IAQG’s Registration Management Committee (RMC) is circulating a sudden revision to AS9101, the rules for auditing under AS9100. The Rev. E draft takes into consideration some market realities pushed by the CB’s and their auditors: the previous rev D had tripled the paperwork required by auditors, and the RMC refused to increase audit days. This led to big gripes by auditors, as well as rushed paperwork and offloading report writing to the clients themselves.
Scrambling to maintain their vision of “90% of the supply chain certified” (a fantasy at best, since probably less than 0.1% is certified right now), the RMC rushed out rev E , taking into account the feedback of the registrars.
So, under the guise of improved “process auditing” — a concept that is defined exactly nowhere — the OER checklist and evidence report is dumped entirely, and a few pages are added to the controversial, and almost universally loathed, PEAR form. At first blush this presents a lot more problems for AS9100 and the IAQG.
First, there will be a reduction in the level of objective evidence required to be recorded by the auditor. The ramifications are obvious: auditors need to spend far less time on the production floor gathering evidence, and need to do far less to justify their findings. This ties in with the unspoken theme that the IAQG is simply not interested in objective evidence to support decisions related to AS9100 certification.
Second, it pushes forward on this wacky idea that the way to assess a QMS is by assessing process effectiveness, which actually runs counter to the original purpose of conformity assessment. Judging effectiveness is a subjective process in itself, and one that only works (sometimes) when backed up with massive objective evidence. Even then, it can easily be challenged because the evidence is usually cherry-picked to support a predetermined notion. With the simultaneous elimination of the Objective Evidence Report, we will see a reduction in the amount of evidence used to support an auditor’s opinion on whether a process is effective or not.
How this works in real life: a CB auditor gets a “feel” for whether a process is effective based on his or her personal experience, previous employment history, and knowledge (or lack thereof) of a particular industry or technology. They then write the PEAR and plug in some hand-picked evidence to support the decision. It’s supposed to happen in the other direction — the evidence listed on the OER is collected into a decision on process effectiveness, but it’s never happened that way.
AS9101E codifies this backwards approach into “law.”
Incidentally, the entire thing is probably contrary to international rules on accredited auditing, but then so was AS9101D, and the IAF never interceded. Under the last revision, AS9100 Rev C certificates should have probably been declared invalid, due to violations in rules governing audit sampling and objectivity.
Worsening matters are the recent rulings by AAQG, IAQG and the IAF that clients can fill in their own PEARS with whatever evidence they want, and the auditors need only sign off that they verified it. With the OER jettisoned, the auditors wont have to leave the conference room and can merely autograph a PEAR form filled out entirely by the client ahead of time… and it’s all completely legal!
(An aside; inside sources tell me a recent RMC meeting actually advised CB’s not to have clients fill out their own PEARs, even while RMC head Tim Lee was trying to save face by telling Oxebridge that having clients fill in their own evidence is completely fine. More on that as I gather up evidence.)
The OER was the last firewall against lazy auditing, but the CB’s won out and in its desperation to flood the aerospace market with certificates, the RMC caved.
Meanwhile, I suspect the “guru” who came up with the PEAR idea — something, by the way, not supported in any school of process management, engineering or any industry whatsoever and invented entirely from thin air by the RMC — is probably being heralded internally as a genius.
But then so was RABQSA’s Mike Carmody when he wanted to do psychometric testing on every working auditor, and we saw how well that worked out.
Sometimes bad ideas get a lot of traction, and this PEAR 2.0 thing is one of them. This will do far more harm than good for the value and validity of AS9100 certificates. It will make it easier for the auditors, for sure, but is that what we want?
Well, it’s what Boeing wants anyway. But history will judge this a massive mis-step on ethical, technical and logical grounds, as certifications are granted purely on auditor whim, and the notion of using evidence to make objective decisions is tossed into the FOD bucket.
Christopher Paris is the founder and VP Operations of Oxebridge. He has over 35 years’ experience implementing ISO 9001 and AS9100 systems, and helps establish certification and accreditation bodies with the ISO 17000 series. He is a vocal advocate for the development and use of standards from the point of view of actual users. He is the writer and artist of THE AUDITOR comic strip, and is currently writing the DR. CUBA pulp novel series. Visit www.drcuba.world
