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| articles:as9100d_oe_requirements-1 [2019/08/24 11:43] – rrandall | articles:as9100d_oe_requirements-1 [2023/05/14 21:40] (current) – rrandall |
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| ====== AS9100D Objective Evidence Requirements: Part 1 Documentation ====== | ====== AS9100D Objective Evidence Requirements: Part 1 Documentation ====== |
| | {{keywords>AS9100 documentation}} |
| AS 9100D is an incredibly poorly written QMS standard littered with ambiguous / vague requirements that have resulted in subjective interpretations and inconsistent implementation. This article discusses the minimum "Objective Evidence" actually required by the standard. Any interpretations beyond these minimum requirements (e.g., by an internal or external auditor) are based purely on subjective //opinion//. | <WRAP button>[[articles:as9100d_oe_requirements-2|Part 2 Records]]</WRAP> |
| | AS 9100D is an incredibly poorly written QMS standard littered with ambiguous/vague requirements that have resulted in subjective interpretations and inconsistent implementation. This article discusses the minimum "Objective Evidence" actually required by the standard. Any interpretations beyond these minimum requirements (e.g., by an internal or external auditor) are based purely on subjective //opinion//. |
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| The first confusing point to address is which documentation (e.g., procedures) are actually required by AS 9100D. | The first confusing point to address is which documentation (e.g., procedures) are actually required by AS 9100D. |
| | **15** | The organization shall maintain //**documented information**// that defines the nonconformity and corrective action management processes. | 10.2.1 | | | **15** | The organization shall maintain //**documented information**// that defines the nonconformity and corrective action management processes. | 10.2.1 | |
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| <note tip>**# 2 ** \\ For guidance on documenting "a general description of relevant interested parties", read: [[articles:context_of_the_organization|Context of the Organization... and "Interested Parties"]]</note> | <WRAP center round tip 80%>**# 2 ** \\ For guidance on documenting "a general description of relevant interested parties", read: [[articles:context_of_the_organization|Context of the Organization... and "Interested Parties"]]</WRAP> |
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| | <WRAP center round tip 80%>**# 3** \\ Guidance from ISO on crafting an acceptable QMS "scope" can be found online in the: [[https://committee.iso.org/files/live/sites/tc176sc2/files/documents/ISO%209001%20Auditing%20Practices%20Group%20docs/General/APG-Scope2015.pdf|ISO 9001 Auditing Practices Group Guidance on: "Scope of ISO 9001, Scope of Quality Management System (QMS) and Scope of Certification"]]</WRAP> |
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| | <WRAP center round important 80%>**# 3** \\ When asked "//Is it allowable for an organization to claim non-applicability with any sub-clause or sub-paragraph of 9100-series?//", the response contained in the IAQG official [[https://www.sae.org/iaqg/projects/9100-2016_clarification_table.pdf|"AS 9100:2016 Series Clarifications"]] stated: \\ //"Yes. Organizations can claim non-applicability even down to a shall statement or portions of a shall statement."// \\ \\ Also, when asked "//Is it required that any non-applicability with a requirement be documented in the scope section of the __Quality Manual__?//", the response contained in the IAQG official [[https://www.sae.org/iaqg/projects/9100-2016_clarification_table.pdf|"AS 9100:2016 Series Clarifications"]] stated: \\ //"No. It is required that any non-applicability with a clause or “shall” statement be documented information but does not have to be documented in the scope section of a __Quality Manual__."// </WRAP> |
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| <note tip>**# 3** \\ Guidance from ISO on crafting an acceptable QMS "scope" can be found online in the: [[https://committee.iso.org/files/live/sites/tc176sc2/files/documents/ISO%209001%20Auditing%20Practices%20Group%20docs/General/APG-Scope2015.pdf|ISO 9001 Auditing Practices Group Guidance on: "Scope of ISO 9001, Scope of Quality Management System (QMS) and Scope of Certification"]]</note> | <WRAP center round important 80%>**# 5** \\ When asked "//Is using the process diagram in Figure 2 from clause 0.3.2, in your quality manual for interaction between the processes sufficient?//", the response contained in the IAQG official [[https://www.sae.org/iaqg/projects/9100-2016_clarification_table.pdf|"AS 9100:2016 Series Clarifications"]] stated: \\ //No. 9100-series standards are a process-based standard with requirements to identify the organization’s QMS processes and their interaction. The diagram on page 8 of 9100-series includes the relationships of the 9100-series sections 4 through |
| | 10. This diagram is not intended to define an organization’s processes and their interaction. Additional information is available from the [[https://committee.iso.org/files/live/sites/tc176sc2/files/documents/ISO%209001%20Auditing%20Practices%20Group%20docs/Auditing%20to%20ISO%209001%202015/APG-Processes2015.pdf|ISO 9001 Auditing Practices Group website]] and [[https://www.sae.org/iaqg/projects/9100-2016changes.pdf|IAQG 9100 Key Changes Presentation]] on the topic Process Management/Approach. \\ In addition, Annex A.1 of the standard provides this statement: “The structure of clauses is intended to provide a coherent presentation of requirements, rather than a model for documenting an organization’s policies, objectives, and processes.”//</WRAP> |
