Registration Management Committee (RMC)
Lessons Learned and Corrective
Action from IAQG’s RMC Oversight
Assessment in Montreal
Will Tate / Robert Flaharty
Triumph Group / Spirit AeroSystems
January 16, 2014
Company Confidential
Other Party (OP) Assessor Workshop
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
Objectives
• Overview of the Americas Sector Audit conducted in
Montreal, October 2013
– Findings
– Opportunity for Improvements
– Strengths
– General Comments for AAQG
– Feedback for IAQG OPMT
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
Oversight Requirement
Oversight of all entities of the ICOP (Industry Controlled
Other Party) process is required as defined in 9104/1
and 9104/2 Aerospace Standards
 Complete an oversight of each SMS, as defined in the 9104/2
standard (AS9104/1, sec. 13.2a)
 Provide a mechanism for a periodic review of the lessons learned
by each of the IAQG sectors. (AS9104/1, sec. 13.2b)
West Palm Beach, FL- January 16, 2014
Palm Beach Gardens, Florida
January 16, 2014
Registration Management Committee (RMC)
SUMMARY OF OVERSIGHT
• Overall the AAQG SMS Oversight was successfully
completed as required
• 1x Major and 4x Minor Non-conformances were raised
• In addition, a further 16x Opportunity For Improvements
(OFI’s) were identified
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
Summary of Findings
1. Minor – Delegation of responsibility for Auditor ReAuthentication
2. Minor – Timely closure of oversight NCR’s
3. Major – Correct application of the definition of
Aerospace Audits to all AEA Re-authentication
applicants
4. Minor – Oversight reports are not correctly
documented or that records of oversight are
maintained
5. Minor – Conflicts of interest are not assessed and
effectively managed for oversight teams
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
AAQG # 01 (Minor):
• It was not demonstrated that the currently documented arrangements
effectively reflect the current arrangements for the control of the AAQG
RMC auditor authentication activity as follows:
– Auditor re-authentication review and decision-making are subcontracted
from the RMC Auditor Review Committee to the respective AAB’s, RABQSA
and INMETRO however the arrangement is not documented (ref: RMC Proc.
103)
– Arrangements for the retention of auditor authentication or re-authentication
records are not documented.
– Procedure 103 was not demonstrated to be effectively implemented as the
date of release was indicated as a draft
• In considering Procedure 103, the AAQG RMC may wish to review the
division of responsibilities between the industry and the subcontract
AAB to clearly document that the responsibility of auditor
authentication and re-authentication decision-making is defined as
being with either the RMC Auditor Review Committee voting members
or with the subcontract AAB
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
AAQG # 01 (Minor):
cont
Corrective Action:
The RMC 103 Procedure will be corrected to reflect the current revision’s
release date by 1, Dec 2013 and a memo will be sent to the America’s
AABs (INMETRO and Exemplar Global, formally RABQSA) defining the
delegation of re-authentication approval of existing auditors by the
auditor review team chair by 18 Dec 2013.
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
AAQG # 02 (Minor):
• The AAQG RMC was not able to demonstrate the timely closure of
oversight NCR’s in all cases (ref: 9104/2 Appendix J timescales)
Corrective Action:
• Update RMC Procedure 102 to include escalation process and more clearly define the roles and
responsibilities of the process for escalation and oversight of the RMC for status of open
issues.
• With the release of AS9104-002 (2013) there will be a documented requirement for escalation
after 90 days when issued during independent oversight in paragraph 7.15.2 b: for “shared” or
supplemental.
• The subject of closing and elevating NCRs over 90 days will be presented as a topic for future
OP Assessor Training Workshops.
• Oversight Chair will monitor for closure/status of open issues and present during closed RMC
meetings.
•
ANAB documented an internal NCR in August for having 2 AB issued NCR’s (to CB’s) that went
beyond 90 days and we did not move to suspend, as required. ANAB’s corrective action was to
modify our process and require a 75 day response from our CB’s on all AQMS minor NCR’s (All
Major NCR’s are already at 60 days for response), this allows 2 weeks for any “back and forth”
that may be needed. This is documented in their newly released Accreditation Rule 29
(AR29). Their EQM System workflow now flags its coordinators at day 75 and they in turn
notify Bob Cruse of any that are nearing the 90 day mark so they can begin assembling an
appeal panel to convene on (or as near as possible) the 90 day deadline.
