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Volume 8 · Issue 1 · January 2003

Contents

Purchasing on Lists for 2003 QS-9000 Surveillance Audits
IASG Advises Registrars on Subcontractor Development

If your organization is registered to QS-9000:1998, December 31, 2002, was the deadline by which all of your critical-to-quality subcontractors were to be registered to ISO 9001/2. In advance of the deadline, the International Automotive Sector Group (IASG) issued an Advisory on December 10, 2002, to registrars detailing how QS-9000-registered production or service parts suppliers that have failed to get their subcontractors registered to ISO 9001/2 or audited by a customer-approved second-party are to be treated. As a result, expect that your organization’s next QS-9000 surveillance audit will include a thorough assessment of the Purchasing Department for evidence of subcontractor registrations.

In effect, if a QS-9000-registered organization does not have assurance that all its suitable suppliers are registered to ISO 9001/2 or some other verification of conformity exists, it will have its registration either put on probation or issued a nonconformity. It will have, respectively, either 4 or 6 months to correct the problem before its QS-9000 certificate is revoked. In other words, those suppliers of components or services that affect the quality of the product a QS-9000-registered organization provides to its automotive customer(s) need to be registered or the Tier 1 will be at risk of losing its registration and its contracts with original equipment manufacturers (OEMs).

Registrars will be required by the Advisory to issue a nonconformity if one or more suppliers to a QS-9000-registered organization are found not to be registered to ISO 9001/2 or QS-9000, which involves ISO 9001/2:1994 registration, when the next surveillance audit is conducted (it is expected that ISO Technical Specification [TS] 16949 registration would also be acceptable). The nonconformity would be against the requirements of 4.6.2.1, Evaluation of Subcontractors—Subcontractor Development, of QS-9000 and IASG Sanctioned QS-9000 Interpretation C9, Supplier Development.

A major nonconformity must be issued if the QS-9000-registered supplier has also demonstrated other performance problems indicated by one or more customers, as spelled out in the Advisory, or other quality management system (QMS) nonconformities are found during the audit. A minor nonconformity will be issued if there are no other QMS or performance problems, in which case the nonconformity must be corrected within 2 months (60 days) or a major nonconformity must be cited. A copy of the Advisory, which was posted on the IASG web site (www.qs-9000.org), is reprinted on page 24.

The time frame for correcting the nonconformity will thus depend on whether other quality-related problems exist. While the Advisory does not change the requirements for automotive suppliers and the impact on their suppliers, it does reinforce the seriousness of the OEMs that require supplier registration to QS-9000 when it comes to ensuring the use of registered QMSs down the supply chain.

THE OUTLOOK had the opportunity to discuss with Bob Djurovic of DNV Certification, Inc., and Tony Perkins of QMI how registrar evaluation of conformity with Interpretation C9 and 4.6.2.1 will occur. When asked if their organizations or other QS-9000-qualified registrars they were aware of planned to contact their QS-9000-registered clients in January 2003 to seek documented evidence of the registration of their suppliers in conformity with C9, both indicated that there would not be a special audit for this requirement of QS-9000 registration.

"We plan to conduct our QS-9000 surveillance audits according to a normal schedule, so some clients may have several extra months to get their suppliers registered and to obtain evidence of those registrations, preferably a copy or photocopy of the certificate," confirmed Djurovic, who noted that most DNV clients registered to QS-9000 undergo semi-annual audits. He added that he did not expect many instances where suppliers would not be registered to ISO 9001/2 and/or QS-9000, but a thorough review of the Purchasing Department would yield objective evidence of conformance.

"The biggest change is that the schedule of what will be audited during the first QS-9000 surveillance of 2003 will definitely include compliance with the Sanctioned Interpretations, since our auditors need to verify that supplier registrations are in order," explained Perkins, who reported that QMI had communicated with its QS-9000-registered clients about the implications of C9 repeatedly over the past 18 months.

