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Whittington Newsletter )
QMS, EMS, Information Security, Services Management, and Six Sigma March 2009
In this Issue
  1. ISO 9001 and Risk
  2. Prepare for an Audit
  3. Actions After Audits
  4. How Many Shalls?
  5. AS9100C Differences
  6. Class Schedule

Greetings!

Welcome to the Whittington & Associates e-Newsletter! Visit and bookmark our web site.

Our newsletters provide guidance on ISO 9001, AS9100, ISO 13485, ISO/TS 16949, TL 9000, ISO 14001, ISO 27001, ISO 20000, ISO 22000, and related ISO standards, as well as, Six Sigma.

If you have any questions about the articles appearing in this issue, or you want to suggest topics for future issues, please let us know.


ISO 9001 and Risk

What does ISO 9001 say regarding risk management? Well, ISO 9001:2008, clause 0.4, repeats this statement unchanged from the ISO 9001:2000 standard (underlines are my emphasis):

This International Standard does not include requirements specific to other management systems, such as those particular to environmental management, occupational health and safety management, financial management, or risk management.

It seems to clearly state there are no requirements in ISO 9001 for risk management. However, the revised statement below from ISO 9001:2008, clause 0.1, says "risk" will influence how you set up your quality management system:

"The design and implementation of an organization's quality management system is influenced by its organizational environment, change in that environment, and the risks associated with that environment, "

Although ISO 9001:2008 doesn't include any requirements for risk management, does it include any that are risk-related? Consider clause 5.6.2, Input (Management Review), which states:

"The input to management review shall include information on (f) changes that could affect the quality management system."

To determine how a change might affect the quality management system, you should assess the likelihood of the change happening, when it might happen, and its impact if it did happen. This sounds like considering the risk associated with a change to understand its effect.

And, what about clause 8.5.3, Preventive Action, when you consider potential problems and try to keep them from happening? Wouldn't that involve identifying, assessing, and mitigating the risk associated with a potential problem?

Risk Guidance

Although ISO 9001:2008 doesn't include a specific requirement for risk management, several places in the standard would cause us to consider risks. And, the guidance standard, ISO 9004:2000, states that an organization "should" consider risk management.

For example, ISO 9004:2000, clause 5.1.2, "Issues to be Considered", states that management should consider identifying and managing risks. And, clause 5.4.2, "Quality Planning", says that inputs for effective and efficient planning include risk assessment and mitigation data.

Clause 5.6.3, "Management Review Output", says additional outputs may include loss prevention and mitigation plans for identified risks. Clause 6.3, "Infrastructure", states that infrastructure planning should consider the identification and mitigation of associated risks.

Clause 7.1.3.1, "Managing Processes - General", says an operating plan should be defined to manage the processes, including identification, assessment, and mitigation of risk.

Clause 7.1.3.3, "Product and Process Validation and Changes", says that risk assessment should be undertaken to assess the potential for, and the effect of, possible failures or faults in processes. And, that the results of the assessment should be used to define and implement preventive actions to mitigate the identified risks.

Clause 7.3.1, "Design and Development", says management has the responsibility to ensure steps are taken to identify and mitigate potential risk to the users of the product and the processes of the organization. Risk assessment should be undertaken to assess the potential for, and effect of, possible failures or faults in products or processes. The results of the assessment should be used to define and implement preventive actions to mitigate the identified risks.

Clause 7.4.1, "Purchasing Process", says management should identify and mitigate any risk associated with the purchased product. Clause 7.5.2, "Product Identification" (yes, 7.5.2 in ISO 9004; not 7.5.3 as in ISO 9001) says the need for identification and traceability may arise from the mitigation of identified risks. Clause 8.5.3, "Loss Prevention" refers to the data generated from the use of risk analysis tools, such as, fault mode and effects analysis.

But what is risk management?

