Work Instructions and Audits

Chart, graph, sampling, plan, calculation, z1.4

Question

Regarding ISO 9001: 2008 (or 2015) auditing, I have always been trained that a work instruction when implemented as supporting the QMS can be audited as it is supporting the effectiveness of the QMS. I was recently told by a business owner that not only is that not true, he does not have to show me his work instruction.  I would like to reply with a clear technical response. Can anyone share their view on this?

Answers

Thank you for your question.   Of course you know you’re right.  It sounds like you have a major nonconformance against Clause 5.1 on your hands.

Denis Devos
A Fellow of the American Society for Quality
Devos Associates Inc.
(519) 476-8951
www.DevosAssociates.com

ISO 9001:2015 clause 7.5.1b states the following :
The organization’s quality management system shall include: documented information determined by the organization as being necessary for the effectiveness of the quality management system/

 Documented information includes both procedures and records see appendix A.3 (Documented information). 

 Since the work instructions are supporting the QMS, it is part part of the QMS, and can be audited as part of both the internal audit and external audit.  It appears that part of the confusion may be caused by a lack of understanding of the new term “documented information.”

John G. Surak, PhD
– Providing food safety and quality solutions –
tel: 1-864-506-2190
skype:  john.surak
email: jgsurak@yahoo.com
A member of Stratecon International Consultants
http://www.stratecon-intl.com/jsurak.html

Zero Acceptance Number Sampling Plans and the FDA

Pharmaceutical sampling

Question

There has been some debate over using the MIL-STD-1916 acceptance sampling plan over the ANSI/ASQ Z1.4-2003 (R2018) sampling plans.  The opinion is that the ANSI/ASQ Z1.4-2003 (R2018) is outdated and no longer an acceptable method of determining a qualification sample plan and the MIL-STD-1916 should be used in place of ANSI/ASQ Z1.4-2003 (R2018). Do you have information around this debate over which sampling plans are acceptable by the FDA?

Answer

FDA does not (and can not) tell you what sampling plan is to be used.  The FDA requirement is that the plan be statistically valid.  As long as you follow the regulation, you are meeting FDA requirements.

In medical device manufacturing the key point is to have the plan accept on zero defectives.  This point is not FDA but legalese.  It is based on past lawsuits.  The plan “Zero Acceptance Number Sampling Plans” by Nicholas L. Squeglia (available from ASQ) has been widely adopted for this reason.

ANSI/ASQ Z1.4 in not outdated and continues to be widely used.  It is the American National Standard Institute (ANSI) version of MIL-STD-105 which the government discontinued maintaining, allowing ANSI to maintain it along with many, many other MIL-STD’s as a government cost reduction.

MIL-STD-1916 can be used but it is not widely used because of its difficulty and practical use.

James Werner

For more about this topic, visit ASQ’s website.

AQL Clarifications

Automotive inspection, TS 16949, IATF 16949

Question

I am confused about the values used for AQLs. For example in Table II-A the AQL values range from 0.010 to 1000. Where do these values come from and what do they mean?

The table states, “AQLs, in Percent Nonconforming Items and Nonconformities per 100 Items .” At first I thought the values were percentages, but how can you have more than 100, as in 100%, as the values go up to 1000? Also how can there be more than 100 nonconformities per 100 items, unless one part can have multiple nonconformities?

Just looking for clarification on the AQL numbers, what they mean, and how to interpret them.

Answer

Let’s start with the definition of Acceptable Quality Level (AQL).  From Z1.4, the AQL is the quality level that is the worst tolerable process average when a continuing series of lots is submitted for acceptance sampling.  Although individual lots with quality as bad as the AQL can be accepted with fairly high probability, the designation of an AQL does not suggest that this is necessarily a desirable quality level. The AQL is a parameter of the sampling scheme and should not be confused with a process average which describes the operating level of a manufacturing process. It is expected that the product quality level will be less than the AQL to avoid excessive non-accepted lots.

The columns with percentages greater than 100% should not be included in the standard, but remain as indication of how to interpret lots where the entire sample is defective.  It has some statistical relevance with use of the switching rules, but for the general practitioner, it should be ignored.

Hope this helps.

Steven Walfish

DPMO

Inventory, Inspection, Review, Suppliers, Supplies

Question

My question concerns the process performance metric DPMO (defects per million opportunities). I want to use this to quantify a particular supplier’s performance. My question is, is the number of defects referred to in the calculation the number of defects produced by the supplier (in which case it would involve data I don’t have access to), or is it the number of defects experienced by the customer (which is us)? I of course can count the number of defects we receive from the supplier, but if this metric is supposed to be based on the number of defects produced by an organization, I would have no way of knowing how many defects are produced by the supplier’s process, but contained within the supplier’s facility. My hope is to be able to characterize the supplier’s process performance in terms of sigma level.
Answer

The DPMO metric is not usually considered a point estimate of the true percent defective in the lot (either at the supplier or customer site).  It is a relative performance metric used to equate the observed percent defective from a sample to defective units per million opportunities.  If a supplier culls out all the defective units before shipping to you (i.e. perfect inspection system), your internal DPMO would be 0, even if the supplier DPMO is high. If your goal is to characterize the supplier’s process performance in terms of sigma level, you would need their data, as the data you collect internally is just an estimate for the average outgoing quality from the supplier and not their process performance.

