Issues

1. Issues RMC Meeting September 14, 2005 Sao Jose dos Campos Mike Roberts

2. Issues - List • General (Previous) Issues • AS9110 Auditor Issues • Expiration of Auditors, Notification, Extensions • Expired Certifications, Notification, Extensions • OEMs Having Problems from Certified Suppliers • OASIS Data Entry Within One Month • Certificates Posted In OASIS - Mandatory • Multi-site Issues • Cross Sector Recognition • ARP9009

3. Issues - 1 • AS9003 • Issue resolved at Savannah meeting • Issues affecting RMC • AS9101C • Report this afternoon at the AAQG meeting • Americas Sector, Inc. • Report by Jay at RMC and AAQG • This directly affects the RMC OEM membership

4. Issues - 2 • ANAB (and CBs) are running into some trouble finding AS9110 AIEA’s. • The requirement is 4 in the last 10 years (etc) and then “in addition they shall have had specific training in repair/overhaul or demonstrated 2 years full time experience in the last 4 years”.  Assuming the “specific training” is A&P training or something similar.  • As for the 2 in 4 years experience; as you can imagine an individual with that level of "full time" experience with repair/overhaul/maintenance is not an "experienced" auditor. • I have contacted numerous OEM’s to see if they have an AS9110 AIEA that can witness our AS9110 AA’s in order to upgrade them to AS9110 AEA’s and I have been unsuccessful. • We are moving ahead with the program using AS9110 AA’s and a technical expert (maintenance individuals from an airline).  This person (or persons) are not auditors; however, they are “technical experts” in this field.  I will be sending the expert’s resumes to the RMC Auditor Review Team for their recognition.  As you can imagine moving forward this way is not cost effective so we are still in search of an AS9110 AIEA that can witness our AA’s. • One proposal is if an auditor is an AS9100 AEA and they take the AS9110 training (competency and in-depth) and have been approved as an AS9110 AA have an expert in repair/maintenance field witness the auditor (who is AS9100 AEA & AS9110 AA) to upgrade to AS9110 AEA.  Because really if they are already an AS9100 AEA we know they can audit; it is making sure they know the repair/maintenance field.

5. Issue – 2A • One is about AS9110 auditors. Feel free to comment to all present that ANAB will be compelled to include an industry expert, at additional cost to CBs, for AS9110 as we are unable to have any of accreditation auditors qualified, and are unable to locate any candidate to become an accreditation auditor.

6. Issues - 3 • For an existing auditor, the database does not allow me to simply change the expiration date for an auditor upon acceptance of the information for renewal.  I have to enter this as a new approval.  Also, if I enter in any date in error, I cannot change it.  I have to enter in a new approval.  Note that the drop-down menu also does not allow for "renewal" • For an auditor (AIEA, AEA or AA) that is certified by RABQSA, the auditor will get advance notice of the pending expiration.  So, for these auditors, there should not be any inadvertant expirations. • For an "approved" auditor, there is no process for advance notice of pending approval.  For an AIEA or AEA, which are in OASIS, a CB or auditor may not be aware of the expiration until an audit report cannot be entered.  For an AA, the AB or CB or auditor may not be aware of the expiration until someone reviews the letter of approval from ANAB---which may be during an accreditation audit or whenever the letter is being updated for changes. • When I (with ANAB, not RABQSA) become aware of an expired "approved" auditor (AIEA, AEA or AA), I will delete it from the letter of approval and notify the CB.  When reviewing the renewal information, if the CB can provide evidence that the renewal conditions were satisfied during the term of approval (which means the training and audits occured during the term of approval), I will grant the renewal from the prior expiration date.  If the renewal information indicates that some of the requirements were met after the expiration, I will grant the renewal from the date of my review and forward----and follow up with the CB for correction or corrective action for any audits conducted while expired.  Please advise if you agree with the process I am using. • One suggestion I have is to have a notice generated by OASIS sent to the AEA about 90 days prior to expiration.  It may be wise to also send this notice to the oversight body (e.g. ANAB) under which the auditor is in OASIS.

