Combating Contamination

Workplace safety, OHSAS 18001, work environments

Q: We want to ensure that we are receiving clean containers to package our products. How can we improve our incoming inspection process?

A: You should encourage your vendor to ship only clean containers. Then, be sure that the shipping and receiving process doesn’t cause contamination. If you can determine the source or sources of the contamination, the best fix is to remove the cause.

If that approach is not possible and you have incoming containers that may have some contamination, then consider the following elements in creating an efficient incoming inspection process.

1) How do you detect the contamination?

Apparently, you are able detect the container contamination prior to filling them, or are able to detect the effect of the contamination on the final product. Given that you are interested in creating an incoming test, let’s assume you have one or more ways to detect faulty units.

As you may already know, there are many ways to detect contamination. Some are faster than others, and some are non-destructive. Ideally, a quick non-destructive test would permit you to inspect every unit and to divert faulty units to a cleaning process. If the testing has to be destructive, then you’ll have to consider lot sampling of some sort.

There are many testing options. One is the optical inspection technique, which may find gross discoloration or large debris effectively. Avoid using human inspectors unless it’s only a short term solution, as we humans are pretty poor visual inspectors.

Another approach is using light to illuminate the contamination, such as a black light (UVA). Depending on the nature and properties of the contamination, you may be able to find a suitable light to quickly spot units with problems.

Another approach, which is more time consuming, is conducting a chemical swab or solution rinse and a chemical analysis to find evidence of contamination. If the contamination is volatile, you might be able to use air to “rinse” the unit and conduct the analysis. This chemical approach may require specialized equipment. Depending on how fast the testing occurs, this approach may or may not be suitable for 100 percent screening.

There may be other approaches for detecting the faulty units, yet without more information about the nature and variety of contamination, it’s difficult to make a recommendation. Ideally, a very fast, effective and non-destructive inspection method is preferred over a slow, error prone, and destructive approach. Cost is also a consideration, since any testing will increase the production costs. Finding the right balance around these considerations is highly dependent on the nature of the issue, cost of failure, and local resources.

2) How many units do you have to inspect?

Ideally, the sample size is zero as you would first find and eliminate the source of the problem. If that is not possible or practical, then 100 percent inspection using a quick, inexpensive, and effective method permits you to avoid uncertainties with sampling.

If the inspection method requires lot sampling, then all of the basic lot sampling guidelines apply. There are many references available that will assist you in the selection of an appropriate sampling plan based on your desired sampling risk tolerance levels.

Another consideration is the percentage of contaminated units per lot. If there is a consistent low failure rate per lot, then lot sampling may require relatively large amounts of tested units. You’ll have to determine the level of bad units permitted to pass through to production. Short of 100 percent sampling, it’s difficult (and expensive) to find very low percentages of “bad” units in a lot using destructive testing.

3) Work to remove original source(s) of contamination to permit you to stop inspections.

I stress this approach because it’s the most cost effective in nearly all cases. In my opinion, incoming inspection should be stopped as soon as possible since the process to create, ship and receive components should not introduce contamination and require incoming inspection to “sort” the good from the bad.

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

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

Can We Require ISO 9001 Certification?

Suppliers, supplier management

Q: My company has bought another company in Canada and we are outsourcing to them. They are not certified to ISO/ANSI/ASQ 9001:2008 Quality management systems–Requirements.  Do we have the legal right to require them to get certified since we are?

A: Thank you for contacting the ASQ Ask the Experts Program.  With regard to your question, there is no requirement in ISO 9001 that requires any organization or their suppliers to be certified by a third-party. Certification is only needed if it’s required by a customer contract/purchase order, or if an organization has opted to be ISO 9001 certified.

However, as an ISO 9001 certified organization, your quality management system must include controls to maintain control over outsourced processes. This requirement is stated in clause 4.1. The control over outsourced processes may include all or any of the following:

1.    Use of an approved suppliers list (see clause 7.4.1)

2.    An onsite supplier quality audit (see clause 7.4.3)

3.    Review and approval of equipment, processes, procedures, methods, and personnel qualifications for processes that require validation such as welding, nondestructive testing, heat treatment or others (see clause 7.5.2).

In summary, ISO 9001 certification is a management decision and not a requirement.  Organizations that follow the ISO 9001 requirements and have outsourced processes should have controls in place to manage those processes.

I hope this helps.

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

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

“As Found” Calibration Data – Available for a Fee?

Automotive inspection, TS 16949, IATF 16949

Q: I have been an auditor of ISO/ANSI/ASQ 9001:2008 Quality management systems–Requirements since 1992 and recently began consulting hospitals who seek ISO 9001 certification.

My experience with auditing to ISO 9001 is mostly in the manufacturing sector. When I audited against ISO 9001 clause 7.6 control of monitoring and measuring equipment, I routinely included questions regarding the process for assessing the validity of previous measurement results when equipment did not conform to established limits. I found no real issues with this until lately.