Risk Management

Risk is a product of the uncertainty of future events and is a part of any process. It is a fact for any organization. We typically try to stay away from situations that involve high risk. However, when we cannot avoid risk, we look for ways to reduce it (or its impact). Yet, even with careful planning and preparation, risks cannot be completely eliminated because they cannot be completely identified in advance. However, strange as it may seem, risk is essential to progress.

The opportunity to succeed also carries the opportunity to fail. So, we have to learn to balance the possible negative consequences of risk with the potential benefits of its associated opportunity. Risk may be defined as the possibility to suffer damage or loss. The possibility is characterized by three factors:

1. The probability, or likelihood, that loss or damage will occur.
2. The expected time of occurrence.
3. The magnitude of the negative impact that can result from its occurrence.

The seriousness of a risk can be determined by multiplying the probability of the event actually occurring by the potential negative impact to cost, schedule, or performance:

Risk Severity = Probability of Occurrence x Potential Negative Impact

Risks where the probability of occurrence is high and the potential impact is very low, or vice versa, are not considered as serious as the risks where both the probability of occurrence and the potential impact are medium to high. Managers should recognize and accept the fact that risk is inherent in any activity.

There are two ways of dealing with this risk. One, risk management, is proactive and carefully analyzes future project events and past projects to identify potential risks. Once risks are identified, they are dealt with by taking measures to reduce their probability or to reduce their impact. The alternative to risk management is crisis management. It is a reactive and resource-intensive process, with available options constrained or restricted by events.

Because risk will be found in all areas, and will often be interrelated, risk management should address all processes of the system. Learning to balance the possible negative consequences of risk with its potential benefits is the key to successful risk management.

Prepare for an Audit

To prepare your organization for an external audit:

  • Communicate the audit scope and schedule
  • Ensure key contacts are available for interview
  • Verify process owners can clearly describe
    • inputs and outputs
    • resources and methods
    • controls and measures
  • Arrange for auditor access to documentation
  • Plan the logistics for the audit team visit
Managers of the areas to be audited should:
  • Become familiar with the documents in their area
  • Walk through the area for a spot check on operations
  • Verify that only valid documents are being used
  • Identify records that prove requirements are met
  • Be prepared to share performance results for area
  • Ensure that the work areas are clean and orderly
  • Confirm that past nonconformities have been fixed
  • Brief employees on how to interact with auditors
  • Communicate a positive, learning view of the audit
  • Participate in the audit briefings and meetings
Auditors will need escorts, so their guides should:
  • Know the quality system and how it operates
  • Understand the audit plan and functional areas
  • Be available by staying with the audit team
  • Clarify, not answer, for the person interviewed
  • Act as witnesses for any audit nonconformities
  • Help keep the auditors on the planned schedule
  • Take good notes for possible follow-up actions
Of course, employees in the areas to be audited should:
  • Understand the quality policy and their role
  • Prepare by participating in internal audits
  • Know where their documents are located
  • Be able to quickly retrieve their records
  • Know how to respond to auditor questions
  • Be prepared to demonstrate their activities
  • Be aware of quality objectives for their area
Employees should be ready to answer audit questions such as:
  • What is the overall purpose of this process?
  • Please describe your job and responsibilities.
  • What are the process inputs and who supplies them?
  • What resources are needed for this process?
  • What are the process outputs and who receives them?
  • How do you know what to do?
  • What training, skill, and experience are needed?
  • Show me, or tell me, how you do the job.
  • How do you know if it is done right?
  • When it is not right, what do you do?
  • What records are kept of this activity?
  • How is the process controlled?
  • What are the process objectives?
  • How is the performance measured?
  • How could this process be improved?
When being interviewed, employees should:
  • Listen carefully to the auditor questions
  • Provide brief, accurate, honest answers
  • Answer specific questions, not volunteer
  • Avoid steering auditor to other discussions
  • Be cooperative, not misleading or defensive
  • Avoid digressing, speculating, or embellishing
  • Ask for clarification if they don't understand
  • Admit if they don't know the answer to question
  • Refer auditor to right person for an answer
After the audit, be sure to:
  • Thank everyone for their participation
  • Summarize audit results to organization
  • Request corrective actions, as needed
  • Monitor actions for timely completion
  • Verify corrective actions are effective
  • Inform the audit body, as appropriate
  • Analyze results and identify any trends
  • Initiate preventive actions, as needed

