As reported earlier, AS9100 will be updated but rebranded as “IA9100” and released with a fresh revision status. Apparently, the draft standard is nearly entirely completed, but hasn’t been submitted for voting yet. This is because IA9100 will still have to include any changes to the core ISO 9001 text, and that might not come for another year.
In the interim, however, the IAQG knows that aerospace-related text changes will be made, and has released a few spoilers. In a recent set of meetings, the IAQG gave some presentations on the expected changes, and I am summarizing them here. My commentary appears in italics.
Short version: the creeping addition of entirely non-auditable, feel-good social issues is underway. It’s as if the IAQG saw what ISO was doing with “climate change,” and said, “hold my beer.” Oh, and they are adding cybersecurity, so that’s fun.
Clause 4.4: In yet another bit of evidence that the IAQG has no clue about the process approach, they apparently are going to add language saying that the identification of processes is now optional. Not sure how you have a management system without processes, but, then, I don’t crash 737 MAXes into the ground or buy all my titanium from Vladimir Putin, so what do I know?
Clause 5.1: Adds language to require a “Quality Culture,” in what appears to be some liberal cribbing from the Oxebridge Q001 standard, without attribution. Or not. But at least Oxebridge clients will be prepared, since we’ve already been doing this part. Also, a requirement for an “Ethical Work Environment,” which is hilarious coming from Boeing who — did I mention? — buys titanium from Vladimir Putin.
Clause 6.1: Some language clarifying the difference between organizational risks (subject to 6.1) and operational risks (subject to 8.1.1) but still no real concern for the former. IAQG doesn’t care if you go out of business, so long as your parts are on time.
Clause 7.1.4: In what is one of the worst ISO 9001 clauses, IAQG is dead-set on making it much, much worse. The clause that currently includes the bit about ensuring an “emotionally protective” and “calm, nonconfrontational” work environment is going to get language about “ethical behavior, product and personnel safety, quality of work life.” More evidence the people writing this standard have not been on a shop floor in decades. This stuff is already covered by LAWS and — I hate to break it to you, Buddy Cressionnie — your standard isn’t better than a law.
Clause 7.1.5: Adding a reference to Measurement System Analysis (MSA) to the note (but not as a requirement).
Clause 7.1.7: An entire new clause requiring information security. This will be a deal-breaker for a lot of companies that simply can’t afford the cost of implementing the (likely) expected controls. I haven’t seen the exact language, but this could push AS9100 out of reach for a lot of end users. IAQG could have created another cybersecurity standard in the new “IA9000” family, and then flowed that down as needed to relevant suppliers. But, no, they are being hamfisted about it, and shoving something in to be followed by everyone.
Clause 7.5.3: Additional language about controlling electronic documents, because Tim Lee doesn’t know we already had computers back in the horse-drawn cart days of 2015.
Clause 8.1: More language about cybersecurity, another reference to MSA, a nod to FOD, and some product placement language about APQP, which they no doubt hope will make a lot of people go out and buy IA9145.
Clause 8.1.3: The Product Safety notes have been moved into the requirements, so are now mandatory. These include: “identification of hazards, safety risks, change impact from safety risk, safety process effectiveness, training, communication and awareness, and reporting events.” It’s still not clear if the authors understand the original intent of the clause was product safety and not plant safety, but maybe this will be clear when we see the actual final language.
Clause 8.1.4: Ditto, now the notes become requirements for counterfeit part control, including, “training, parts obsolescence monitoring program, traceability of parts, test methodologies, monitoring counterfeit parts, and segregation/containment/reporting of suspected or detected counterfeit parts.” This is going to be difficult for companies that deal with very limited products subject to counterfeiting, since they won’t be able to exclude 8.1.4, but also won’t comply with all those requirements. Tricky.
Clause 8.3.2: In a move designed to anger the “Agile” folks, they aim to “divide design and development into distinct activities.” OK, sure, whatever, let’s go back to 1955 while we’re at it.
Clause 8.4.2: Minor tweak to Note, no practical change.
Clause 8.4.3: “Restructured clause to increase understanding including adding direct and sub-tier control.” I don’t know what that means, so I pasted it verbatim. Will they finally fix the language that suggests the bullet points are mandatory for all Purchase Orders? I doubt it.
Clause 8.5.1.3: They are clarifying that there’s more to this than just First Article. Great, guys, but then don’t complain when your mom-and-pop machine shop starts charging you 500% more for your parts.
Clause 9.2: New requirement to ensure internal audits include a review of performance indicators, and “ensuring risks are included” when establishing an audit program. That latter one was already pretty well assumed, not sure what they are on about.
Clause 10.3: Here, the IAQG materials are contradictory. They claim a “Note” will be added, but that it will contain a “requirement to plan periodic QMS maturity assessment and set improvement goals and objectives.” You can’t put requirements in the notes, geniuses. Let’s hope they sort that out.
This list is pretty comprehensive so, again, it means the draft is written and just awaiting the ISO 9001 text changes. I’m troubled that just like ISO 9001, the authors are making the standard worse, not better, and adding things that really don’t belong in a QMS standard at all. But given it’s the same gang that worked on AS9100 Rev D, and faced no blowback for their prior mistakes, we can only assume they feel more emboldened than ever.
What’s good? They resisted their demons and didn’t add “cost reductions” to the standard, thank God. Also, no reference at all to AS13100, the “engines and systems standard,” showing that the IAQG is literally breaking in half as the 9100 and 13100 teams go to war with their increasingly less-compatible standards.
Meanwhile, they have not tackled anything that might affect the companies of the authors themselves, like prohibiting making ad hoc changes to your delivery dates without notifying the supplier. Without addressing that, aerospace suppliers will continue to have artificially low on-time delivery rates, and risk being disqualified because of them. I guess Boeing can always buy from China? Or more from Putin?
Disappointing.
Christopher Paris is the founder and VP Operations of Oxebridge. He has over 30 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