Steven Walfish

Here’s more about DPMO.

Document Revision Criteria

ISO documentation practices, requirements

Question

Is there any criteria available for the frequency of document revision in ISO 9001 or ISO 13485?  Some organization don’t revise the documents for a period of more than 2-3 years.  The reason provided by the organization is that there were no changes during this period. Do ISO standards mandate the revision of documents within a certain time frame? Can we treat this as non-compliance, if the documents are not revised over a period of 2-3 years ?
Answer

There are no criteria nor a requirement for document revision in ISO 9001:2015, 7.5.

ISO 13485:2016, 4.2.4, states, “review, update as necessary and re-approve documents.” This leave the review to the discretion of the organization.

Thus, there is no mandatory review frequency and no non-conformance if documents are not revised within a determined time frame.  ISO 13485 does require a review, however. But, the frequency of the review is not mandated.

George Hummel

Verification or Calibration?

Automotive inspection, TS 16949, IATF 16949

Question

There is a second part to 7.6 para “a” which reads; “where no such standards exist, the basis used for calibration or verification shall be recorded.” It is clear for shops that are complying to the ISO 9001:2008(E) we need to have measurement standards traceable to international or national measurement standards. My question has to do with cylindrical plug gages that are used at the machines to verify manufactured print dimensions. The pins/plug gages are not sent out at intervals for calibration however, they are compared to a traceable measurement standard before being issued to the manufacturing area. We consider these gages to be calibrated “as used ” and we do not record the initial actual size of the pins/plug gage but issue it only on the basis that the size was verified against a traceable measurement standard. Are we required per Para 7.6 to record the actual size of the pins/plug gages?

Answer

Thank you for your question.  What you are describing is verifying prior to use, rather than calibration.    If the rings or other standards being used to check these plug gauges each day are properly calibrated and traceable to national standards, you are compliant with ISO 9001:2015.  If you are registered to AS 9100 or TS 16949, stricter requirements will apply and you may not be meeting those requirements for recording variable results of calibration.

Denis Devos, P.Eng
A Fellow of the American Society for Quality
Devos Associates Inc.
(519) 476-8951
www.DevosAssociates.com

Clauses 8.4.1 and 8.4.2 in 9001: 2015

Mr. Pareto Head and IT

Question

The insurance company I am temporarily helping on quality is limiting its ISO 9001 certified perimeter to the administration of contracts and claims.
With regard to clauses 8.4.1 and particularly 8.4.2 of ISO 9001:2015, should the other internal entities of the company (.i.e HR, IT, Sales Dept, …) absolutely necessary but outside of the perimeter be considered exactly like external providers – just like a provider of IT, for instance – or should they be considered as internal providers with a limited control of their contribution to the QMS through a simplified SLA? Of course, SLAs will be put in place in order to secure the relationship of these internal entities with the perimeter.

I thank you in advance for your help/interpretation of clauses 8.4.1 and 8.4.2 applied to the case submitted.

Answer

Thank you for your question.   Yes, that is an appropriate interpretation, but let me add three comments.

Firstly, recognize that your support functions are captive within your organization and therefore not subject to all of the same conditions that would be imposed on an outside service provider.   For example, you can’t stop doing business with them if you are not happy with their service.  I like your idea for an SLA – keep it simple, but outline your requirements and expectations for their support services.

Secondly, use your process approach (clause 4.4) to define the boundaries of your QMS and how those other external departments interface with you.  This will be helpful in helping your team and others to understand the relationship between your QMS and the rest of the organization.

Thirdly, take advantage of the Context of the Organization analysis (clause 4.1) to further explore those relationships and that will help to determine the level of control you require over those support functions.

Denis Devos, P.Eng
A Fellow of the American Society for Quality
Devos Associates Inc.
(519) 476-8951
www.DevosAssociates.com

“Shall Be Determined” in 9001

Certification, ISO 9001

Question

Many of the Quality Management Systems requirements in the ISO 9001: 2015 manual include the verbiage “shall be determined.”  I need to be sure that I understand exactly what this means in this context.  For example, “4.4  QMS and its processes 4.4.1 a)  The inputs required and the outputs expected of the QMS processes are determined.”   Does this mean that there should be process or work instruction written describing this?  Does it mean that there should be documentation showing the development of this information?

Answer

Thank you for your question.  It might be useful to look at the definition of the word determine.  According to the Oxford Dictionary:  Determine means to “Ascertain or establish exactly be research or calculation”, Merriam Webster has a similar definition:  “to find out about or come to a conclusion about by investigation, reasoning, or calculation.

