In AS9100 revision D, clause discusses “Validation and Control of Special Processes.” It’s an attempt to improve upon the core ISO 9001 text above it, in 8.5.1, that makes a blink-and-you’ll-miss-it reference to special processes, without actually using the term.

What Is A Special Process?

First, understand what “special process” is supposed to mean, in ISO-speak. A “special process” is any activity you perform that you can’t subsequently verify through inspection or testing. For example, say you do something to a part but cannot know if you’ve done it well until after the customer installs the product in their equipment. Or, alternatively, the only way for you to test the product would be as part of a destructive test, leaving you with no product afterward to ship.

It’s a messy concept for sure. Nearly everything can be inspected or tested in some way, and the aerospace industry likes to slather the name “special process” on a lot of things that are not even particularly hard to inspect. That argument is outside the scope of this article, however.

For both ISO 9001 and As9100, if your company does something that might fall under this (loose) definition, you are expected to do some sort of “validation” of the special process, to make up for the fact that you can’t inspect or test the quality of that work afterward. ISO 9001 is horribly vague in this regard, which is typical for the 2015 version. All the standard says is that the organization must perform:

… the validation, and periodic revalidation, of the ability to achieve planned results of the processes for production and service provision, where the resulting output cannot be verified by subsequent monitoring or measurement.

ISO ignores the term “special process” entirely, making the clause super-confusing to anyone who doesn’t have an inside track on the developers’ mindset.

AS9100 tried to clean this up a bit by adding an entirely separate clause,, on the subject. Here, AS9100 doesn’t shy away from calling these activities “special processes,” and then lays out a more detailed set of requirements for validating them.

Many aerospace companies, however, don’t perform special processes directly. Instead, they outsource processes like anodize, heat treat, nondestructive testing (NDT), or plating… all activities commonly branded as special processes in the aerospace industry. They might even go further, only outsourcing these activities to Nadcap-accredited providers, adding another layer of confidence.

But if you’re a company that does outsource special processes, does that mean you get to exclude from your AS9100 QMS scope entirely? This is a debate that has been floating around for a few decades, going back to earlier versions of AS9100.

To Exclude or Not to Exclude?

And, as usual, third-party certification body auditors are no help whatsoever and cause more harm than good in this debate. You may encounter one auditor, from your CB, that insists you should exclude the clause if you outsource special processes. They will make a very compelling argument, too.

Then, another auditor from the same CB will come to your company in the future and tell you the opposite: that you must include it, even if you outsource special processes. The second auditor will say — in an equally compelling fashion — that you can only exclude the clause if you don’t do special processes at all, whether you outsource or not.

There’s no right answer, and neither ISO nor IAQG has provided any real guidance. Furthermore, any guidance they might issue would be completely ignored by CB auditors, who are not required to be trained on the latest official interpretations anyway. So it really doesn’t matter what ISO or IAQG might say.

But let’s break down the risks, then.

It causes no harm whatsoever to include the clause in your scope if you outsource special processes. In your documentation, you would simply explain that “our company does not perform special processes, but we do outsource them to approved suppliers.” Then, you would define the controls over those outside process suppliers in your usual purchasing procedures.

If a CB auditor disagrees, there’s nothing they can do about it. You went beyond what was required by AS9100, and they cannot write you up for that. They have no nonconformity to report, so any opinion they have on the subject is just that: an opinion. You don’t have to listen to it.

But the opposite is not true, when the CB auditor finds you have excluded a clause that they think should be included. The exclusion of a clause that is actually applicable to your company would amount to an instant major nonconformity, under the (somewhat vague) definition that says a “major” includes any instance where a company fails to implement an entire clause of the standard. If the CB auditor determines you do special processes, even if you outsource them, and finds you have excluded the clause, they could write up a major nonconformity. This puts your AS9100 certification at risk.

Now, if you chose to file an appeal, your AS9100 suspension is virtually guaranteed – the IAQG does not allow for the “clock to stop” on suspending your certification during an appeal process, which can take months to years to run its course. By then you will have lost your certification entirely, and be prohibited from re-obtaining it until the major NC is cleared. You will also have lost customers or be in violation of your contracts.

This is a clever trick the IAQG has pulled to ensure no one ever contests their major NCs. Then the CBs can later claim — falsely — that they enjoy high rates of performance quality and customer satisfaction. But in reality, it’s because filing an appeal is a death sentence for your AS9100 certificate.

So the risk of excluding the clause is huge, while the risk of including it is nil.

Therefore, I urge AS9100 certified companies to include if they outsource special processes, and (gently) push back against any CB auditor or consultant who might argue otherwise. After all, they are not going to pay you for lost contracts if you lose your AS9100 cert.


Traditional Tri-System