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
AAQG#03 (Major):
• It was not demonstrated that in all cases that RABQSA, as the AAB for
the AAQG RMC, is correctly applying the definition of Aerospace Audits
to all AEA Re-authentication applicants.
• This finding is a recurrence of AAQG Oversight finding from May 2011.
No evidence was available to demonstrate that corrective action from
the May 2011 finding had been effectively implemented.
Corrective Action:
The RMC auditor review team will provide a follow-up review with
Exemplar Global personnel on the correct type of audits to be included
with auditor authentication and re-authentication documentation
packages. The Auditor review team will perform periodic random checks
of re-authenticating auditors, by requesting that their re-authentication
documentation be forwarded to the auditor review team for review of
their audit logs. The Auditor review team will request that AB auditors
that have been recently re-authenticated, have their documentation
reviewed by the auditor review sub team of at least 2 RMCAR members.
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
AAQG # 04 (Minor):
• It was not demonstrated that in all cases oversight
reports are correctly documented or that records of
oversight are maintained and made available for
oversight of the SMS.
Corrective Action:
• Review documents to verify if the records requirement is
clearly stated and the location and process for storing is
identified.
• Communicate the records requirement at the upcoming OP
Assessor workshop. Established a secure RMC website for
records retention. Access limited to RMC voting members.
• Review current process and update RMC procedure 102.
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
AAQG # 05 (Minor):
• It was not demonstrated in all cases that conflicts of
interest are assessed and effectively managed during
the deployment of oversight teams conducting oversight
on behalf of the AAQG RMC.
Corrective Action:
1. Revise RMC procedure 102 to be clear on definition of
"Conflict of Interest" as it relates to auditing AAB, CB, TPAB or
AB. Procedure 102 to match requirements defined in to-be
released AS9104-002.
2. Declare in advance to the auditee any potential conflicts and
obtain permission to proceed prior to conducting the audit.
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
SUMMARY OF FINDINGS – OFI’s
• OFI#1: Guidance for Travel Policy (for OP Assessor Oversight) is
informally documented but may benefit from being formally covered in
Procedure 102 Oversight or stand-alone procedure
• OFI#2: AAQG RMC may benefit from maintaining a record of the
approved AAB/TPAB procedures (with Rev status) for their approved
AAB & TPAB subcontractors
• OFI#3: Upon implementation of 9104-002 , the AAQG RMC may
benefit from re-issuing current Form A & B’s to reflect any
changes associated with implementation
• OFI#4: AAQG RMC may benefit from updating Procedure 102 to
reflect the current operating practice i.e. excluding CB, TPAB
and AAB representatives from the Surveillance Sub Team
• OFI#5: The AAQG RMC benefit from introducing a documented process
to ensure that 9104-002 Form A’s (previously Annex I’s) are renewed
after 3 years
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
SUMMARY OF FINDINGS – OFI’s
• OFI#6: It was not demonstrated how the AAG RMC recognise
stakeholders from other CBMC’s and IAQG Sectors e.g. AB’s, AQMS
Auditors, TPAB’s, CB’s, TP’s and Training Courses
• OFI#7: The recorded Objective evidence for CB Head Office ASA April
2013 was considered minimal and would benefit from including more
detailed objective evidence
• OFI#8: The AAQG RMC may benefit from maintaining a record of ICOP
related implementation fees e.g. Auditor Authentication fees etc
• OFI#9: Procedure 102 should clearly define the process for the
management and escalation of NCR’s for independent OP Assessor
Oversights e.g. OP Assessor contacts AB to escalate etc
• OFI#10: Procedure 103 needs to reflect that RMC Auditor Review
Committee makes a recommendation which is then endorsed by the full
RMC
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January 16, 2014
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Registration Management Committee (RMC)
SUMMARY OF FINDINGS – OFI’s
• OFI#11: Procedure 101 should include a statement to ensure
‘Rights of Access’ to all stakeholder data
• OFI#12: The AAQG RMC should ensure that it maintains
documented records of the decision making process (vote) for
suspension or withdrawal of approval for a stakeholder e.g.
