AS9100:2009 (Rev. C) is now fully released with the advent of AS 9104/1, the AS9100:2009 (Rev. C) interpretation guideline document for registrars.
Clients will see changes relating to audit days and site/certificate structure, compliance to Internal Tracking of Arms Regulations (ITAR), and Export Administration Rules (EAR), and a closer focus on internal auditing.
Major changes to AS9104/1 address audit days and site/certificate structure. ASR has begun the process of evaluating all existing AS9100:2009 (Rev. C) contracts to determine that the certificate structure is defined and documented correctly, and the new audit day table is applied correctly. These new rules affect all audits occurring after January 1, 2013.
It is important to note that the IAQG/AAQG have put into place these new requirements without allowance for deviation. The goal is to calibrate all registrars so that there is no variation in audit duration regardless of which registrar conducts an audit. Additionally, OASIS will have new controls in place so that if incorrect certificate structure or audit days are entered, the audit will be rejected and will require correction by the registrar and client.
As the implementation process rolls out, there will be additional changes that may impact our clients. We will notify affected clients as these changes take place.
New revisions to AS9100:2009 (Rev. C) include the International Tracking of Arms Regulations (ITAR) and Export Administration Rules (EAR). Client companies will be expected to comply with these new rules if they are appropriate. All third-party AS9100 auditors are now charged with auditing the effectiveness of a supplier's ITAR/EAR compliance. This is an important legal requirement that organizations will need to be aware of during their contract review process.
Another objective is robust quality management systems. Standard writers want aerospace suppliers to beef-up their internal auditing so that suppliers find non-conforming issues rather than third-party auditors.
Specifically, the rewrite of AS9100:2009 (Rev. C) and the registrar guideline AS 9104/1 sets criteria for third-party auditors to take a closer look at the following with regards to internal auditing:
- How does the internal audit team measure effectiveness? Third-party auditors will focus on metrics such as improved quality, an improved quality management system, on-time/schedule, and budget costs.
- How did the internal audit team perform (outputs)? Third-party auditors will look for well-written audit reports including succinctly written corrective action statements; acceptances of good corrective action with follow up internal audits for effectiveness. They will look for evidence that internal auditors are competent and did any auditor audit their respective area.
- How did inputs match up to outputs? In other words, does the internal audit program meet all requirements of the AS9100 standard?
- How did the internal audit plan for effectiveness? This addresses audit planning, including previous audit results and metrics.
The rework of AS9100:2009 (Rev. C) and the accompanying interpretation guideline AS 9104/1 is directly aimed at quality management system improvement of the aerospace-supplier base. What was acceptable in the past is no longer
acceptable. Beginning in 2013 aerospace suppliers can expect to be held to higher quality management system standards.