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  New QS Interpretations 1 July 2001 (Pt 1)

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Author Topic:   New QS Interpretations 1 July 2001 (Pt 1)
ml retcher
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posted 19 June 2001 01:25 PM     Click Here to See the Profile for ml retcher   Click Here to Email ml retcher     Edit/Delete Message   Reply w/Quote
Effective July 1, 2001 one of the new interpretations added is:

4.6 - Purchasing
C9 - Supplier Development (4.6.2.1)  (07/01/01)

"goal of subcontractor compliance" requires subcontractors to achieve compliance within a defined period not to exceed 18 months from the effective date of this sanctioned interpretation. Minimum subcontractor compliance shall be certification by an accredited certification body to a current version of ISO 9000 Quality Management Series of Standards, excluding ISO 9003: plus any requirements specified by the customer.

NOTE: The second note under 4.6.2.1 referencing "priortization" does not negate this requirement.
-------------------------------------
The note in the QSR states:
The "prioritization" of subcontractors for development is dependent upon the needs of the subcontractor relative to the requirements of QS-9000 and the importance of the product or service they supply.
-------------

HELP! I have several mom and pop shops that supply me with great product, no quality issues but are not big enough to spend the money on being certified. Any suggestions or comments would help me with them?

+++++++++++++++++++++++
Editor's note: I added BOLD and colour for emphasis.

[This message has been edited by Marc Smith (edited 20 June 2001).]

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Jim Biz
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posted 19 June 2001 02:52 PM     Click Here to See the Profile for Jim Biz   Click Here to Email Jim Biz     Edit/Delete Message   Reply w/Quote
Does it say "achieve certification" or achieve "compliance"? I'm not in favor of compliance self-declaration - but in some of these cases you might be able to "help them along" with a minimum documentation structure.... IMHO it may be an acceptable way to extend the 18 month period until something else "can" be done.

Regards
Jim

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DICKIE
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posted 19 June 2001 02:58 PM     Click Here to See the Profile for DICKIE   Click Here to Email DICKIE     Edit/Delete Message   Reply w/Quote
I have the same problem with subcontractors, most are too small to afford registration. Does this apply to all vendors (pens,paper,trash removal, etc) or just vendors performing work on customer parts? I don't know yet how we are going to deal with this.

Greg

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Al Dyer
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posted 19 June 2001 06:00 PM     Click Here to See the Profile for Al Dyer   Click Here to Email Al Dyer     Edit/Delete Message   Reply w/Quote
Things are going to get very interesting with this requirement. Some possibilities:

1: Under the realm of supplier development, the customer will assist in setting up the system. The supplier already has a system in place that could be used as a model for the sub-contractor.

2: Sub-contractor bites the bullit and makes a business decision as to what level of supplier they want to be.

3: Supplier pays for or subsidizes the cost of registration of the sub-contractor.

4: The sub-contractor meets with all of their customers and gets some type of subsidy from their customer base.

5: Supplier buys the sub-contractor.

6: Big three realize they are full of crap and let their suppliers control their own company and sub-contractor base. (hahahahahah)

Good luck to all of us!

ASD...

[This message has been edited by Al Dyer (edited 19 June 2001).]

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Marc Smith
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posted 19 June 2001 07:16 PM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
quote:
Originally posted by Jim Biz:
Does it say "achieve certification" or achieve "compliance"?
Certification:

-> Minimum subcontractor compliance shall be certification by
-> an accredited certification body

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JRKH
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posted 19 June 2001 08:08 PM     Click Here to See the Profile for JRKH     Edit/Delete Message   Reply w/Quote
I don't have a copy of the standard in front of me so I may be off base but...

In the standard it gives the acceptable methods of registration. I believe one of them is ceritfication by the customer. Perhaps this is one way around this.

Also I note that the requirement is to ISO, not QS.

James

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Marc Smith
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posted 19 June 2001 08:15 PM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
I have worked with companies as small as 8 people. Investment shouldn't be more than US$10K max.

They have my empathy, but.... If they want 'big three' business (no matter where down the food chain they are) they'll pay the money and go through registration.

