Control Plans - Is customer approval needed ?

During a recent TS audit the auditor has stated the following

Any changes to the control plan must be approved by the customer

• The control plan is a contractually binding document with the customer
• We can not state that an operation is done as per SOP 113 (or what ever number it is) and as such we cannot change the SOP should we wish to have a tighter detection method than in the control plan, even though the change was due to an 8D and was only for a limited time.

In all my 30 years in quality I have never been told this before. Mind you we have had several issues with this auditor

Thanks in advance
Andy

 

I am with you on this Andy, never heard of such a thing. I will be interested in hearing what others have to say about this.

 

According to the standard, the NOTE ins section 7.5.1.1 says "Customer approval may be required after review or update of the control plan." It also refers back to 7.1.4, which says "Note 1 Any product realization change affecting customer requirements requires notification to, and agreement from the customer." So, I would think that you could argue against the control plan being reapproved after a change - but, it would depend on your customer requirements. If your customer did not require this, then no. If, as a result of an 8D, notification and agreement is required to close out the 8D, this would cover the 7.1.4 portion.

Just my 2 cents worth.

 

I agree with the first statement. However I differ in opinion to that second statement. Only if you adapt the process Control Plan and your SOP 113 is the process, then when you change the SOP you change the process then the Contrl Plan has to be reapproved. But if you have a system Control Plan, whereby 1 of the process is controlled by SOP 113, then you can state that, OP____ particular process is controlled by SOP 113. THe process has not changed, only tighten the Control. But you must have a Revision History to describing the change that takes place. It does not need to be reapprove by the customer. If you need to change the process, you have to inform the OEM and resubmit a PSW. I hope you are adapting the system Control Plan not process Control Plan.

We all have issues with TS auditors because the TS16949 is so prescriptive and it has different interpretation. When I have issues, I talk to the auditor first and when I cannot resolve the issue then I would think of going to another second opinion. The only TS auditors you will find that is top notch in the field of TS16949 are found in this QFO. I hope this helps.

 

Approval of the control plan is a very customer-specific requirement. If in doubt, have your customer saying in an email it is not required..........

 

There is no specific requirement in TS16949 that Control Plans should be signed by the customers. Notes on the TS are not requirements but just guidance and cannot be used by auditors to cite a nonconformance.

However, customers must be notified and/or approve changes in the Control Plan if the nature of the change requires it based on the customer's change control procedures or your company's. Also if the Control Plan is customer-specific and they approve it, then any change would require re-submission and approval by the customer.

 

Hi Andy, I've just come out of the automotive world, was in it around 17 years and I don't agree with your TS auditor.
In the last couple of years I found that the auditor we had started to come up with things that had never been highlighted in the past.

If I was you, I would just ask the customer(s) and see what they say.

 

Case 1. Change in control plan for process imrovement.
Customer approval is not required but customer can be informed. Records of revision history must be ensured.
Case2. Change in control plan effecting product design.
PSW must be re submitted. If required by customer submit the control plan.

As for as ISO/TS 16949 is concerned customer requirement must be fulfilled.

 

It is a question of a change management process that you should have previously agreed with your customers.
Based upon different level of change and criticalities , you should undergo different level of approval and/or notification of a change in the control plan.

 

I think a lot of this depends on the product and the relationship with the customer. If you are making parts to customer prints, then the two point may be valid. However, if you are making commodity parts and those parts are sold to several customers, then those points are less valid.

 

What does "approve the control plan" even mean? Do they sign it? Do they sign a warrant that was sent with it? How are the warrant and the control plan linked to provide evidence that the signed warrant is in fact approving the control plan.

So many questions....

The reality is if the changes impact the process, the controls of the process, and/or the end result of the process it cannot be a bad idea to send the update to the customer via a new warrant listing the revision to the quality plans as the reason. However, if you are changing a spelling error or a format issue is it really a reason to ask for a new warrant?

 

We always worked with the customer to create Control Plans.

 

This is really "funny" and shows these people talking out of both sides of their mouth.

First auditors should stop practicing law. If have heard all about these being "legal documents and agreements." Not really. At best, like most of your business documents, they will be evidence in a very complex litigation.

Second, if it is such an "agreement" that means my customer and I agreed to its contents so auditors need to keep their nose out of the content of the "agreement." They can't tell me I did "something wrong." What gives them the right to interfere with our "agreement." But they do anyway. Go figure.

 

I'd like to offer a summary of information concerning approval of control plan by the customer:

• The Note on 7.5.1.1 says "Customer approval may be required...". This was already quoted by Emmyd;
• The Foreword of TS standard says "Paragraphs marked “NOTE” are for guidance in understanding or clarifying the associated requirement". NCs can only be raised against "shalls" not on "shoulds", "Notes" and "such as". Naty Menez has also a say on this;
• The Note on 7.1.4 says "Any product realization change affecting customer requirements requires notification to, and agreement from, the customer". Emmyd also mentioned this and the statement still fall under a "Note";
• The 4th edition of PPAP in Note of 2.2.7 says "Control Plan approval may be required by certain customers". However, AIAG's PPAP Manual, like TS standard, has the same treatment for statements under "Notes";
• Descriptions of Section 12-Customer Engg Approval/Date and Section 13-Customer Quality Approval/Date of the Control Plan form on AIAG's APQP Manual both says "Obtain the responsible customer engineering/quality representative approval (if required - see appropriate customer specific requirements";
• The GM CSR Manual, effective on July 2015, on section 4.2.6 says "General Motors does not provide waivers to organizations for control plan approval because General Motors signatures on the Control Plan are not required";
• Ford CSR Manual, effective Nov. 1, 2015, on section 7.3.1.1 says "Process FMEA(s) and Control plan(s) for inverted delta component(s) require Ford Engineering & STA approval in writing".

My two cents.

 

In other words control plans don't need customer approval unless the customer requires it. Why do we have to make it any more complicated than that?

 

Sorry if I confused you. I just want to provide additional references.

 

No confusion. And you had a very well thought out approach. I am only pointing out, that the question has been answered by the reference in the note. Unfortunately, some people like to make things up which aren't actually there requiring your step by step analysis to get them to see the light.

 

Control Plans can be shared or approved by customer if customer mention it in his standard or it is required by the customer.
As per TS Standard in 7.5.1.1 there is no any necessary requirement of approval of control plan by customer as it stated in "NOTE: customer approval MAY BE required after review or update of the control plan"

 

What level Control Plan are you submitting? The Note on 7.5.1.1 says "Customer approval MAY be required...". So it is by Customer Specific requirement whether or not to submit the control plan. Every other comment here is valid. Please appeal to the CB if the TS auditor's statement resulted in a nonconformance.