Three updates
Four corrections
Eleven additions
Fourteen clarifications
Three deletions
One modification
Thirteen revisions
Three updates
Four corrections
Eleven additions
Fourteen clarifications
Three deletions
One modification
Thirteen revisions
So, not too many real changes occurred. Instead, the changes present a response to industry confusion with the original language but do not really address real issues. In fact, in some cases the revisions make previous problems worse. Two of the most prominent areas of concern are the requirements that address government safety and environmental regulations, and those that involve laboratory accreditation. What makes these two particular issues worse is the actual language of the requirements. In the first case, Element 4.9, which deals with proper handling, recycling and elimination or disposal of hazardous wastes, talks about "appropriate certificates or letters of compliance." In the automotive industry, this is a very dangerous requirement. Most governmental agencies do not issue certificates or letters of compliance because of liability concerns. So the question is raised: "How can anyone prove to an auditor that in fact the requirements have been followed?" Some try to muffle this concern with an answer such as "the company needs only to demonstrate knowledge of the appropriate regulation(s), and show that they have addressed the issue(s) and would comply with the applicable environmental or safety regulations." This opens a can of worms, primarily because it becomes a very subjective way of evaluation that completely goes against the principles of a quality audit. It allows the auditor to have the freedom of evaluating a system based on knowledge rather than effectiveness. That totally contradicts the essence of QS-9000, which exists to standardize the quality issues in the industry. The second issue deals with Element 4.10.1. This section says, "suppliers shall use accredited laboratory facilities when required by the customer." The elimination of the original note to the standard presents a real interpretation problem. There is a strong implication-although some automotive task force members do not think so-that the laboratories must be accredited by a third party. That is what the actual words call for. To refuse to recognize and accept this is foolish. This is another major concern for auditors because it is left to their discretion to evaluate the situation. Again this is a total contradiction of QS-9000's intent. (At least for this issue, a formal interpretation by the task force is expected in late 1995.) Other QS-9000 issues deal with the evaluation method, the additional references in Section II and Appendix H. Let us first look at the evaluation method. Whoever designed the evaluation method seems to have forgotten that they are not dealing with surveys. They are dealing with audits, which are system-oriented. Therefore, the evaluation should and must be in a "pass or fail" mode. Not only has the principle of pass or fail not been followed, but a cumbersome methodology of letters and numbers has been developed that may confuse even the best of auditors, not to mention the suppliers. The method must be revised as soon as possible. It is unacceptable to talk about a system orientation for quality and then turn around and evaluate that system with criteria designed for surveys. (There is an option of pass or fail, and it is at the supplier's discretion. Here we talk about the second option as defined in the Quality System Assessment.) Another comment about the evaluation method pertains to the QSA checklist. Again, it seems that the designers of this document have forgotten that they are not dealing with an inspection (prescriptive) approach to evaluation. By following the checklist as closely as it is recommended, auditors lose the flexibility and initiative to probe and to follow their instincts. Yes, a prescriptive checklist holds some value because it provides standardization for everyone to follow, but the value of rigidity must be weighed against the information lost. The checklist in the audit process is a very effective tool when used as a guideline and a planning tool. However, when used as a prescriptive mechanism-as the document proposes-the auditor is not doing an audit but rather performing an inspection process. As is, the QSA checklist is the measurement standard for the audit. It should only be a guideline. Another concern with the revised QS-9000 is the additional specific requirements that each automaker requires. To talk about a harmonized requirement and then add volumes of additional individual requirements defies the best of common sense. How can we talk about standard quality for the automotive industry and then turn around and expect suppliers to fulfill all the additional requirements for the individual customers? Are we really harmonized or are we playing games? Are we interested in reducing cost or are we interested in shifting quality responsibility downward to the first- and second-tier supplier base? It is imperative for the task force to be honest about this and try to eliminate some of their trivial and unique ways of doing business. If improvement is the real goal, there is no way that suppliers need 30 additional documents to define quality in their organization. We are talking about one specific industry with one specific ultimate product. Therefore, the quality requirements should and must be compatible. The list of additional requirements must be streamlined, if not completely eliminated. Finally, Appendix H is the most horrendous addition to the revision. It is a prescriptive guideline for audit duration, e.g., if a plant has 31-100 employees, the initial audit must last six on-site days. It is a true sin to define the length of an audit. If W. Edwards Deming taught us anything at all, it is the fact that we must use statistics to project, evaluate, resolve and understand the population, rather than depend on inspection methods. What the designers of the table have done with this appendix has taken the world of quality back to the days where inspection was used to define quality. How can we predefine the speed of an effective audit? And what happens if the auditors finish before the prescribed minimum guideline? Isn't an audit an unbiased, random exercise to identify the effectiveness of the system under evaluation? Appendix H allows registrars and consultants to charge unnecessary fees. (Competition would not be able to resolve this problem. It is a design problem and must be changed as soon as possible.) Outside QS-9000's changes, revisions and modifications, those who work in the automotive industry must address one more issue-the ambitious schedule of implementation. Chrysler and GM are on record that by December 31, 1997, all their suppliers must be third-party accredited (Ford Motor Co. requires compliance but not third-party certification). Let us be real! This deadline is nothing more than an intimidation tactic and in reality is meaningless. Why? Logistically, it can't happen. There are not enough knowledgeable auditors, lead auditors and registrars to perform all the initial audits necessary for certification, not to mention the mandatory six-month surveillance. Which leads to the following questions: Is the QS-9000 requirement going the slippery road of the same programs that it is trying to replace? Is QS-9000 going the route of the other harmonized requirements, e.g., FMEA, measurement system analysis and so on? (With these harmonized requirements, even though they have been around for several years, the individual original equipment manufacturers use their own system and in some cases totally contradict the official requirement published by the Automotive Industry Action Group.) Will QS-9000 certification be awarded because of political pressures? And what happens when a first-tier supplier is not certified by the deadline? Is the OEM willing to shut their production line down to wait for such certification? We raise these questions because, as of this writing, the waiting period for the initial audit by a registrar is anywhere between 10 and 14 months. If we project this cycle for all first-tier suppliers, the time is not enough to certify everyone. Then what happens to the OEM assembly plants and to the QS-9000 deadline? A final note about the harmonization concept: If QS-9000 is legitimate and really concerned about quality and lowering costs-and it appears that it is-why are the OEMs still pushing for their own quality programs? Why will a company push their supplier base to increase their cost in implementing additional requirements and approaches to quality, and at the same time refuse to recognize that their demands increase the cost of doing business for their supplier base? If harmonization is indeed the goal of the OEMs, then the additional individual requirements must be re-evaluated and either implemented throughout or scrapped. These trouble spots and recommendations were offered in the spirit of constructive criticism for an improved and otherwise good requirement. QS-9000 is a great attempt in the right direction; however, it does need some fine-tuning.
About the author . . . D.H. Stamatis, Ph.D., CQE, CmfgE, is president of Contemporary Consultants Co., located in Southgate, Michigan. He specializes in quality issues, especially ISO 9000, QS-9000, TQM, DOE and FMEA. qd
