David Burns's Podcast: Recent Episodes

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NO PERFORMANCE DETERMINED - UKCA & OR CE MARKING, THE CPR & NPD

When using the term "NPD" or no performance determined, it means just that. You are "warning" by way of the declaration the limitations of the item e.g. not everything has been specified and or tested.

Within the Construction Products Regulation [(EU) No 305/2011 also a Statutory Instrument within the UK] clearly states that the "manufacture" is the one placing the product onto the market, and ultimately the one responsible the integrity of the UKCA / CE Mark as applied.

(EU) No 305/2011 - see Article 2 Clause 19

This basic fact about the one placing the product onto the market, is a key requirement of all CE obligations - soon to also be the UKCA requirement, currentl revised to 1st January 2024.

Calling all Notified Bodies, please wake up to the following:

a) EN 1090-1 Table ZA.3 – this is the tasks for the certification [notified] body when they visit you (the enterprise) – to review the FPC only against (clause 6.3 and this limited focus is as legislated within the CPR and may exclude “design” - (EU) No 305/2011 - see Article 2 Clause 26) and with reference to;

b) Annex ZA.1 – the specification for the product as provided from the customer (or if design is within the FPC scope, the internal design requirements); as applicable to the product (and contract specification, as defined), with reference to;

c) Annex B – the certification [notified] body will undertake an initial inspection and on-going inspection of the FPC (as per scope – with reference to Annex B.4.2) – basically, assess the effectiveness of the FPC with consideration to the above 1 and 2; and finally;

d) ZA.3 ## – the certification [notified] body will review the “declaration of performance" UKCA / CE Mark certificate content as issued by the FPC – to include any NPD’s as confirmed within 2 above.

Therefore, the Notified Body is awarding "certification" against the "factory production control" clause of EN 1090-1, 6.3 for the enterprise to issue "declarations of performance" for UKCA / CE Mark (at the point of dispatch from their "factory production control")..

Where the "factory production control" excludes design from the scope as confirmed with the Notified Body, the the legal responsibility for the product specification sits firmly with the customer and or their design experts (the CPR manufacturer in law).

Why are we putting this out there?

So many Notified Bodies are bouncing SME fabrication welding firms into "non-conformances" due to the SME's customer NOT providing the correct information for the product. From customers not providing the EXC level through to bolts and weld test specifications not made clear.

However, in this regard, we recommend to all "non-design" EN 1090 firms to simply state NPD on their CE Marking "declarations of performance" (in line with the EN 1090 Annex ZA's). Clearly stating this within the "declaration of performance" to the customer specified requirements as per their drawing specification provided.

As a non-design EN 1090 firm, you cannot be permitted to deviate from the information provided from your customer (without written consent to do so); should you deviate from the customer contract specification, this would be a breach of contract and you would be liable for any failures.

Notified Bodies should focus on auditing with reference to the primary points of legal reference; the CPR and CE Marking. The EN 1090 has become the focus of attention and not the legal frame-work.

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All I did was park my car at the hotel.

This is a little story about hotels and car parking and data access control – and those that issue fixed penalty fines claiming they hold ISO 9001 - certificated by organisations with non-UKAS accreditation.

Is this acceptable? They have access to your data, because they have access to the DVLA via your car registration.

Who is looking at this data?

Listen to my story about "Smart Parking" and an organisation named POPLA and the British Parking Association (BPA) and my “fixed penalty” charge.

However, “Smart Parking” went on to explained that I have the right to appeal to an organisation named POPLA (this is an independent appeals service for Parking Charge Notices issued on private land).

I noticed on the footer of the “Smart Parking” letter they “claim certification” against ISO 9001 and members of the BPA. But is this a scam? Who are these organisations that fail to understand the UK "conformity assessment" rules of best certification practice.

Do "Smart Parking", POPLA and the BPA simply represent the original “man in a van” (or lady in a van) wheel clampers from the past?

I asked these question in the first instance (perhaps selfishly on my part), because I have this “fixed penalty” charge from “Smart Parking”, but also prompted by “Smart Parking” claiming an ISO 9001 certification that is clearly NOT UKAS-accredited. This makes me think - bogus! No legitimate regulator is unaware of UKAS accreditation.