7. Issues – 3A • If you recall at Savannah I raised the idea of making a request that OASIS is set up to notify/warn individual auditors and a specified CB contact when an auditor is three months away from their approval expiration date. • How should I make this request and to whom should I make it? Is there a formal process and OASIS change request form or other document that needs to be used/completed?

8. Issues - 4 • We are seeing issues with expired certs yet the re-assessment is not occurring until after the expiration date. • The OASIS data indicates the cert will expire tomorrow. • The issues include: • Can a cert be extended beyond the expiration date? • While C/A is being processed? • Due to schedule issue for up to ? Months • No extensions allowed. • What are the actions a CB should take when a certification expires? • Removal from OASIS • This issue may have a significant impact to the OEM's that have recognized certs. It creates internal actions to document this status and may require a change in supplier approval status (i.e., returning to a 2nd party approval) which are not value added if the supplier is in the process of updating their cert. • This is an issue that needs to be addressed in the next version of AS9104.

9. Issues – 4A • I am getting internal reports from our Field Representatives that CBs are not updating OASIS information when certifications have expired and that OASIS does not include necessary multi-site information. • We are at the end of our first 3 year AS certification cycle (several AS certifications were issued in 2002). The concern we have is with ensuring that OASIS has the latest updated information and that recertification occurs prior to expiration or the supplier is removed from the database.

10. Issues - 4B • Certification Extensions

11. Issue – 4C • Another is regarding extensions to certification if a CBs client does not qualify for full re-certification. OASIS is not allowing for extensions. The issue has been identified as part of review of the database---but has gained attention when PRI tried to enter an extension. I have been communicating with members of the OASIS subteam and with Mike Roberts---urging some flexibility. This is just a heads up for you as this is likely to be on the table.

12. Issue – 5 • Another issue we have all feared may be emerging. Some OEMs are having problems with products from certified sites----and upon challenge to CBs are getting luke-warm responses. This may be serious if the CB industry does not realize that "output matters" and take very prompt and effective action in response to any complaints.

13. Issues - 6 • OASIS - considering that AS9104 became effective 1 April 2005, and 8.4 which requires entry into OASIS one month after certificate issue or surveillance audit, the AAQG (or IAQG OT) may wish to establish a deadline for entry of all AS9100/AS9110/AS9120 clients into OASIS--period.

14. Issues - 7 • How has it been communicated to CBs the decision taken in Amsterdam that effective 1 July 2005, certificates are to be uploaded into OASIS?

15. Issues - 8 • Although AS9104 became effective 1 April 2005, which is truly when the 8.2.3 came into effect regarding sampling being for AS9120 only, it is reasonable to assume some sampling or multisite certificates may have been done earlier that does not now conform.  My suggestion is to announce this (I can do via a Heads Up for our CBs) with a time period for CBs to review the client files for any multisite certificates or sampling and for them to work with their clients to come into conformance with the new rules.  I suggest giving them 3 months for the review, and another 9 months for them to work with their clients to effect the changes.

16. Issues - 9 • I have spoken to UKAS and at the moment there is no agreement in place which allows a ANAB qualified auditors to carry out an audit on a UKAS certified AS9100 company. However, they are working on the agreement with ANAB, as well as other accreditation bodies, and they expect this to be finalised and a reciprocal agreement to be in place by the end of August, or the beginning of September this year (UKAS are 90% sure this will be agreed by then). • I suggest you ring ANAB and get their view on this agreement and when they think it will happen as they have had some specific issues with the agreement, although UKAS think these are now resolved. • UKAS suggest that if you book the client it should be booked as late as possible, i.e. not before the beginning of September, but even then you are taking a risk when the agreement is not yet in place, so if you do this you may need a contingency plan. • UKAS plan to publish the sub-contractor list detailing all the accreditation bodies involved in this reciprocal agreement on their web site at the end of August so it would be a good idea to keep your eye on this.

17. Issues – 10 • ARP 9009 • What is the status of the "Common Quality Clause" document (a.k.a. ARP 9009)? • Who is the current champion? • Does a team/project still exist and is it sanctioned by the AAQG? • Who is the team lead? Who is on the team? • When was the last project report? • What is NASA's involvement?