Impact on ISO 9001:2000 and ISO/TS Transitions

While a few QS-9000-registered organizations may have obtained waivers for some of their suppliers and a few may have used customer-approved second-party audits for ISO 9001/2 conformity of their suppliers, the vast majority were required by Interpretation C9 to have their critical to quality suppliers registered by December 31, 2002. As Interpretation C9, issued on July 1, 2001, states:

"Goal of subcontractor compliance" [in 4.6.2.1 of QS-9000] 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 ISO 9000 Quality Management Series of Standards, excluding ISO 9003; plus any requirements specified by the customer.

The December 31, 2002, deadline may actually have greater repercussions in terms of another deadline. On December 15, 2003, all accredited certificates of registration to ISO 9001/2/3:1994 will become obsolete. What this means is that, while QS-9000-registered organizations will be able to maintain their existing ISO 9001/2:1994-conforming QMSs until the Daimler-Chrysler or Ford/GM deadlines for transitioning to ISO/TS 16949:2002 (July 1, 2004, and December 14, 2006, respectively), their suppliers will be obliged to transition to ISO 9001:2000 by December 15 of this year. The impact may be on both ISO 9001:2000 transitioning during 2003 and on ISO/TS 16949:2002 transitioning in 2003 and beyond.

Advisory: QS-9000 Clause 4.6.2.1 and Sanctioned Interpretation C9 (December 10, 2002)

Situation:
QS-9000 certified supplier site not meeting the requirements of Clause 4.6.2.1 and Sanctioned Interpretation C9 related to subcontractor development.

FINDING RECOMMENDATIONS

Major Nonconformity:

  1. Noncompliance with 4.6.2.1 and C9, and
  2. Certified supplier site has performance problems as identified by customer performance trend data including, but not limited to:
    • Delivered part quality
    • Customer disruptions including field returns
    • Delivery schedule performance (including incidents of premium freight)
    • Customer notifications related to quality or delivery issues, and/or
  3. Other nonconformities in the certified supplier system indicating either a likely failure of the quality system or conditions exist to materially reduce its ability to assure controlled processes and products.

Implications:
A "major" finding means certification probation status with four months to remedy the probation as provided in R3 of the Sanctioned Interpretations currently in effect.

Minor Nonconformity:

  1. 1) Noncompliance with 4.6.2.1 and C9, and no other performance or quality system factors as listed above.

Implications:
A "minor" finding requires 60 days to correct. If the "minor" is not corrected, the result is a "major" finding as provided in R3 of the Sanctioned Interpretations currently in effect.

The nonconformity would be issued when identified.

THE OUTLOOK spoke with the manager of supplier development at a major Tier 1 to the Big Three that is making a concerted effort to complete the transition to ISO/TS 16949:2002 in the first half of 2003. However, the biggest hold-back may be the Tier 1’s suppliers. According to this manager, who wished to remain anonymous, when he surveyed more than 100 suppliers in the latter part of 2002 about their registration status—both to ensure all the suppliers were registered to ISO 9001/2 and/or QS-9000 before the Interpretation C9 deadline and to see how many had already transitioned to ISO 9001:2000—the survey showed that none of them had transitioned to ISO 9001:2000 and that many could not even give a scheduled date for the transition assessment by their registrars.

"Ultimately, if my suppliers are not transitioned to ISO 9001:2000, we can’t transition to TS 16949:2002," stressed the manager. "So, what we are doing now is working with our suppliers to get them through the QMS upgrade process and the transition assessment. We hope to have a fully compliant TS-based QMS within our organization in the next few months, with the only missing piece being 7.4.1.2 [Supplier Quality Management System Development]. I think we will benefit greatly from the TS transition and that our suppliers will benefit from ISO 9001:2000."

THE OUTLOOK recommends that, if your organization is a supplier to organizations registered to QS-9000, you make sure that your customers have documented evidence of your organization’s ISO 9001/2 registration and that you consult with your customers about their plans for transitioning from QS-9000 to ISO/TS 16949:2002. Depending on the nature of your organization’s relationship with its customers, it may be practical to coordinate the upgrade of your QMS to ISO 9001:2000 with the transitioning of the QMSs of your customers to ISO/TS 16949:2002.

If one or more of your key customers are interested in making the transition sooner, there may be benefits in cooperating with their plans by having your organization make the transition to ISO 9001:2000 sooner.

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