Secondly, my complaint is in the process of an appeal with an organisation [POPLA] that is linked to a trade association named BPA [British Parking Association]. Again, they seem to be unregulated. And you'll like this bit, “Smart Parking” is also a member of the BPA.

Is this an all-round conflict of interest?

Who is actually looking at my data?

Is access to my data a breach of my privacy rights?

Where is the impartiality with my appeal? I seem to be screwed...or am I?

Or if BPA or POPLA is regulated, do they represent their members [including “Smart Parking”] and the owners and managers of car parking schemes - or me.

Over to you DVLA. Over to you ICO. Over to you UKAS.

In the meantime, I am awaiting my appeal that is currently with POPLA - the organisation recommended by "Smart Parking". I will keep you posted.

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Hello my name is David Burns of The Assessment Register and welcome to our "podcast".

As the "podcast" name implies, this podcast is all about considering and controlling potential "counterfeit" within your supply chain. The AS 9100, IATF 16949 and ISO 9001 requires a level of control to mitigate "potential" counterfeit .

Whether alloys and electronic or software and certificates, counterfeit can creep into the supply chain. However, be very aware. Counterfeit is only counterfeit if proven to be counterfeit. Many AS 9100 and ISO 9001 auditors forget that a counterfeit part may not be a counterfeit, but a mistake without malicious intent.

Within “quality management system” circles, we are all aware that the law will take precedence over a voluntary Standard. In addition, a legally binding contract will also take precedence over a voluntary Standard. UK law around “forgery and counterfeiting” talks about “intending to deceive” through knowingly “imitating a product” and claiming it is the genuine thing.

This can be achieved by incorrectly-labelling the item, false or misleading certification, creating a similar brand, etc. things that will cause confused product messaging.

The AS 9100, IATF 16949 and ISO 9001 present the case for “product identification and traceability” and now “prevention of counterfeit” parts. So, nothing new, but an important consideration for the quality management system. We recommend that prevention should be an integral part of the following:

· Supplier selection – known and quality assured suppliers

· Purchasing – terms and conditions that reminds about counterfeit matters

· Training – internal awareness training for those involved with the above and inspection

· Non-conformance – reporting and containing potential counterfeit items

· Reporting – to customer and the authorities

…well that’s the summary… have a great listen and then visit: www.assessment-register.co.uk

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An Excellent Opportunity to Attend our 4 Session Remote AS 9100 Training Programme, to include Internal Audit methodologies and best practice.

Listen to this podcast for all you need to know about attending this remote training programme. We describe the 4 sessions, expertly designed as follows:

1. AS 9100 Awareness & Implementation
2. AS 9100 Technical Areas Discussion
3. AS 9100 Internal Auditor Training
4. AS 9100 Case Studies & Workshops

Course History

Our “remote training” course – is all about AS 9100 and aerospace quality management "best practice". Originally developed for our consultancy project clients, based on the need for practical understanding and not just talking about AS 9100 clause headings, but actual explanation about technical implementation in context with the organizational requirements.

The course is divided over 4 x sessions, throughout 1 x day.

This provides the opportunity to spread the technical load and absorb and consider the course content – ensuring your questions are geared for maximum benefit for your needs.

You will receive:

• Your Personalized AS 9100 Training Certificate
• Your Copy of our AS 9100 Presentation

Unlike many other AS 9100 training courses, our “remote training” course programme is delivered by true practitioners with an unchallenged reputation of ensuring Certification success.

The course programme provides a unique blend of practical implementation advice against those awkward clauses of the AS 9100 – providing proven examples when required.

We understand what the Certification Body requires from you to achieve AS 9100. Therefore, our primary focus is ensuring you successful development and implementation, through to compliance. We pride ourselves on delivering expertise for both improvement and technical compliance – we stand or fall by the quality of our AS 9100 training.

Course Objectives

Our “remote training” course programme is dynamic and encourages complete delegate participation. All delegates are asked to provide us with a series of questions in advance of attending the course, relevant to specific needs to ensure we balance the course to the group – and answer your specific questions.

