[UPDATE 9/21/2016: The final edition has been released, and we will be assessing it shortly.]
We’ve finally secured a copy of AS9100 Rev D, the latest revision of the aerospace QMS standard, currently in draft form. It took six cat burglars and eight actual cats to do it, but we’ve got it. Here are some quick takeaways for those of you interested in what’s coming:
- The new AS9100D just takes the ISO 9001:2015 standard and inserts much of the old AS9100C language in places where it fits. That means that ISO 9001:2015 remains in its entirety, warts (RBT) and all.
- It follows the clause structure of ISO 9001:2015, and adds a few sub-clauses
- New ISO 9001 concepts such as context of the organization and risk based thinking remain in place. The Annexes from ISO 9001 are also in place. AS9100 adds a lot of notes to clarify things.
- The standard appears to have been written by a very tiny handful of people; I’d guess five at the most. This aligns with the IAQG’s general position that its standards are written “by consensus” only if you view “consensus” as a few people write it, everyone else agrees with it. Not ideal.
- IAQG still doesn’t understand risk management, nor human factors, but that hasn’t stopped them from mandating their uninformed views anyway, and pretending they represent the entire “aviation, space and defense” industries.
- AS9100D does put back some risk management language, whereas ISO 9001 avoided it entirely, opting only for “thinking” about risk. It’s not well done, though, and is still confusing.
- Despite ISO 9001 doing away with the Quality Manual, the AS9100D draft points users back to creating one, through a note.
- Adds requirement about re-certification of personnel, borrowed from AS9110.
- Operational Planning and Control adds requirements for FOD, product obsolescence, plus old MIL-Q style language about handling, packaging and preservation
- Clause 8.1.1 is changed to “Operation risk Management” and clarifies that risk in this clause are only related to products and services. Nice touch.
- New clause 8.1.3 on Product Safety. Gets dangerously close to a product certification; some stakeholders in ISO will be furious.
- New clause 8.1.4 on Prevention of Counterfeit Product. Clearly the anti-counterfeit boys at IAQG had the most influence, or the best whiskey.
- Counterfeit part control continues in supplier control; also, under control of nonconformances, the organization is prohibited from returning counterfeit parts to the supplier, and must take control over them. Legally, this could be tricky.
- Added back language about special processes, which ISO 9001 had taken out.
- Adds back language about statistical techniques, which ISO 9001 had taken out.
- The old AS9100 clause for “Project Management” is diluted down to a note now.
- Internal auditing now indicates that “performance indicators” can be used to assess QMS effectiveness.
- Adds ensuring personnel and suppliers are aware of “ethical behavior.” This may lead to CB auditors now claiming expertise over “ethics” which should result in the entire world laughing itself to death.
- Didn’t fix confusing language about “work transfers” from AS9100C; IAQG clearly ignored the industry on this.
- Added back the confusing language on validation of test reports that had originally appeared in AS9100B, but which was removed in AS9100C. The IAQG still refused all input on how to fix this, and instead just cut and pasted the old AS9100B language, making the old problem new again. Now they say it’s “focused towards critical items”, but that’s not clear. Fool me once, and all that….
- Adds language about Human Factors (HF), but borrows from AS9110 to do so. Since AS9110 is for aircraft maintenance orgs, AS9100 has effectively ignored all other forms of HF, and is now imposing aircraft MRO style HF on everyone. Working professionals in aerospace know that human factors for design of systems is very different from HF in repair stations, but IAQG doesn’t know that.
- Clause on Corrective Action adds some language about HF, too, muddying the waters further.
- Adds a note, presumably as a political concession to the IAQG “APQP Team”, for Advanced Product Quality Planning, which is tilting AS9100 towards an eventual mandatory automotive-style PPAP. This will be utterly unsustainable for any small- to medium-sized AS9100 organization, but IAQG (read: Boeing) simply doesn’t care.
- AS9100D follows ISO 9001’s inexplicable lead on removing preventive action entirely, which the industry should be up in arms about. No serious aerospace player — including the Boeing and Lockheed companies that write AS9100 — has ever abandoned preventive action, nor have they ever been particularly confused by it. The IAQG team, however, is clueless as ever, and damns AS9100 users into eliminating the idea of proactive, root-cause-based PA systems, in lieu of a risk register and some “thinking” about risks. This is likely to literally increase the risk of product safety, but again, IAQG is clueless.
OXEBRIDGE HAT TIP
- AS9100D adopts my “uncertainty battery” model, almost lifting the language from my presentations and articles word-for-word. More on that in a coming article.
About Christopher Paris
Christopher Paris is the founder and VP Operations of Oxebridge. He has over 30 years' experience implementing ISO 9001 and AS9100 systems, and is a vocal advocate for the development and use of standards from the point of view of actual users. He is the author of Surviving ISO 9001 and Surviving AS9100. He reviews wines for the irreverent wine blog, Winepisser.