Actions After Audits

According to ISO 9001:2000, clause 8.2.2, on internal audits, we were to " ... ensure that actions are taken without undue delay to eliminate the detected nonconformities and their causes". Many organizations interpreted these actions to be taken as "corrective actions", and they were partially right.

ISO 9001:2008 expanded the internal audit requirement to say "ensure that any necessary corrections and corrective actions are taken ... ". This revision tells us that an immediate correction might be needed before determining the cause of the nonconformity and taking corrective action to prevent its recurrence.

The only other place in the standard that refers to correction is in clause 8.2.3, Monitoring and Measurement of Processes. It continues to state in ISO 9001:2008, as it did in ISO 9001:2000, that "When planned results are not achieved, correction and corrective action shall be taken, as appropriate ...".

Clauses 8.2.2 and 8.2.3 both call for process monitoring. If you are monitoring a process as required by clause 8.2.3, and it doesn't achieve its planned results, you are to (as appropriate) take correction and corrective action. Clause 8.2.2 now matches 8.2.3 by saying if processes being monitored by an internal audit don't meet their requirements, then take the necessary corrections and corrective actions.

What is a correction? ISO 9000:2005 defines it as the "action to eliminate a detected nonconformity", whereas, it says corrective action is the "action to eliminate the cause of a detected nonconformity ...".

So, when a process is not meeting its requirements (per 8.2.2) or planned results (per 8.2.3), the problem must be eliminated, as necessary (8.2.2) or appropriate (8.2.3). And, then when we know what caused the nonconforming situation, corrective action must be taken (as necessary or appropriate) to remove the cause and prevent the recurrence of the nonconforming situation.

Another view of clause 8.2.2 and clause 8.2.3 is through the ISO 9000:2005 definition of effectiveness, the "extent to which planned activities are realized and planned results achieved". Part of clause 8.2.2 calls for audits to determine if a system conforms to planned arrangements and is effectively implemented. Clause 8.2.3 says to take action when planned results are not achieved. So, clauses 8.2.2 and 8.2.3 both monitor process effectiveness and both expect correction and corrective action to be taken.

How Many Shalls?

Have you ever been asked how many requirements are in ISO 9001:2008? Well, one answer might be that there are 136 "shall" statements in the standard, spread across the five major clauses as shown below:

Clause 4: Quality Management System = 13
Clause 5: Management Responsibility = 15
Clause 6: Resource Management = 5
Clause 7: Product Realization = 67
Clause 8: Measurement, Analysis, and Improvement = 36

But, how do you count a "shall" with multiple sub-clauses? Should each sub-clause be viewed as a separate requirement? For example, look at clause 4.1, General Requirements. It has a total of five "shall" statements. However, one of the "shall" statements has six sub-clauses, identified as "a" through "f", each of which could be viewed as a unique requirement.

And, take a look at clause 6.3, Infrastructure. It has one "shall" statement, then in the next sentence, continues with a sub-clause list of items that could be considered as infrastructure examples, as applicable. So, how many requirements would you count for clause 6.3? One or four?

As you can see, coming up with a total requirement count for the standard is not an easy task, or a necessary one. What is important is that we are aware of the requirements, and conform to them, and not worry about the best way to count them.

AS9100C Differences

AS9100C Transition Plan

The International Aerospace Quality Group (IAQG) has proposed a 30-month transition timeline for existing certified organizations. However, due to the need for global harmonization and the release of supporting standards, the start date for transition had not been set (as of the date of this article).

A possible scenario could be:

January 2009:
AS9100C was released.