Our “remote training” is aimed at those already familiar with the requirements of "quality management systems". In addition, fir those seeking to have a better understanding of the aerospace and defence sector requirements - all your questions will be answered with a “no-nonsense” example to support compliance.

Course Tutor

With over 30 years of "quality management" and "conformity assessment" experience, within the private sector and government institutions. Successfully completed over 600 legal metrology, standards, testing and quality assurance projects within the UK and internationally. From AS 9100 to ISO 17025 and AQAP to CAA JAR 145, from engineering apprentice, compliance manager to senior civil servant... to include sector scheme development for trading standards... rest assured, our course tutor is a true practitioner that won't disappoint.

System design and implementation techniques, through to in-process inspection and calibration requirements, from special process control to supply chain integrity... business strategy, risk and mitigation planning, FOD and counterfeit materials awareness.... rest assured, our course tutor is a true practitioner that won't disappoint.

After listening to this podcast, contact and book your place. We can also deliver this training course programme one-on-one remotely or at your organization if preferred.

Email: info@assessment-register.co.uk

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**What do we actually mean?

The importance of Traceability** – Its all about providing “confidence” and “integrity” within the supply chain. Everything to support the product specification and of course user (consumer) confidence and ultimately "brand image":

From raw materials, such as – metals, alloys, carbon fiber, wood, packaging, food, etc. through to all matters of calibration – measurement integrity, standard reference materials for chemical analysis, legal metrology for trade, etc.

That Paper Trail – We traditionally underscore our confidence with “a paper chase” (or pdf's) from the supplier of materials or components, for example:

• Certificate of conformity (against a technical specification or part number)
• Declarations of performance (against a directive for CE / UKCA Marking)
• Mill certificate (from the – well… the mill)
• Test certificates (from those within the “process” responsible for inspection / testing).

However, remember…. just because you have the “paper trail” with a link to the “item” supplied, it does not mean that the material or product is correct or compliant.

No.... ISO 9001 and AS 9100 only require the management of "traceability" and not material or product compliance... for that, we must delve deeper!

Your customers are aware of the failures within the "supply chain" and that is why customer contracts state "supplying materials and components with certification from a quality assured and approved supplier - does not absolve you the supplier from the responsibility of ensuring material compliance".

This "podcast" will provide the necessary guidance for your consideration about how you manage your supply chain integrity - risk and mitigation.

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Hopefully both... a cool drink, a hot sunny beach, waves crashing, and yes, an ISO 9001 podcast - living the dream or what!!

Now is the right time to consider taking your business to the next level. Up date your current ISO 9001 or go for the AS 9100 certification. 

The positive re-structure and re-launch of your business and what better management tool – ISO9001. In just 4 days, The Assessment Register team can quickly make you ready and manage your formal certification! The foundation of continuous improvement.

Yes, it is time to land the mother ship – the mother of all quality management system Standards – ISO 9001 is the cornerstone for competitive advantage and business improvement.

This podcast is a simple reminder about the benefits of ISO 9001 and related certification.

• Enhanced reputation
• Business improvement
• Commercial awareness
• Risk mitigation
• Resource planning
• Sustained development
• Quality assurance

…and above all, putting your business on the tender to bit for customer contracts.

Remind yourself of the benefits at your leisure – listen to the podcast and contact The Assessment Register for more information – www.assessment-register.co.uk 

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Its all about The Assessment Register... people have been asking, so... "what do you do?".

This podcast provides an insight onto what we do. As management consultants that specialise in metrology, standards, testing and quality management... well, its all about trade facilitation through compliance.

We support private sector business, institutions and certification bodies comply with contract and legal obligations... so, the podcast just provides an overview.

Although, we don't advertise and most of our clients arrive by referral... we've been about since 1990 successfully support trade and industry; its what we do!

Sounds awful to say, but we're very good at what we do...we're always ahead of the game for our clients... our team oozes confidence! 

Need AS 9100, done it loads mate... its easy!

Need ISO 9001, no brainer... absolute doddle!

Need ISO 17025, hmm can be tricky, but we've achieved accreditation... 

Just ask and we'll do the necessary.