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Roger Eastin
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posted 20 June 2001 07:58 AM     Click Here to See the Profile for Roger Eastin   Click Here to Email Roger Eastin     Edit/Delete Message   Reply w/Quote
I know that the interpretations do not say anything about where this requirement stops on the food chain, but do you see this targeting mainly tier 2 suppliers?

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tomvehoski
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posted 20 June 2001 08:45 AM     Click Here to See the Profile for tomvehoski   Click Here to Email tomvehoski     Edit/Delete Message   Reply w/Quote
I would think that this would affect any subcontractor that is selling directly to a QS-9000 certified company. I would expect it to be much like what happened with the ISO Guide 25 requirements - after the deadline QS companies started getting written up on surveillance audits for not having their lab/calibration subcontractors certified. This caused the QS registred company to pressure and/or drop their non-certified subcontractors.

There may be some relief with the additional registration requirements in Appendix I (Paragraph 4, Page 112) of QS-9000. This paragraph states that some elements of QS-9000 may be waived by the supplier for a small company that does not have adequate resources. This seems to conflict with the new interpretation. Also, how small is too small?

We have called several registrars we deal with to determine what their interpretations are. So far, nobody was aware of the changes yet.

Tom

[This message has been edited by tomvehoski (edited 20 June 2001).]

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Laura M
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posted 20 June 2001 09:02 AM     Click Here to See the Profile for Laura M   Click Here to Email Laura M     Edit/Delete Message   Reply w/Quote
quote:
Originally posted by Roger Eastin:
I know that the interpretations do not say anything about where this requirement stops on the food chain, but do you see this targeting mainly tier 2 suppliers?

I think this is the issue. I have a Tier 3 client that is being instructed to become QS9000 by the Tier 2. By the way, the automotive is about 5% or their total business, and they are not sure if they want more. Based on this interpretation, can they say - we're "good enough." Or does the last statement in the interpretation of "other requirements specified by the customer" still makes the request for QS9000 ligit?

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Marc Smith
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posted 20 June 2001 09:16 AM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
quote:
Originally posted by Roger Eastin:

I know that the interpretations do not say anything about where this requirement stops on the food chain, but do you see this targeting mainly tier 2 suppliers?


I don't know - it sounds as if it's 'all the way' down. Heck - 2nd and 3rd tiers have already been passing QS-9000 requirements down stream.

Maybe in the NEXT version of sanctioned interpretations we'll find out...

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Marc Smith
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posted 20 June 2001 09:19 AM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
quote:
Originally posted by tomvehoski:

There may be some relief with the additional registration requirements in Appendix I (Paragraph 4, Page 112) of QS-9000. This paragraph states that some elements of QS-9000 may be waived by the supplier for a small company that does not have adequate resources. This seems to conflict with the new interpretation. Also, how small is too small?


Excellent observation, Tom.

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Jim Biz
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posted 20 June 2001 09:33 AM     Click Here to See the Profile for Jim Biz   Click Here to Email Jim Biz     Edit/Delete Message   Reply w/Quote
Opps - remove double post

[This message has been edited by Jim Biz (edited 20 June 2001).]

NOTE: Folks, and FYI. You can remove a 'double post' by 'EDITing' one of them. While in the 'edit' screen you will see (in the mid- to upper- left) a check box to Delete the post.

[This message has been edited by Marc Smith (edited 20 June 2001).]

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Jim Biz
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posted 20 June 2001 09:46 AM     Click Here to See the Profile for Jim Biz   Click Here to Email Jim Biz     Edit/Delete Message   Reply w/Quote
Thanks Marc: I read the post too quickly.
(OR maybe I'll need to find out who put that nonconforming liquid in my coffee cup?)

Anyway mentioned this situation to one of our sub's last night - he's wondering about "creative merger" or "multi site certifications"

Currently we are 9002 but would like to upgrade to Qs in the future & would have the same problem with one or two of our subcontractors... example- we have a retired couple that does small part bending for us - part time working in their garage but very cost effective. Have never had a problem with their work & would be difficult to ask them to pay even 5K to be certified.

Regards
Jim

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Marc Smith
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posted 20 June 2001 10:15 AM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
-> Anyway mentioned this situation to one of our sub's last
-> night - he's wondering about "creative merger" or "multi
-> site certifications"

This sounds interesting! It may be an excellent topic for a new thread. To be honest, it really sounds like an exciting project. Including a separate company on one cert.

