Rescheduling an ISO 9001 Surveillance Audit

Schedule, calendar, timeline

Q: Our organization had its last external (third party) audit in December 2011 for ISO 9001:2008 — Quality management systems — Requirements. We planned to have our next audit the week of November 26, 2012, but the auditor has become ill and cannot come at that time.

Do we need to have our surveillance audit within one year of the last audit? I am considering rescheduling for the first quarter of 2013.

A: Thank you for contacting ASQ’s Ask the Experts.  With regard to your inquiry, surveillance audits are usually conducted by most registrars on an annual basis.  Your registrar has complete responsibility for ensuring the availability of their audit staff to conduct these audits as they are required.

In the event that no other auditors can be provided by your registrar, it would be their responsibility to ensure the audit is rescheduled to another mutually agreed upon date and, if necessary, extend your organization’s ISO 9001:2008 certification status as appropriate.

Your organization’s ability to maintain to an active QMS certification status should not be dependent upon the availability of the registrar’s auditor.  I recommend that you contact your registrar to confirm the next date for your surveillance audit.

I hope this helps.

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

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

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

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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

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ISO 9001, Control of Monitoring and Measuring Equipment

Audit, audit by exception

Q: In ANSI/ISO/ASQ Q9001-2008 Quality management systems — Requirements, clause 7.6,  there is a requirement which states: “When used in the monitoring and measurement of specified measurements, the ability of computer software to satisfy the intended application shall be confirmed.”

Do you have any guidance on how this can be established in an analytical laboratory?

A: To answer your question, I would first refer you to the note at the end of 7.6.  It reads:

“NOTE:  Confirmation of the ability of computer software to satisfy the intended application would typically include its verification and configuration management to maintain its suitability for use.”

Now, that can sound confusing to some folks. So, let me offer you some direction.  To “confirm” (verify) your software’s abilities, you need a known standard.  I’m not referring to a standard that is traceable to national standards.  I’m referring to data you know should be revealed as a failure by your software.

For example: You have samples from 10 subgroups and, you know that one sample, when analyzed, will be found to be nonconforming.  You can use a separate source to determine what the Cpk is, or you can simply identify which sample is out of tolerance and by how much.  When you use this known standard to test your analytical software, the results will tell you if it is suitable for use.

Most software is designed with some sort of pass/fail testing option.  Nonetheless, using a proven standard to verify your software brings it down to earth and more applicable to your needs.

Bud Salsbury
ASQ Senior Member, CQT, CQI

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Z1.4:2008 Inspection Levels

Q: I am reading ANSI/ASQ Z1.4-2008: Sampling procedures and tables for inspection by attributes, and there is a small section regarding inspection level (clause 9.2). Can I get further explanation of how one would justify that less discrimination is needed?

For example, my lot size is 720 which means, under general inspection level II, the sample size would be 80 (code J). However, we run a variety of tests, including microbial and heavy metal testing. These tests are very costly. We would like to justify that we can abide by level I or even lower if possible. Do you have any advice?

The product is a liquid dietary supplement.

 A: Justification of a specific inspection level is the responsibility of the “responsible party.” Rationale for using one of the special levels (S-1, S-2, S-3, S-4) could be based on the cost or time to perform a test. Less discrimination means that the actual Acceptable Quality Level (AQL) on the table underestimates the true AQL, as the sample size has been reduced from the table-suggested sample size (i.e. Table II-A has sample level G of 32 for a lot size of 151 to 280, while General Inspection level I would require Letter E or 13 samples for the same lot size).

Justification of a sampling plan is based on risk and a sampling plan can be justified based on the cost of the test, assuming you are willing to take larger sampling risks. If you use one of the special sampling plans based on the cost of the test, it is helpful to calculate the actual AQL and Limiting Quality (LQ) using the following formulas.

You solve the equation for AQL and LQ for a given sample size (n) and defects allowed (x):

Steven Walfish
Secretary, U.S. TAG to ISO/TC 69
ASQ CQE
Principal Statistician, BD
http://statisticaloutsourcingservices.com

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Capability Analysis

Pharmaceutical sampling

Q: Why is a standard capability analysis determined to be best represented by 30 pieces?

I have answered this question by explaining it best represents a normal distribution. But I wonder if this is traceable to an industry standard?

A: You are right that most people associate 30 pieces with the conventional quantity for performing a capability study.  Although I don’t know the origin of this number, I can tell you the following:

  • The number 30 has nothing to do with whether or not the population is normally distributed.
  • In many applications, the number 30 is insufficient to properly model the process.  For example, automotive industry standards published by the Automotive Industry Action Group (AIAG) in their statistical process control (SPC) and production part approval process (PPAP) documents define 100 pieces as the appropriate sample size for an initial capability study (based on 20 subgroups of five or 25 subgroups of four).

I hope you find this helpful.

Denis J. Devos, P.Eng
A Fellow of the American Society for Quality
Devos Associates Inc.
London Ontario
www.DevosAssociates.com

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