March 2009 - August 2009
(6 months for training providers to develop training for the new standard)

September 2009 - August 2010:
(12 months to train certification bodies and auditors)

September 2010 - August 2011:
(12 months for all companies to update to the new standard at their next surveillance or recertification)

The On-line Aerospace Supplier Information System (OASIS) database will be used to share IAQG expectations and track client transition activity via certification body issuance of AS9100C certificates. The AS9100C transition start date will be communicated via OASIS when it becomes available.

In regard to auditor training, the IAQG Other Party Management Team (OPMT) is developing sanctioned training for aerospace auditors. All Aerospace Auditors (AA, AEA, and AIEA) will be required to complete this supplemental training prior to conducting any AS9100C audits for certification purposes under the Industry Controlled Other Party (ICOP) process. This training will cover transition and client assessment to the AS9100 series of standards (9100, 9101, 9110, and 9120).

The Aerospace standard, AS9100:2009, Revision C, is available for purchase at the SAE web site (http://www.sae.org) for a member price of $48.00, or list price of $61.00. The standard can be ordered at the ASQ web site (http://www.asq.org) for a member and list price of $61.00.

AS9100C Differences

The differences in AS9100C versus AS9100B are described in my paper, Changes in AS9100C, that can be downloaded as a PDF file from our web site.

Additions based on the changes from ISO 9001:2008 are underlined and highlighted in the paper as yellow. Additions in the unique AS9100C parts of the text are underlined and highlighted in green. All the unique unchanged AS9100C text is shown in bold.

The underlining of new text will allow readers to spot the additions, even if the paper is printed without color. AS9100C and ISO 9001:2008 texts are shown inside boxes and in Italics to help separate the text from the comments. Deleted text from ISO 9001:2000 and AS9100B is indicated by strikethroughs.

Most of the text in AS9100B (and ISO 9001:2000) was not affected by AS9100C (and ISO 9001:2008). The unaffected parts of AS9100B, carried over unchanged into AS9100C, are not repeated in the paper.

Class Schedule

Root Cause Analysis

ISO 9001:2008
Understanding ISO 9001:2008
Implementing ISO 9001:2008
Quality System Documentation
ISO 9001:2008 Internal Auditor
ISO 9001:2008 Lead Auditor

ISO 14001:2004
Implementing an EMS
ISO 14001:2004 Internal Auditor
ISO 14001:2004 Lead Auditor

ISO/TS 16949:2002
ISO/TS 16949:2002 Internal Auditor
ISO/TS 16949:2002 Lead Auditor
Understanding and Implementing ISO/TS 16949:2002

Core Tools
Advanced Product Quality Planning
Design Failure Modes Effects Analysis
Process Failure Modes Effects Analysis
Production Part Approval Process
Statistical Process Control
Measurement System Analysis

AS9100B:2004
AS9100 Internal Auditor
Implementing AS9100
AS9100 Lead Auditor

ISO 27001:2005
ISO 27001 - Understanding an ISMS
ISO 27001 - ISMS Implementation
ISO 27001 - ISMS Internal Auditor
ISO 27001 - ISMS Lead Auditor

ISO 20000-1:2005
Understanding ISO 20000
Implementing ISO 20000
ISO 20000 Internal Auditor

ISO 22000:2005
Understanding ISO 22000
ISO 22000 Internal Auditor
Understanding HACCP
Implementing SQF Systems
Advanced HACCP

ISO 13485:2003
Understanding ISO 13485:2003
ISO 13485:2003 Internal Auditor
Implementing ISO 13485:2003
ISO 9001 Lead Auditor - ISO 13485 Emphasis

Capability Maturity Model Integration
Introduction to CMMI v1.2

Six Sigma
Introduction to Statistics
Green Belt Certification
Black Belt Certification

Books
See our list of ISO 9001, Auditing, and Six Sigma books. Includes book descriptions and links to Amazon.

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