Addressing AS9100’s “Ghost Clauses”

The updating of the aerospace standard AS9100 from Rev B (released in 2003) to Rev. C (released in January of this year) has generally been seen as a good thing. The new revision clarifies some language, adds some important (yet not-particularly-difficult) new requirements, and even dropped some confusing requirements. It’s that latter point, however, that will be giving AS9100 C early adopters some trouble.

Chicken, Meet Egg

While the AS9100 C standard was available for purchase — and, thus, implementation by companies — as of the beginning of 2009, third party certification bodies (“registrars”) cannot audit or certify to the new version until certain other documents are released, those that govern how registrars will be conducting AS9100 certification audits. These include the updated rules for aerospace auditor training, and the “audit tables” which define how many days a registrar must audit a company, based on employee count and other factors. Without the official release of these documents, registrars cannot audit to the new revision, and must continue to audit and certify only to AS9100 B.

With so much commonality between AS9100 B and C, this shouldn’t cause much of a problem, right? Not so much. A company implementing the new requirements of revision C will simply be ahead of the game, with additional features embedded in their quality system that the registrar’s auditors will simply ignore.

It’s the “ghost clauses” — the requirements deleted from revision B — that will be trouble. A company implementing revision C is likely to forget or overlook implementation of these older requirements, only to be shocked when a registrar issues nonconformities — some potentially sever — against AS9100 B.

With only an estimate of when the final aerospace rules will be released for AS9100 registrars (most indicate by Q1 2010), we know we are facing at least a six month period until registrars can officially audit to AS9100 C … meaning the ghost clauses are going to haunt early adopters of AS9100 C for at least half a year.

(FYI: mysteriously — or not so mysteriously, if you understand how some of them think — there are some registrars quoting AS9100 C registration services. They are doing so “inappropriately”, as the only “legal” service they can offer at this time is an AS9100 B certification audit. Be careful with any registrar who insists they can issue an AS9100 C certificate now, as that’s simply not true.)

Calling Forth the Ghosts

Specifically, the three ghost clauses are:

• Clause 4.2.2 Quality Manual: there is no longer a requirement to include a means of showing how the QMS procedures correspond to the clauses of AS9100.
• Clause 7.4.3 Verification of Purchased Product: there is no longer a requirement to validate test reports when they are used as a means of receiving incoming raw materials.
• Clause 8.2.2 Internal Auditing: there is no longer a requirement for the development of “detailed checksheets, process flowcharts,” etc. to support internal auditing, nor the need to measure their effectiveness.

The first and third of the ghost clauses are minor, to be sure — it will hardly be a “showstopper” if an AS9100 C early adopter company fails to include a “procedure vs. AS9100 clause” matrix in the Quality Manual, or develop anything more than a traditional AS9100 internal audit checklist.

It’s the second ghost clause that stands to create significant problems. Under AS9100 B, the “validation of test reports” clause caused no end of problems, due in part to poor wording in the standard itself, and confusion on the part of the standard’s authors as to what, exactly, they were getting at. Oxebridge spent a month discussing the clause with AS9100’s authors, trying to determine if the intent was to validate test reports data in order to prove the truthfulness of vendors or the quality of product — or both. In the end, Oxebridge wound up with six different answers.

Rather than clarify the intent, the authors of AS9100 Rev C dropped it entirely, in a gutsy move that earns the authors some credibility for knowing when to cut and run. Companies struggling with how to not spend thousands of dollars in independent lab testing of incoming raw materials will be relieved to know they can stop the practice entirely, and still comply with AS9100.

That is, when AS9100 C audits are finally underway. Until then, a company implementing AS9100 C must also implement the three ghost clauses of AS9100 B, or risk being written up against them. And, under AS rules, all findings — major or minor — must be resolved and closed to the satisfaction of the registrar before an AS9100 certificate can be issued.

Dealing with the Ghosts

As always, Oxebridge likes to provide solutions… not just a declaration of the problem. Therefore, we suggest the following way of addressing each of the ghost clauses, so companies can implement AS9100 C now, and undergo a certification audit now, instead of waiting six months.

1. Include the “procedure vs. AS9100 clause checklist” in your Quality Manual. It’s a ten minute exercise in creating it, so an easy way to get past this ghost clause.
2. In your Internal Auditing procedure, define your current audit checklist in detail, and include language that the Quality Manager (or similar manager) will “review the results of audits and look for ways in which the checklist can be improved, if problems are found.” That simple language buys you out of this ghost clause.
3. As for the validation of test reports… well, you have to implement it for six months. Determine your two largest or most critical raw materials or subcontracted processes for which you receive test reports or certifications from the suppliers as part of receiving. Develop a log that shows you intend on validating test reports through either in-house measurement or test, or via independent lab testing, and submit one sample of each now. Include in your procedure that you do not have to repeat the validation exercise for another six months (get it?) if a comparison of the validation meets the data on the supplier-provided test report. Include language on how to deal with a situation when the data does not match. After six months are up, the new AS9100 C should be fully rolled out, and you can delete the procedure entirely. At worst, you have spent a few dollars on sending in two samples for testing. At best, you uncover an unscrupulous vendor or illegitimate test report.

Christopher Paris
VP Operations
Oxebridge Quality Resources

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