I'd love to head up such a project! I know I could make a case for it.

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Marc Smith
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posted 20 June 2001 10:18 AM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
quote:
Originally posted by JRKH:

In the standard it gives the acceptable methods of registration. I believe one of them is ceritfication by the customer. Perhaps this is one way around this.


Nope - the interpretation specifically says "... certification by an accredited certification body ..."


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Laura M
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posted 20 June 2001 10:21 AM     Click Here to See the Profile for Laura M   Click Here to Email Laura M     Edit/Delete Message   Reply w/Quote
In other words they are certified by your certification process? I've actually had a situation where an auditor allowed a Tier 1 "subcontractor" (the way we used the term, not the way QS uses the term) to be treated almost like a separate department. WE provided job instructions, quality requirements, gaging, etc. Basically the information that would typically be in a manufacturing department. They did the work. Their work was encompassed in our ppap documentation. They were really only a separate business as far as the IRS is concerned, but we treated them like a department. Is that what you're getting at?

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Marc Smith
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posted 20 June 2001 10:36 AM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
Yup - that sounds like it. Technically they're a separate company, right? Or are they really a division of the parent?

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ml retcher
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posted 20 June 2001 10:57 AM     Click Here to See the Profile for ml retcher   Click Here to Email ml retcher     Edit/Delete Message   Reply w/Quote
If you are talking about a joint venture?? then the second part of the interpretations being released make more sense.
*********************************************
"Joint ventures, mergers, acquisitions (effective 7/1/01)
A supplier shall notify its registrar of the following site changes: closure, transfer of ownership including merger, acquisition or joint venture. Notification shall be provided by the supplier to the registrar of record within 30 days from the time such site change was announced. Failure of the supplier to comply with the notification requirements shall result in a major non-conformity issued from the registrar of record, a major nonconformance which can only be clsoed by the registrar conducting a special on-site surveillance audit up to and including a full audit.
Within 60 days of supplier notification to the registrar of record, such registrar shall complete the following: determine the timeliness, scope and extent of surveillance audit requirements, and if necessary, conduct a special surveillance assessment, up to and including a full audit.

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David McGan
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posted 20 June 2001 12:02 PM     Click Here to See the Profile for David McGan   Click Here to Email David McGan     Edit/Delete Message   Reply w/Quote
I don't recall seeing this requirement in TS16494. So if we become registered to TS16949, will this requirement no longer apply?

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Laura M
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posted 20 June 2001 12:36 PM     Click Here to See the Profile for Laura M   Click Here to Email Laura M     Edit/Delete Message   Reply w/Quote
quote:
Originally posted by Marc Smith:
Yup - that sounds like it. Technically they're a separate company, right? Or are they really a division of the parent?


Separate company - cheap because of low overhead, cheap labor. Just do as they are told by "big company." The big company PCP/FMEA even shows "ship to ..." with the controls that the big company provides to them. Data get faxed back as approval and release before parts are used. Like I said, it was instead of the 'big company' setting up an inside department. So the little company has everything a mfg dept would typically have. Big company even provides training, I think. As far as the QS audtis of the big company - the auditor has stated that he may need to visit there, but so far the data and acceptable quality has kept him out.


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Roger Eastin
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posted 20 June 2001 03:18 PM     Click Here to See the Profile for Roger Eastin   Click Here to Email Roger Eastin     Edit/Delete Message   Reply w/Quote
David - good point, I was wondering that myself! Do Sanctioned Interpretations only apply to QS9K or do they "cross the line" and apply to TS16949 also? I suspect they only apply to QS9K, but I've seen stranger things happen!

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Marc Smith
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posted 20 June 2001 03:26 PM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
I thought all of QS applies to TS unless specifically stated otherwise. Not true?

Laura should know - or maybe Howard.

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Al Dyer
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posted 20 June 2001 05:15 PM     Click Here to See the Profile for Al Dyer   Click Here to Email Al Dyer     Edit/Delete Message   Reply w/Quote
quote:
Originally posted by Marc Smith:
I thought all of QS applies to TS unless specifically stated otherwise. Not true?

Laura should know - or maybe Howard.