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| <note important>**# 3** \\ When asked "//Is it allowable for an organization to claim non-applicability with any sub-clause or sub-paragraph of 9100-series?//", the response contained in the IAQG official [[https://www.sae.org/iaqg/projects/9100-2016_clarification_table.pdf|"AS 9100:2016 Series Clarifications"]] stated: \\ //"Yes. Organizations can claim non- applicability even down to a shall statement or portions of a shall statement."// \\ \\ Also, when asked "//Is it required that any non-applicability with a requirement be documented in the scope section of the __Quality Manual__?//", the response contained in the IAQG official [[https://www.sae.org/iaqg/projects/9100-2016_clarification_table.pdf|"AS 9100:2016 Series Clarifications"]] stated: \\ //"No. It is required that any non-applicability with a clause or “shall” statement be documented information but does not have to be documented in the scope section of a __Quality Manual__."//</note> | <WRAP center round tip 80%>**# 5** \\ //Most// AS 9100D auditors prefer to see "the sequence and interaction" of your QMS processes in "Turtle Charts" because that is how the auditor's [[https://www.sae.org/iaqg/forms/disclaimer9101fform3ul.htm|SAE AS 9101F, Form 3 "Process Effectiveness Assessment Report"]] (a.k.a. "PEAR" form) is structured. However, if using "flow charts" to document "the sequence and interaction" of your QMS processes, preference should be given to using the [[https://www.omg.org/spec/BPMN/|"Business Process Model and Notation" (BPMN™) Standard]] for flow charting your processes.</WRAP> |
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| <note important>**# 5** \\ When asked "//Is using the process diagram in Figure 2 from clause 0.3.2, in your quality manual for interaction between the processes sufficient?//", the response contained in the IAQG official [[https://www.sae.org/iaqg/projects/9100-2016_clarification_table.pdf|"AS 9100:2016 Series Clarifications"]] stated: \\ //No. 9100-series standards are a process-based standard with requirements to identify the organization’s QMS processes and their interaction. The diagram on page 8 of 9100-series includes the relationships of the 9100-series sections 4 through | <WRAP center round tip 80%>**# 2 thru 8** \\ While AS 9100 does NOT require a "Quality Manual", it is generally a good idea to do so as a "defensive measure" because: \\ 1. Addressing all of the requirements of AS 9100D in a "Quality Manual" (at a policy level) the business can argue that it has addressed the more //subjective// requirements (contained throughout AS 9100D) that do not specifically require "objective evidence", and \\ 2. Including references to the sources for the business's interpretations can immediately dismiss many //subjective// interpretations that an auditor may have. \\ \\ Also, a "Quality Manual" can improve efficiency through providing a single source addressing items 2 thru 8 from the above chart.</WRAP> |
| 10. This diagram is not intended to define an organization’s processes and their interaction. Additional information is available from the [[https://committee.iso.org/files/live/sites/tc176sc2/files/documents/ISO%209001%20Auditing%20Practices%20Group%20docs/Auditing%20to%20ISO%209001%202015/APG-Processes2015.pdf|ISO 9001 Auditing Practices Group website]] and [[https://www.sae.org/iaqg/projects/9100-2016changes.pdf|IAQG 9100 Key Changes Presentation]] on the topic Process Management/Approach. \\ In addition, Annex A.1 of the standard provides this statement: “The structure of clauses is intended to provide a coherent presentation of requirements, rather than a model for documenting an organization’s policies, objectives, and processes.”//</note> | |
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| <note tip>**# 5** \\ //Most// AS 9100D auditors prefer to see "the sequence and interaction" of your QMS processes in "Turtle Charts" because that is how the auditor's [[https://www.sae.org/iaqg/forms/disclaimer9101fform3ul.htm|SAE AS 9101F, Form 3 "Process Effectiveness Assessment Report"]] (a.k.a. "PEAR" form) is structured. However, if using "flow charts" to document "the sequence and interaction" of your QMS processes, preference should be given to using the [[https://www.omg.org/spec/BPMN/|"Business Process Model and Notation" (BPMN™) Standard]] for flow charting your processes.</note> | <WRAP center round important 80%>**# 9** \\ The IAQG official [[https://www.sae.org/iaqg/projects/9100-2016_clarification_table.pdf|"AS 9100:2016 Series Clarifications"]] states: //The 9100-series clause 7.1.5.2 was not intended to force organizations to have the register specifically include the "equipment type, unique identification, location, and the calibration or verification method, frequency, and acceptance criteria.” The organization is required to have this information for equipment listed on the calibration register but not specifically in the register.// </WRAP> |
