ISO 9001 Statutory and Regulatory Requirements

About ASQ's Ask the Standards Expert program and blog

Q: I manage the quality management program at my company according to ISO 9001:2008 — Quality management systems –Requirements.  I was hoping to find some assistance in the area of statutory and regulatory requirements.  Can you provide me with some help in regards to what this means in terms of the standard?

A: Statutory and regulatory requirements are product related.  They may be federal, state or local.  They would depend upon your industrial classification.  Once you have that, you can cross check the classification with the Code of Federal Regulations (CFR).  Since the CFR are subject to change, someone in your organization should be charged with the responsibility for researching updates (there are organizations that provide this service). As far as international is concerned, the country of destination would need to be researched.  Often, a customs broker can be of assistance here.

George Hummel
Voting member of the U.S. TAG to ISO/TC 176 – Quality Management and Quality Assurance
Managing Partner, Global Certification-USA
www.globalcert-usa.com/
Dayton, OH

Related Content:

Imaging Core Lab Takes Quality Beyond Regulatory Requirements With ISO 9001, ASQ Knowledge Center case study, Open Access

Medical Metrics Inc. (MMI), had an existing quality management system structured to meet FDA regulations, but it was missing a framework to help drive organizationwide improvement. MMI worked with an external consultant to create an integrated management system—a fusion of regulatory requirements with the ISO 9001 framework—and received certification to the standard in less than seven months. Read More.

Sarbanes-Oxley And ISO 9000, Quality Progress, Open Access

Critics say ISO 9000 doesn’t compare favorably to quality programs such as the Baldrige criteria, lean and Six Sigma. But ISO 9001’s emphasis on documentation is a major asset from a legal perspective. Quality professionals can help companies comply with Sarbanes-Oxley while enhancing their organizational status. Read More.

Z1.4 and Z1.9 in Micro Testing and API Chemical Analysis

Chemistry, micro testing, chemical analysis, sampling

Q: I work at a cosmetics manufacturing company that produces sunscreen in bulk amounts. When we make 3,000 kg of sunscreen, we will use that in 10,000 units of final sunscreen products which will weigh 300 g each.

How many samples do I need to collect from the 10,000 units to pass the qualification?

The products need to pass both attribute and variable sampling tests such as container damage, coding error, micro testing, and Active Pharmaceutical Ingredients (API)  failure. Almost 100 percent of final products were inspected for appearance error, but a small number of them should be measured for micro testing and API chemical analysis.

For Z1.4-2008: Sampling Procedures and Tables for Inspection by Attributes, we have to collect a sample of 200 (lot size of 3,201-10,000; general inspection level II;  acceptable quality level 4.0 L), and more than 179 should pass for qualification.

For Z1.9-2008: Sampling Procedures and Tables for Inspection by Variables for Percent Nonconforming, we have to collect a sample of 25 (lot size of 3,201-10,000; general inspection level II; acceptable quality level 4.0, L), to meet the requirement of 1.12 percent of nonconformance.

Which sampling plan should we follow for micro testing and API chemical analysis?

A: If the micro test is pass/fail, then you should use Z1.4. The API chemical test  probably yields a numerical result for which you can calculate the average and standard deviation. Then, the proper standard to use is Z1.9. If the micro test gives you a numerical result, then you can use Z1.9 for it as well.

One thing to consider is the fact that the materials are from a
batch. If the batch can be assumed to be completely mixed without settling or separation prior to loading into final packaging, then the API chemical test may only need to be done on the batch, not on the final product. Micro testing, which can be affected by the cleanliness of the packaging equipment, probably needs to be done on the final product.

Brenda Bishop
U.S. Liaison to TC 69/WG3
ASQ CQE, CQA, CMQ/OE, CRE, SSBB, CQIA
Belleville, Illinois

Related Resources:

Getting the Right Data Up Front: A Key Challenge, Quality Engineering, open access

Rational decisions require transforming data into useful information by appropriate analyses. Such analyses, however, can be only as good as the data upon which they are based. In this article, the authors urge that careful consideration be given, up front, to procuring the right data and provide some guidelines. Read more.

A Graphical Tool for Detection of Outliers in Completely Randomized, Unreplicated 2k and 2k-P Factorials, Quality Engineering, open access

With the increased awareness of statistical methods in industry today, many non-statisticians are implementing statistical studies and conducting statistically designed experiments (DOEs). With this increased use of DOEs by non-statisticians in applied settings, there is a need for more graphical methodologies to support both analysis and interpretations of DOE results. Read more.