AAB etc
• OFI#13: AAQG RMC should consider introducing a Document
Register that records all relevant scheme procedures and
forms, including revision status
• OFI#14: The AAQG RMC may benefit from increasing the
duration for the 2013 Oversight to increase the effectiveness of
the Office Oversight of INMETRO as the 2012 was 1 day
covering both AB & AAB activity
• OFI#15: The AAQG RMC may benefit from maintaining a list of
attendees for OP Assessor Workshop Training courses.
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
SUMMARY OF FINDINGS – OFI’s
• OFI#16: The current AAQG TP List published in OASIS,
managed by RABQSA on behalf of AAQG RMC, contains a
number of approved Training Courses which are not listed in
9104-003 e.g. ‘AQMS Foundation (Tailored)’ performed by SAI
Global, AS9100 Standard Blended performed by Gladhill
Associates International etc; the AAQG RMC may benefit from
updating this List to only reflect approved Training Courses
relevant to the ICOP scheme
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
STRENGTHS IDENTIFIED
• Strong committed team of RMC members actively
supporting the ICOP scheme in AAQG
• Use of CB Report Cards to focus CB improvement
• Strong working relationship with ANAB performing joint
CB Oversights
• Co-operation and assistance of the AAQG Auditee’s
throughout this oversight with a genuine commitment to
improve their processes.
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
GENERAL COMMENTS FOR AAQG
• AAQG RMC must ensure they apply the lessons learned with
RABQSA to future AAB/TPAB activities – ultimately the RMC is
responsible for the performance of its subcontracted activities!
• Consider performing an annual self SMS assessment using an
independent OP Assessor
• Beware of potential Conflicts of Interest and how you manage
them effectively
• For future AAQG Oversight, it is requested that the RMC
ensures greater support from their stakeholders e.g. ANAB,
RABQSA and INMETRO
• It was identified that the 9104-001 Transition approval of
INMETRO was not completed in accordance with SR002
timescales and suspension was not initiated in due time;
however since the transition has now been completed, no NCR
is being raised at this time.
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
General feedback for IAQG OPMT
• Needs to be stronger in monitoring SMS Oversight NCR’s
and ensuring these are closed in a timely manner
• Must consider performing SMS Oversight in the week
before the IAQG OPMT F2F meetings or as a totally
separate activity
• Consider having a more dedicated OP Assessor team to
conduct the Oversights – this would ensure a consistent
approach and might help to introduce common practices
• SMS Oversight provides an excellent opportunity to learn
from other SMS on different approaches, identify best
practice etc
• OASIS changes – functionality to be amended to show
Suspension date for AAB/TPAB
Palm Beach Gardens, Florida
January 16, 2014
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Registration Management Committee (RMC)
General observations by the RMC team
• Validate representation by all Americas required entities for the entire
duration of the audit
• RMC should establish a records administrator for RMC records
management
• Validate availability of all records 2 weeks prior to the audit date
• Establish a minimum of 2 audit teams and designate a facilitator to
track down items as required
• Track closure of audit CAs as part of our Action itemstime log
• RMC should conduct semi-annual internal audits (Jan/Jul)
• Establish a timeframe for submitting completed oversight records for
retention
• Ensure all entities approved by the RMC have records retained that
show evidence of the approval (specify where all records will be
retained)
•
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January 16, 2014
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Registration Management Committee (RMC)
Robert Flaharty – Spirit Aerosystems Wichita, KS
•
30 Years working in Supplier Quality
•
Supplier Audits, Source Inspection, Corrective Action
•
Systems Development
.
Will Tate – Triumph Group, Dallas, TX
•
35 Years working in Aerospace & Defense
•
15 Years Engineering, 20 Years QA and Process Improvement
•
Supplier QA, QMS, QA information systems
.
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January 16, 2014
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Registration Management Committee (RMC)
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January 16, 2014
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