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Performing work outside scope

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Sam Tillman Created:   Apr 06, 2023 Last commented:   Apr 06, 2023

Performing work outside scope

One of our AS900 location (we will call them "TMT") is listed on our AS9100 certifications with only service scope. TMT is considering doing manufacturing work within our facility for another one of our divisions (RMS) which has a different AS9100 certificate, and TMT is Not listed on their As9100 certificate. 
Questions are:
We have our recertification audit in June,
1. If TMT does the manufacturing work for RMS can our 3rd party auditors look at this process and audit it during our upcoming recertification audit? 
2. Can our 3rd party auditors write us a nonconformance for TMT not having manufacturing under our scope even though they aren't doing work for our Site for us but the work will be performed in our facility? 
3. Should we, or are we required to request an exclusion for our upcoming recertification audit for this portion of the work even if the work isn't for our division (but work will physically be performed within our site)?. 
4. Other than clause 4.3 determining the scope, what other clauses would apply to this unique situation? 
5.  If RMS is considering TMT their supplier, is TMT still required to have a scope with manufacturing listed?

 6.If TMT does this work what kinds of things are they not allowed to use belonging to our site?  I'm assuming the other site is responsible for providing all the tools, gages, resources, work instructions, for the other site.  
7.  Should they add manufacturing in their scope under our certification or does it matter?  
7.  Any other concerns I should have?

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Mark Hammar Apr 06, 2023

When the auditors are auditing a site, they are only to audit within the scope of the management system, and anything else is excluded from the audit. As a bit of a ridiculous example; if you were making aircraft parts under your scope, but also had a part of your facility that made and sold Ice Cream Cones, you wouldn’t expect the ice cream cone part of the business to be audited as it is not part of the scope.

So, that being said, in answer to your questions:

1. The 3rd party auditors should not look at something outside of your scope.

2. If they are not auditing it, it should not be a nonconformity. Nonconformity is only within your scope.

3. This will depend on how your scope is written. If you have said “all activities at this address” then you would need to exclude this.

4. For TMT the scope consideration would be all you should need to consider.

5. RMS needs to ensure their suppliers, and outsources processes, meet the requirements of their QMS. So, if RMS requires certification of the organization doing work, then it is on them to ensure suppliers meet their needs. This all comes down to how RMS controls their suppliers, and doesn’t affect TMT (unless RMS needs TMT to have this in their QMS scope).

6. This question of providing resources is not within the scope of the audit. You can give resources to whomever you want, but it might be easier to ensure control if you do as you indicated.

7. Again, adding manufacturing to your AS9100 QMS scope is completely up to you, depending on what RMS needs for their suppliers.

8. I can’t think of any concerns, as long as you mee the quality requirements of your customer (RMS) this shouldn’t affect your audit.

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Sam Tillman Apr 06, 2023

Excellent response, very well written, clear and concise.  Thank you for your support!  

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