Now, clients say that calibration service providers do not routinely provide “as found” data in the report that’s sent to clients/customers. I have been told that “as found” data only becomes available to the client/customer for an additional charge (and it’s not cheap).

Obviously, organizations cannot comply with the ISO 9001 requirement to perform the aforementioned assessment without this data. Since this has only come to my attention recently, I am wondering about the ethics and legality of withholding specific information in the calibration report – unless an additional fee is paid.

Could you please provide some insight or justification for this business practice?

A: It is always a good idea to evaluate one’s suppliers. This requirement is in ISO 9001 clause 7.4 purchasing. The May 2010 Quality Progress Measure for Measure column, “Supplier Demand,” provides guidance on evaluating and selecting calibration providers accredited to ISO/IEC 17025-2005: General requirements for the competence of testing and calibration laboratories. In addition, the ILAC-P14:12/2010 policy document requires ISO/IEC 17025 accredited laboratories to provide measurement uncertainty data with the measurement results as of December 1, 2011.

The customer should specify their requirements in their purchasing documents for calibration. ISO/IEC 17025 has contract review requirements that accredited laboratories must meet in order to to comply with clause 4.4 of ISO/IEC 17025.

In order for the laboratory to make an out of tolerance decision, it has to measure “as found” data. Even if the laboratory does not report it, it is required to retain it per ISO/IEC 17025 clause 5.10.4.2, second paragraph:

“When a statement of compliance with a specification is made omitting the measurement results and associated uncertainties, the laboratory shall record those results and maintain them for possible future reference.”

So, for a start, it is a good idea to use ISO/IEC 17025 accredited calibration providers and specify the customer’s requirements. Some provide “as found – as left” data routinely. Others may charge because they may claim that it takes extra time. But, if a competing laboratory provides it as part of the service, the other laboratories will follow suit or lose market share.

If the ISO/IEC 17025 accredited providers have to make a compliance decision on an item being calibrated, why would they not record the data? Even if it’s not provided, they are required to retain it for future reference in case of an inquiry. Calibration providers (whether accredited or not) that do not provide “as found – as left” data should probably be avoided. One does not know if they provided a legitimate calibration or they “stickered” the calibrated item and produced a generic certificate.

Other laboratories complying with ANSI Z540-1 or ANSI Z540.3 requirements are also required to provide “as found – as left” data. Otherwise, they are not fully complying with Z540 requirements.

The September 2010 Quality Progress Measure for Measure column, “Calibration Evaluation,” discusses evaluating non-accredited calibration providers and what to look for when assessing them.

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
http://www.emc3solutions.com

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

ISO 9001 Second-Party Audits and Confidential Information

Reviewing confidential files, training records, human resources files

Q: I am auditing contractors involved in a huge project of ours, and from time to time when I ask for information (risk register, management review meetings, etc.), they say it is confidential.

Where is the limit for confidentiality and how I should deal with it? Actually, it seems like the contractor is using it as a trick.

A: What is not clear from your question is the contractual arrangements you have with your suppliers.  If the contract has a confidentiality clause and calls for second party audits, there is no excuse for withholding information.   ISO 9001:2008 — Quality management systems –Requirements does not address confidentiality.  That is best addressed in the specific arrangements between supplier and customer.

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

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

ISO 17025 Certified Facility

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

Q: We have a specification that states test reports shall be from an facility certified to ISO 9001:2008 Quality management systems–Requirements. Our test reports are from a facility certified to ISO/IEC 17025-2005: General requirements for the competence of testing and calibration laboratories.

Isn’t ISO 17025:2005 under the ISO 9001:2008 umbrella?

A: Your interpretation is, indeed, correct. Actually, for a testing lab, accreditation to ISO/IEC 17025 is superior to registration to ISO 9001! As you know, your accreditation agency actually observed your personnel performing tests. They had to demonstrate competency. This was in addition to the verification that you had a working management system in place (that’s why they call it accreditation and not registration. We won’t even get into the misuse of the word certification).

To make sure your customer gets the assurance they want, I recommend you contact your accreditation agency. Ask them for a letter that states this equivalency. That will probably blow your customer away – or at least amaze them! Unless you can show the text you provided to ASQ was from one of the ISO or ANSI standards-writing committees, as an official interpretation, it probably holds little weight.

Your customer is right to monitor your performance this way. Recent food safety issues, prominent in the news, have a common element to them — insufficient attention to supplier performance. Expect to see more of this as the manufacturers and distributors pay more attention to their supply chain. I expect you are or will be doing the same for your critical sub-suppliers. Remember too, there are many ways to monitor supplier performance. Registration/accreditation is one of the ways.

Dennis Arter
ASQ Fellow
The Audit Guy
Columbia Audit Resources
Kennewick, WA
http://auditguy.net

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