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"Remote auditing is here and here to stay”...it's all about planning... then taking the initiative... and of course, you've probably heard it from UKAS and loads of other Certification Bodies that, remote auditing is receiving positive feedback - excellent!

This podcast is aimed at those on the receiving end of Certification Body and UKAS “remote audits” of Quality Management Systems - making life easier.

A well prepared Quality Manager will support your auditor to become quick and slick.

Ask your Certification Body auditor for a "pre-audit" check-list of questions with clause by clause auditing timing - this will help you to help them - drive down your Certification costs by simple preparation.

Don't waste time "nattering" online. Keep to the audit plan. Feed you auditor with data and evidence. Ensure that you KPI's make sense - feed the auditor with facts.

We have decided to provide a few suggestions prior to starting your audit. The main one is train the Quality Manager to be the "face of your business"; its all about presentation.

This podcast is based on how to make the “remote audit” a success for those sitting on both side of the table, summarized as follows:

1. Contracts and non-disclosure agreements

2. Technology communication testing

3. Planning, timing and costing

4. Information and data media

5. Scope and duration

6. Culture and environmental perspective

7. Reporting the audit and follow-up

The “remote audit” is a completely different beast to norms of face to face auditing… it must be treated like a new technology… train yourselves on how to “present the case” for your business and quality management system.

Require support? Please contact us at The Assessment Register...
www.assessment-register.co.uk

All the best.

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80% OF NCR'S CAN BE DIRECTLY TRACED TO WEAK REVIEW OF CUSTOMER CONTRACTS & TENDERS.

Quality management systems require some basic ingredients to ensure effectiveness. One of the primary ingredients is "contract review" for AS 9100, ISO 9001 and ISO 17025.

Keeping in mind that 80% of an organizations poor performance, can be traced to a poorly controlled "contract review" process. Due to the lack of? Yes, you've guessed it, due to the lack of "review of the contract detail". 

Or not reviewing the contract terms and conditions for technical and quality requirements and commercial obligations.

Customer complaints, supplier issues, in-process reworking, late delivery, etc. can almost all be attributed to those involved with contract review. Those unfortunate individuals that are either under pressure, under resourced or under qualified for the task.

This podcast will simply highlight the requirements for the management and administration of sales order processing and effective quality control of your customer needs. 

www.assessment-register.co.uk

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ASK US FOR YOUR "FREE" INTERNAL QUALITY SYSTEM AUDITOR CERTIFICATE REMOVING AUDIT ANXIETY - LISTEN & LEARN

Soon the Certification Bodies will be back from "remote auditing" and asking you questions about your last 12 months of "internal auditing". That said, Certification Bodies may never visit you again! Now there's a thought!!

So, whether new to internal quality system auditing, or an old hand, listen and learn from our "podcast" and at the same time refer to our "free" kindle eBook from Amazon.

Be prepared to present you case for internal auditing and reporting.

Our internal auditor training is divided into 5 easy reference sessions:

1. Developing audit concepts - why, where and when to audit
2. The auditor - character and how to select the best auditor
3. The audit - where to look, what to audit and who to ask
4. Auditor skills - getting it right, with the correct information
5. Reporting the audit - presenting the performance improvement case to management

… with the primary objective of performance improvement and contract compliance.
… you'll know as much as the Certification Body at the close of the podcast.

For your FREE e-book (copy into your browser) - https://www.amazon.co.uk/INTERNAL-AUDITOR-NEXT-GENERATION-19011-ebook/dp/B078R8ZFMG/ref=sr_1_1?dchild=1&keywords=the+internal+auditor+david+burns&qid=1588085929&sr=8-1

The information contained in this publication is designed in such a way as to give knowledge and guidance to Quality Managers and Internal Auditors. The methodologies applied throughout this booklet are well proven and will deliver performance improvement – and your reputation as an expert Internal Auditor.

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With fear of stating the obvious, this podcast is about "calibration control" for general mechanical engineering and precision machining. 

The podcast includes hints and tips for the avoidance of audit non-conformances. 

Most organizations will have very good calibration control internally, although sometimes fail to manage external calibration service providers and accredited calibration laboratories.