ISO 9001: Product Development and Customer Satisfaction

Manufacturing, inspection, exclusions

Q: Does a company certified to ANSI/ISO/ASQ Q9001-2008 Quality management systems — Requirements that produces raw materials for a customer according to their written specification also, as a raw material supplier, have a responsibility under ISO 9001 to meet the customer’s needs for their design intent and intended and known use?

In simple language, I sell a raw material to a customer who takes my raw material and then designs a product and sells it to a customer who uses it in the field. I wonder where does the ISO standard application stop for the raw material supplier?  How can a raw material supplier under ISO 9001 meet the needs of a customer’s trade secret designs, or further down the intended use of the product where the raw material supplier has no control over how it will be used or maintained?

A: Your question is more a legal one than a quality one. You are offering a product to a customer. This is your finished product and their raw material. When both parties agree to the terms and conditions (payment, form, fit, function, shipping, etc.) a contract exists. We call this a purchase order (PO) and part of that PO is the specification for your product. If they place an order to your spec, you have done the design work under ISO 9001 and they are accepting your design. END OF YOUR RESPONSIBILITY for future application and use. If you accept an order to their spec, they have done the design work and you are obligated to make sure your product meets the stated (and often implied) form/fit/function requirements. We call this quality control and you do this by testing in the lab prior to shipment.

Most firms address the issue of application by stating quite clearly in the contract terms that you are selling your product as-is and you do not warrant the product as fit for ultimate use. This is the kind of thing the lawyers require.

Having said all this, there is a requirement in ISO 9001 for you to measure customer satisfaction. You must state in your manual the concept (strategies) for doing this and have some defined processes – usually called procedures – to carry it out. Of course, part of this is the regular management review. Quality, marketing, and sales all provide input on how well the customer needs are being met. Your registrar should be examining how you do this.

If there is a trend showing that customers are unhappy with how the stuff performs under end-use conditions, ISO says you should address those issues. (Ignoring them is an option, if it is deliberate). Mature firms will work on building customer-supplier partnerships, getting their engineers to talk to your engineers. Although this is technically outside of the quality function, it is still part of your overall quality management system.

Charlie Cianfrani
Consulting Engineer
Green Lane Quality Management Services
Green Lane, PA
ASQ Fellow; ASQ CQE, CRE, CQA, RABQSA Certified QMS-Auditor (Q3558)
ASQ Quality Press Author
Related Content:

Open access resources about supplier quality and product development:

Two Sides of the Same Coin: Using Teams in Customer-Supplier Relationships, Journal for Quality and Participation

In the Know: A BoK dedicated to quality in outsourcing is essential in today’s global marketplace, Quality Progress

The Role of Quality Management Practice in the Performance of Integrated Supply Chains, Quality Management Journal

Has Information About Quality Become a Liability? Quality Progress

Product Liability: Beyond Loss Control — An Argument for Quality Assurance, Quality Management Journal

Quality in Radical Innovation

Employees, Training, Working, Learning, Duties, Tasks, DFSS, Innovation

Question

Design for Six Sigma (DFSS) involves the discovery, development, and understanding of critical to quality areas and fosters innovation. However, studies have shown that using focus groups, interviews, and etc., based on current users only bring forth ideas relative to incremental innovation, as the only knowledge that most customers have is of current products. But we know that the greatest potential for return is in radical innovation.

My question is: what useful tools are there for determining critical to quality areas of radical innovation products, or products that are new to market where customers have little to no knowledge of?

Answer

These are great questions that are not easy to answer as posed.

One of the dilemmas I’ve seen with companies building radical innovation without enough knowledge to identify the important quality aspects is that the company is often under intense pressure to get to market. In some cases, the innovation presents clear aspects that have to be controlled to create an acceptable product. In some cases, the issues are unknown.

I do not agree the work within a group only reflects the knowledge already present. One of the best tools in these situations is carefully crafted questions posed to those most familiar with the new technology. Given my personal bias, I would ask: “What will fail? Why?” and then ask about material, process, and feature performance variation. Focusing on the failure mechanisms and variation will often lead the team to uncover those aspects of the product that require well crafted specifications and monitoring.

Not a fancy tool, just a question or two. Yet, the focus is on what will cause the innovation to not meet the customer’s expectations. What could go wrong? Make it visible, talked about, and examined. Creating a safe atmosphere (no blame or personal attacks) to explore failure permits those most vested in making the product work examine the boundaries and paths that lead to failure.

Once the process of safely examining failures starts, a range of tools assist with the refinement and prioritization. Failure Modes and Effects Analysis (FMEA) and Highly Accelerated Life Testing (HALT), provide means to further discover areas to explore the paths to failure. I mention creating a safe environment first, because using FMEA and HALT when someone’s reputation or status is threatened generally leads to these tools being very ineffective.

