
 

Sidney Vianna

Post Responsibly
Leader
Admin
It isn't part of the AS9100 scheme. Instead of trying to fit it in like a square peg in a round hole, give it its own home.
I don't have a copy of the current AS9101 standard, but the previous one clearly listed ITAR compliance as an item to be checked during Stage 1 Audits for AS9100.

Where to save an ITAR policy?
I would make a reference to it under Context of the organization, as it has implications about plant access and allowed personnel.
 

Quality_Goblin

Involved In Discussions
Interesting comment.

Now for a philosophical question:

If not part of the "AS9100 scheme", how many management systems should an organization have?
I just learned today that it is required under AS9101. However, how many organizations that are AS9100 certified are also certified to AS9101? Who is required to be certified to AS9101?
 

Mike S.

Happy to be Alive
Trusted Information Resource
Why are you ITAR registered? Why do you bother?

Do any of your customers require it?

Does the government require it?

Does 8.2.2 or 8.2.3 apply?
 

Quality_Goblin

Involved In Discussions
Why are you ITAR registered? Why do you bother?

Do any of your customers require it?

Does the government require it?

Does 8.2.2 or 8.2.3 apply?
Oooo! Good questions. Yes, we do have customers that require it so therefore we are registered. I never thought to look at 8.2.2/8.2.3. Based on those sections of the standard, I feel now that this policy might best belong under Operational Planning in our QMS.
 

Big Jim

Admin
AS9101 is
I just learned today that it is required under AS9101. However, how many organizations that are AS9100 certified are also certified to AS9101? Who is required to be certified to AS9101?
AS9100 not something you can get registered to. It is the instructions that your certification body auditors are required to follow when they are auditing you. So those are not requirements for you so to speak, but part of what your auditor needs to determine as part of his audit and which elements of AS9100 they apply to.

If you feel it necessary to do so, you could include them as part of your written procedures. Keep in mind that AS9100 only requires written procedures for two topics, element 8.7, control of nonconforming products, and element10.2, nonconformity and corrective action.

You can have as many more written procedures as you want, so do whatever you feel is needed to provide the structure to have an effective system.
 
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