Now to your question.  There does not need to be a procedure about how things are determined.  The output, or the determination itself, will serve as evidence that you did it.  But determine things in an honest way.  You and your CB auditor will assess the reasonableness of your determinations based on the context of your organization.  For example, if you are a hospital, and you “determine” that surgeons do not need to wash their hands, you should be subject to a nonconformance for getting that wrong.    In your example, taken from clause 4.4, the best way to do this is to create a flowchart(s) showing a series of process steps and their interactions.  The arrows in and out of each box along with explanatory text, will demonstrate that you have determined the inputs and outputs of each process step.

Denis Devos, P.Eng
A Fellow of the American Society for Quality
Devos Associates Inc.
(519) 476-8951
www.DevosAssociates.com

Here’s more information about ISO 9001.

Approved Supplier List 17025 or 9001?

ISO/IEC 17025:2017 General requirements for the competence of testing and calibration laboratoriesQuestion

Every once and while our company will need to find a rare or hard to find item on the web. Due to the rarity of the item we sometimes need to look at sites that are not a typical supplier. So how would you go about approving a supplier such as Amazon or EBay since they are more like a distributor then a supplier and utilize a large pool of other retailers/sellers?

Answer

I think ISO 17025 is not the correct citing; ISO 9001-2015 Section 8.4. would be a better fit.

Approving a distributor is meaningless whether the distributor is Amazon or EBay.  The requirement is under Section 8.4.1 of ISO 9001-2015.  Consider that the supplier is the manufacturer of the item (product) being bought on the web.  The user needs to approve the use of that item – not the supplier. 

The last paragraph under Section 8.4.1 reads, in part: The organization shall determine and apply criteria of the evaluation, selection, and monitoring of performance, and re-evaluation of external providers, based on their ability to provide processes or products and services in according with requirements.  This means that the organization determines the requirements, documents those requirements, and follows the establish requirements.  The requirements here, I suggest, are to approve the supplier based on the supplied item meeting the organization’s needs – specifications.

For example, Home Depot or Lowes is a distributor (source) of a hex-nut that is infrequently used.  The hex-nut has a specification, thread size, length, etc.  The requirement then would be that an inspection of the hex-nut confirms it meets the predetermined requirements. This is all documented.

James Werner

Z1.4 Sample Size

Pharmaceutical sampling

Question

I am trying to determine the sampling size using my ANSI/ASQ Z1.4 table and I wanted to get some clarification. If I am using Table II A and my Sample Size Code letter is D, what would be my sample size? If it falls on an arrow does it mean that I have to change to the next sample size based on where the arrow points?

Answers

From Charlie Cianfrani:

If you are using Z1.4, your sample size is selected based on your lot size.  You would pick the AQL you need based on the risk you are willing to take for the process average of percent defective.  It is important to understand what you are doing when using sampling plans, what they are and the protection you are trying to ensure. Thus, the important step is to determine the AQL. Then you select the sample size to provide the level of protection you are striving to ensure. It is more important to understand the theory behind the tables than to mechanically use the tables.

From Fred Schenkelberg:

Use the sample size where the arrow points. In the 2008 and 2013 versions it explains this in section 9.4, “When no sampling plan is available for a given combination of AQL and code letter, the tables direct the user to a different letter. The sample size to be used is given by the new code letter, not by the original letter.”

From Steven Walfish:

The standard sample size for Code Letter D from IIA is a sample size of 8.  But depending on your AQL, a sample size of 8 would be inappropriate, so the standard has arrows to delineate alternative sample sizes to reach the target AQL.  So, you sample size and accept/reject values are changed.  For example, at an AQL of 0.25, you would move down to a sample size of 50, with an accept/reject of 0/1.  If the lot size is less than 50, you would need to do 100% inspection.  In other words, there is no sampling plan that can give an AQL of 0.25 without a minimum sample size of 50.

From James Werner:

Yes.  When using Z1.4 two items need to be known, lot size and the AQL (Acceptance Quality Limit).  You use Table I – Sample size code letters to determine the Sample size code letter based on the Lot or batch size.  In the question below that was determined to be “D”.  Next step is to use Table II-A to find the sample size related to the sample size code letter – D and the AQL.  On Table II-A go across the table’s row for letter D until it intersect the given AQL column heading.  If an arrow is in that intersection point, follow the arrow then go back to the sample size code letter column to find the actual sample size (if a up/down arrow is in there then you choose).

Example 1.  Code letter is D (as in the question below).  Let’s say the AQL is 0.25.  Starting at code letter D, move across that row until you intersect at the AQL 0.25 column.  There’s a down arrow this row/column intersection.  Follow the arrow downward until the “Ac Re” reads ” 0 1″.  Staying on this row go back to the Sample size code letter column and find Code Letter H and Sample size = 50.  This means for the lot size with code letter D and with an AQL of 0.25 the sample size = 50 and accept the entire lot if no nonconformances were found else reject the entire lot if 1 or more nonconformance were found in the sample.

Example 2.  Let’s say the Sample size code letter was determine from Table I to be “F”.  Looking at Table II-A; If the AQL = 0.65, then the sample size would be 20 and the lot would be accepted zero nonconformance.  But if the AQL = 0.15 then the sample size would be 80.

For more information on this topic, please visit ASQ’s website