One more thought on a safe environment for the exploration of failures. Focus on the process, materials and interaction with customers and their environment. “How can we make this better, more resilient, more robust, etc.?” Not, “Why did you design it this way?” or, “This appears to be a design mistake.” All involved have the same goal to create a quality product or service, yet there may be a lot unknown related to those conditions that lead to product failure. An open and honest exploration to discover the margins and product weaknesses is most effective in a safe environment for those concerned. And, by the way, this includes vendors, contractors, suppliers, and all those involved with the supply chain, development and manufacturing processes.

Fred Schenkelberg
Voting member of U.S. TAG to ISO/TC 56
Voting member of U.S. TAG to ISO/TC 69
Reliability Engineering and Management Consultant
FMS Reliability
fmsreliability.com

Editor’s note: Want to read more about innovation?

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Calibration of AutoCAD Software

About ASQ's Ask the Standards Expert program and blog

Q: To what extent must an engineering firm, specializing in railway infrastructure and transportation, have its AutoCAD software “calibrated” or verified?

Also, what about software designed to calculate earthwork quantities for railway alignments laid out on topographic mapping for all levels of studies – pre-feasibility through preliminary engineering (not for final design, operation simulation and design dynamic system models)? This type of software is utilized by competent draft persons and engineers, but it is not verified prior to use or periodically calibrated.

We don’t confirm “the ability of computer software to satisfy the intended application…”

Your assistance or reference is appreciated

A: AutoCAD is considered “Commercial -Off-The-Shelf” (COTS) software. It is purchased without modification and cannot be modified by the end-user. A similar example would be Excel spreadsheet software. The COTS software by itself should be considered validated and used as is provided it is configured per the software manufacturer’s instructions.

The functionality of the software (distance, volume, formulae and other functions) is fit to be used as intended. If an application is created using COTS software (Excel Templates, AutoCAD applications), then it must be validated and records of validation must be kept.

It should also be noted that definitions of verification and validation are not clearly understood. So, I am repeating them here:

ISO/IEC Guide 99:2007—International vocabulary of metrology—Basic and general concepts and associated terms, defines these terms as:

Verification: provision of objective evidence that a given item fulfills specified requirements

Validation: verification, where the specified requirements are adequate for an intended use

Further explanation:

Validation is a quality assurance process of establishing evidence that provides a high degree of assurance that a product, service, or system accomplishes its intended requirements. This often involves acceptance of fitness for purpose with end users and other product stakeholders.

It is sometimes said that validation can be expressed by the query “Are you building the right product?” and verification by “Are you building it right?”

“Building the right thing” refers back to the user’s needs, while “Are we building the product right?” checks that the specifications are correctly implemented by the system. In some contexts, it is required to have written requirements for both as well as formal procedures or protocols for determining compliance.

Dilip A Shah
ASQ CQE, CQA, CCT
President, E = mc3 Solutions
Chair, ASQ Measurement Quality Division (2012-2013)
Secretary and Member of the A2LA Board of Directors (2006-2014)
Medina, Ohio
www.emc3solutions.com

Does ISO 9001 Clause 7 Apply to Processes?

Manufacturing, inspection, exclusions

Q: Does clause 7 Product Realization in ISO 9001:2008 Quality management systems–Requirements apply to the design and development of manufacturing processes?

We have four facilities that are ISO 9001 certified under one certificate. One location designs the product, and the other facilities manufacture it. In the “design facility” we follow the requirements of clause 7. In the manufacturing facilities, we currently do not apply clause 7 for the process of developing the manufacturing processes.

A: ISO 9001 clause 7.3 is applicable to the design and development characteristics of a product.

ISO 9001:2008 clause 7.1 (Planning of Product Realization) and its reference to clause 4.1 (General Requirements) is more specific to product planning to ensure that the product quality objectives and the processes/resources are available to produce a product that will meet defined quality requirements as specified during design and development in clause 7.3.

Clause 7.1 requires that the planning process include identification of the inter-related processes (i.e., monitoring, inspection, product quality objectives, testing, records of conformity needed to verify the product requirements have been achieved.

The bottom line:  the product characteristics, quality objectives and inter-related processes must be documented.  If this is not fully achieved in the design and development process (clause 7.3), it must be included in the product planning process (clause 7.1). Please see clause 4.1.

Please keep in mind that your company’s ISO registrar will require evidence of conformity (records/documentation) to verify the requirements of clauses 4.1, 7.1 and 7.3 have been met.

Bill Aston
ASQ Senior Member
Managing Director of Aston Technical Consulting Services
Kingwood, TX
www.astontechconsult.com