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| <note tip>**# 2 thru 8** \\ While AS 9100 does NOT require a "Quality Manual", it is generally a good idea to do so as a "defensive measure" because: \\ 1. Addressing all of the requirements of AS 9100D in a "Quality Manual" (at a policy level) the business can argue that it has addressed the more //subjective// requirements (contained throughout AS 9100D) that do not specifically require "objective evidence", and \\ 2. Including references to the sources for the business's interpretations can immediately dismiss many //subjective// interpretations that an auditor may have. \\ \\ Also, a "Quality Manual" can improve efficiency through providing a single source addressing items 2 thru 8 from the above chart.</note> | <WRAP center round tip 80%>**# 9** \\ Consistent with the above "official" interpretation, almost no one identifies the “method” or “acceptance criteria” in their “register” (database)... unless they have a full in-house calibration laboratory. What auditors typically see is: \\ 1. the “method” identified on the calibration certificate (from the calibration/metrology lab). \\ 2. the “acceptance criteria” either identified in the calibration certificate (from the calibration/metrology lab) OR for the company to have a copy of the calibration “method” that was used (containing the acceptance criteria). \\ \\ While the company could have the instrument specifications, if those specifications can’t be matched to the actual calibration method used, then there is no way to confirm that was the actual “acceptance criteria” used in performing the calibration. </WRAP> |
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| <note important>**# 9** \\ The IAQG official [[https://www.sae.org/iaqg/projects/9100-2016_clarification_table.pdf|"AS 9100:2016 Series Clarifications"]] states: //The 9100-series clause 7.1.5.2 was not intended to force organizations to have the register specifically include the "equipment type, unique identification, location, and the calibration or verification method, frequency, and acceptance criteria.” The organization is required to have this information for equipment listed on the calibration register but not specifically in the register.// </note> | |
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| <note tip>**# 9** \\ Consistent with the above "official" interpretation, almost no one identifies the “method” or “acceptance criteria” in their “register” (database)... unless they have a full in-house calibration laboratory. What auditors typically see is: \\ 1. the “method” identified on the calibration certificate (from the calibration/metrology lab). \\ 2. the “acceptance criteria” either identified in the calibration certificate (from the calibration/metrology lab) OR for the company to have a copy of the calibration “method” that was used (containing the acceptance criteria). \\ \\ While the company could have the instrument specifications, if those specifications can’t be matched to the actual calibration method used, then there is no way to confirm that was the actual “acceptance criteria” used in performing the calibration. </note> | <WRAP center round important 80%>**# 12** \\ When asked whether clause no. 8.5.1a) of ISO 9001:2015 "availability of documented information" means "maintain documented information”, the " |
| | [[https://committee.iso.org/files/live/sites/tc176sc2/files/documents/Interpretations/ISO9001_2015_Approved_Interpretations.doc|Official ISO 9001:2015 Inerpretations from ISO TC/176/SC2]]" stated "No". And explained "//The terms “available” and “maintain” are not synonyms, and the use of “availability” was deliberate. “Available” means “able to be used or obtained, or accessible”, whereas “maintain” means “cause or enable to continue”. The “maintenance” of documented information is not explicitly required by Clause 8.5.1(a), but is addressed by other parts of ISO 9001:2015. Clause 8.5.1 (a) requires the documented information to be “available” so that it can be used, not just “maintained” (i.e. preserved). The documented information that needs to be available under Clause 8.5.1(a) is part of the quality management system documentation, and therefore has to be managed in accordance with Clause 7.5.//".</WRAP> |
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| <note important>**# 12** \\ When asked whether clause no. 8.5.1a) of ISO 9001:2015 "availability of documented information" means "maintain documented information”, the " | <WRAP center round important 80%> |
| [[https://committee.iso.org/files/live/sites/tc176sc2/files/documents/Interpretations/ISO9001_2015_Approved_Interpretations.doc|Official ISO 9001:2015 Inerpretations from ISO TC/176/SC2]]" stated "No". And explained "//The terms “available” and “maintain” are not synonyms, and the use of “availability” was deliberate. “Available” means “able to be used or obtained, or accessible”, whereas “maintain” means “cause or enable to continue”. The “maintenance” of documented information is not explicitly required by Clause 8.5.1(a), but is addressed by other parts of ISO 9001:2015. Clause 8.5.1 (a) requires the documented information to be “available” so that it can be used, not just “maintained” (i.e. preserved). The documented information that needs to be available under Clause 8.5.1(a) is part of the quality management system documentation, and therefore has to be managed in accordance with Clause 7.5.//".</note> | **# 14 & 15** \\ There are only 2 requirements in AS9100D for documented "procedures"; "nonconformity control" (8.7.1) & corrective action (10.2.1). These 2 procedures can be (and often are) combined into a single procedure.</WRAP> |
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| <note important>**# 14 & 15** \\ There are only 2 requirements in AS9100D for documented "procedures"; "nonconformity control" (8.7.1) & corrective action (10.2.1). These 2 procedures can be (and often are) combined into a single procedure.</note> | {{page>wiki:pathforward}} |