Not all of QS applies to TS. TS encompasses ISO 1994, soon to be updated.

I think that the big three will revise their TS-16949 customer specific requirements to cover this new QS requirement.

If they don't do it that way they will probable have it in the 2001 version of TS when it released.

MHO

ASD...

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ml retcher
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posted 21 June 2001 07:25 AM     Click Here to See the Profile for ml retcher   Click Here to Email ml retcher     Edit/Delete Message   Reply w/Quote
I am hoping that our "Grandfathered" suppliers will be exempt from this clause. Most of the suppliers we use have been with us since 1995 when we were registered. They were all "grandfathered" in and we keep that list under document control. If that is acceptable then I will be OK with this new clause. If not the small businesses will definately feel the big three taking away their business.

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Marc Smith
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posted 21 June 2001 08:58 AM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
It doesn't sound to me like this will be an issue subject to 'grand fathering'. Sounds to me like Do It Or Else.

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Roger Eastin
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posted 21 June 2001 10:58 AM     Click Here to See the Profile for Roger Eastin   Click Here to Email Roger Eastin     Edit/Delete Message   Reply w/Quote
Does not TS16949 have its own "Sanctioned Interpretations"? I thought this because TS includes other automotive quality standards such as VDA6, etc. When QS9K changes revisions, VDA6 does not necessarily change. So I thought that QS9K could spin off its own interpretations without impacting TS, VDA6, etc.

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Al Dyer
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posted 21 June 2001 11:33 AM     Click Here to See the Profile for Al Dyer   Click Here to Email Al Dyer     Edit/Delete Message   Reply w/Quote
Roger:


I don't know of any "sanctioned interpretations" for TS but I wouldn't be surprised if they are in the works. As to the rest of your post, I agree and think thats how it will shake out. Let's wait and see.

ASD...

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tomvehoski
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posted 21 June 2001 02:32 PM     Click Here to See the Profile for tomvehoski   Click Here to Email tomvehoski     Edit/Delete Message   Reply w/Quote
I just looked back at the qs-9000.org website and they have modified the intrepretation to read as follows:

C9 Supplier Development (4.6.2.1) (07/01/01)
„Goal of subcontractor complianceš requires subcontractors to achieve compliance within a defined period of time not to exceed 18 months from the effective date of this sanctioned interpretation. Minimum subcontractor compliance shall be certification by an accredited certification body to a current version of the ISO 9000 Quality Management Series of Standards, excluding ISO 9003; plus any requirements specified by the customer. Assessment by an OEM or an OEM approved second party will be recognized as meeting subcontractor compliance requirements to 4.6.2.1.
Note: The second note under 4.6.2.1 referencing „prioritizationš does not negate this requirement.

I intrepret this to now mean that OEM approved sources are acceptable, even if they are not ISO certified.
************
Editor's note: This is the same interpretation posted in the post that started this thread so I think we're all still on the same track.

[This message has been edited by Marc Smith (edited 21 June 2001).]

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Al Dyer
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posted 21 June 2001 04:10 PM     Click Here to See the Profile for Al Dyer   Click Here to Email Al Dyer     Edit/Delete Message   Reply w/Quote
This is getting too funny, maybe we should start to expect weekly -sanctioned interpretations-!

From the "current" interpretations:

"...Assessment by an OEM or an OEM approved second party will be recognized as meeting subcontractor compliance requirements to 4.6.2.1."

*How will OEM's approve second parties. (I volunteer)

*Assessment of whom, the supplier or sub-contactor?

Maybe the interpretation team needs some help in technical writing so their views can be understood. If I put that incomplete statement in a procedure, the powers that be would kick me in the A**.

I would also like to note that this is a change, not an interpretation. That is surprizing, the big three had a chance to revise the QS9000 manual, thereby requiring everybody to by a new manual and keep the economy afloat. They are such a benevolent group.

ASD on his soap box...

[This message has been edited by Al Dyer (edited 21 June 2001).]

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Marc Smith
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posted 21 June 2001 05:03 PM     Click Here to See the Profile for Marc Smith   Click Here to Email Marc Smith     Edit/Delete Message   Reply w/Quote
Continued in:
https://elsmar.com/ubb/Forum1/HTML/000490.html

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