This podcast is a gentle reminder not to assume calibration is compliant in the hands of external service providers... Look at the scope of your calibration service providers accreditation schedule.

Consider your customer contract obligations and requirements and then double check this against the calibration laboratory.

Some will claim ISO 9001 certification for the calibration service; this is the management of the calibration service and not always the control of the calibration itself.

The use of a UKAS accredited calibration laboratory is the safe bet (or other ISO 17025 accredited laboratory), but always confirm the scope of your chosen laboratory.

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Remember the UKCA Mark is here and here to stay and so is EN 1090.

The Construction Products Regulation (the CPR) and CE Marking will be accepted in the UK for 12 months and then bang! Its gone! Unless of course you are exporting to the EU.

The question is... how many UK based structural steel fabrication and welding firms export to the EU. Keep in mind, the UK Statutory Instrument, the law requires the "type approval" of the product, produced through an effective factory process. The latter validated by a Notified Body with reference to the construction products regulation, the NSSS guidelines and of course production control the BS 3834 compliance.

In the UK it is the UKCA Mark and BS 3834 and that will be our future. So, it's worth just getting on with reviewing your "factory production control" now to ensure compliance.

Those already with EN 1090 certification, this will be an easy flip-over into the BS 3834.

These Notified Bodies are listed by the EU. Our UKAS Accredited Notified Bodies will not be listed by the EU. Some of you may use a Notified Body that is Accredited by an EU country member Accreditation Body.

The question is... if the UKCA Mark is not recognized by the EU post 1st January 2021, then will your UK customers recognize your EU based Notified Body and their "type approval" of your product for the UK market? Probably not!

The Assessment Register is aiming to keep the UKCA Marking for structural steel and aluminium a simple matter; having in mind that we in the UK don’t generally have a problem with the structural steel and aluminium construction sector.

Our aim is to provide the necessary information examples and points reference to assist with your "factory production control" (FPC) Certification for your UKCA Mark - its here to stay.

The Certification Body or Notified Body that will visit to audit your factory will expect to view a "documented system" of procedures that support your FPC - how you process a job from enquiry through to completion and then provide a "declaration of performance".

Remember the law is the Construction Products Regulation (CPR) and the UK Statutory Instrument and this requires the UKCA Marking for "construction products". The later product produced through an FPC.

The sector is in fact self-regulating, through a system of supply chain integrity. Small and medium sized structural steel and aluminium enterprise owners understand their respective limitations and undertake contracts that are deliverable – its called self-preservation.

www.assessment-register.co.uk

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As we're all aware by now, both the AS9100 and ISO 9001 Standard requirements “screams” business plan to the senior management team. 

This podcast is all about promoting the use of the “business plan” as the preferred “top level” management system document. 

Further recommending that organizations ditch and bin their “quality manual” for the more business practical and user friendly – business plan. 

And its worth keeping in mind, the following:

1. All businesses need to have an effective and practical business plan...and

2. All businesses need to engage business owners with "quality matters" [the Standards]...

3. All businesses that fail to recognize the above 1 and 2 will struggle during Certification

This podcast is a quick and simple explanation of the business plan, its content and linkages to PEAR’s – this AS 9100 requirement.

The business plan should also consider commercial and technical "risk and mitigation" matters - the disaster plan through to supporting matters of planned recovery.

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Process effectiveness assessment report (PEAR's) and a simple overview of the requirements to ensure your compliance. Keep ahead of your audit and listen to this "podcast" for examples of PEAR's and KPI (key performance indicators).

Where is AS9100 PEAR from and why? PEAR is an acronym that is used to help the auditor remember how to audit and fill in the audit report. The letters stand for P = people who do the job, E = environment the work is done in, A = actions that need to be performed, and R resources needed to do the job.

All a bit naff, don't you think?

So, again what is AS9100 PEAR form? PEAR is an acronym for "process improvement" and used as follows. P = process (identified as) E = effectiveness (measured by) A = assessment (of objective measures) R = report (presenting the data) for factual decision making "by the boss" and performance improvement.

Nice PEAR,,, of course, your AS 9100 auditor will need the PEAR more than you! See the PEAR as a necessary evil for AS 9100 compliance.