Supplemental Rule 003 has been released!
For most of you, that headline will probably be met with a collective “what??” as in, “what is supplemental rule 003 (SR003) and how does it affect me”? And in full disclosure…supplemental rule 003 has not actually been released in final form but instead, it is still in draft form.
But all of that aside, SR003 is the document that provides guidance and rules for companies transitioning to the new AS9100, AS9110 and AS9120:2016 standards. In addition, it gives guidance and rules for NQA, UKAS, your NQA auditor etc. specific to the transition from the older version of the standards to the new.
Released by the International Aerospace Quality Group (IAQG) Other Party Management Team (OPMT), SR003 includes a number of deadlines that you, as an aerospace certified company, must be aware of. In addition, I have included other deadlines that will also affect your certification over the next two years.
- September 2016 – AS9100:2016 published
- November 2016 – AS9110:2016 published
- November 2016 – AS9120:2016 published
- March 2017 – NQA expects to begin conducting audits to these new standards
- March 2017 – NQA will discuss your readiness to transition to the applicable 9100/9110/9120:2016 with a representative of your company
- 1st June 2017 – All audits starting after this date must be to the newest versions of the standards
- 1st December 2017 - NQA shall conduct a risk and mitigation analysis for any client that has not transitioned to the 2016 editions of the aerospace standards
- 1st June 2018 – All transition audits to the newest aerospace standards for existing NQA clients are to be completed by this date
- 1st September 2018 – The transition audit report, associated documentation and closed NCR’s (if any) must be received by NQA
- 15th September 2018 – NQA must make the certification decision to transition a client to the newest version of the aerospace standard by this date. If not, the applicable certification will no longer be eligible for transition and an initial certification audit will be required.
The key dates to remember assuming all goes according to plan are that we hope to be able to audit to the new versions of these standards in March… possibly February 2017. All audits starting after 15th June 2017 must be to the new version and your transition audit must be completed by 1st June 2018.
What that means is that you will have approximately 15 months to transition. Lastly, your audit report and closed NCR’s must be at the NQA offices by 1st September 2018.
In addition, SR003 requires that certification bodies like NQA add audit time to your transition audit above and beyond what we would normally do on a surveillance or re-assessment audit. Also, transition audits can occur at a surveillance, re-assessment or during a special visit. If transitioning at a special visit or surveillance, your current certificate expiration date will be maintained.
If transitioning at a re-assessment audit, you will receive a new 3 year certificate. Lastly, a company cannot be certified to the newest version of ISO 9001 and the current version of the AS9100 series of standards (e.g. ISO 9001:2015 and AS9100C).
So what should you do?
Implement the AS91XX:2016 standard and start applying the requirements of it as soon as possible. Be careful when updating your system to the new revision, especially if you are yet to have your current revision assessment/audit.
Make every effort to conduct your transition audit in calendar year 2017. This is because we fully expect an auditor shortage in 2018 as companies wait and then are forced to rush to meet the deadlines. By scheduling and conducting your transition audit in 2017, you will avoid this shortage and not put your certification in jeopardy.
Lastly, talk to your NQA client support representative early and often about your transition audit and if possible, have it completed in 2017. Remember, this audit is going to be longer than your regularly scheduled audit as required by SR003. Your client support representative can tell you the actual length of your transition audit.
It is recommended that all companies review these materials in detail:
AS9100 QMS - Requirements for ASD Organizations
AS9110 QMS - Requirements for Aviation Maintenance Organizations
AS9120 QMS - Requirements for ASD Distributors