How AS9104/1A and Supplemental Rule 004 (SR004) Affect AS9100, AS9110 and AS9120 Certified Companies

Recent changes affecting AS certified organizations are implemented through AS9104/1A (also referred to as AS9104-1:2022) which was released on January 7, 2022. (The previous version of the standard was published in 2012.) “Requirements for Certification of Aviation, Space, and Defense Quality Management Systems” includes major revisions and sets the requirements for Certification Bodies (CBs) regarding the entire certification process and audits, reports, OASIS database, etc. This includes a revision to AS9101:2022.

AS9104/1A is intended for the Certification Bodies (CBs) to implement and roll out, but affects those companies that are AS certified or seeking AS certification for their QMS.

• The drop-dead date for implementation by the CBs and enforcement for AS certified companies is July 1, 2023. The end date for the 9104:2022 series and 9101:2022 transition for the stakeholders is January 1, 2024. Each CB is on a separate schedule based on when they get accredited from their oversight body.
• The CB’s will be required to get new contracts signed by all clients to enforce and follow the new requirements (new terms and conditions for certification).
  • After next year’s audit, all client certificates will be updated with reference to the new AS9104:2022 standard.  Certificates currently state “The assessment was performed in accordance with the requirements of AS9104/1:2012-01“, along with other required verbiage.
  • The certificate expiration date will not change if next year’s audit is a surveillance.  The expiration dates (3-year cycle) will only be updated on a recertification audit.
• Those companies that were Campus or Complex site structures have to change to either Single-Site or Multi-Site certifications. CBs should have already communicated with the clients that will be affected (larger corporations) since audit days must increase (some drastically) and certificates must change after the next year’s audit.
  • There are ways to reduce audit time based on risk and maturity levels of the QMS, however the audit day reduction is only 10%, and the method to achieve this is quite onerous.  This will only benefit companies with audit mandays greater than 5 days (10% reduction on 5 days is ½ day less audit time…). 
• There may be some existing Single-Sites and Multi-Sites where audit durations may be increased based on new formulas required for determining audit mandays.
  • For individual sites, there may be justification for reduced audit time if that site doesn’t perform the following:
    • Management of the QMS – 10% reduction
    • Design and development (8.3) – 20% reduction
    • Control of external processes/providers (8.4) – 15% reduction
    • Control of products or services (8.5) – 20% reduction
  • ISO 9001:2015 is within AS9100:2016 and some CB’s issue certificates showing certification to “AS9100D and ISO 9001:2015”.  For those companies whose ISO 9001 scope is not identical to the AS scope, ISO 9001 can no longer be listed on the AS certificate. 
    • If a company needs an ISO 9001 certification and the scope is different from AS, the CB will add audit time to cover the ISO 9001 scope and issue a separate ISO 9001 certificate with the different scope.
  • Not really a new requirement, but AQMS certified companies have to appoint and maintain an administrator for the OASIS database. There are a few more prescriptive requirements the OASIS database administrator must do.   
  • The requirement to audit purchasing annually goes away.  Purchasing may now be sampled through the 3-year cycle.
  • Companies need to understand and know other IAQG (AS standards) that may be contractually flowed down.  These would now be auditable and sampled during an AS audit. CB auditors (and simpleQuE as internal auditors) will be focusing more heavily on these AS customer specific requirements. 
    • For example, aero engine customers (GE, P&W, Rolls-Royce, Safran) all contractually flow down AS13100.
    • The emphasis will be on AS standards.  Flow downs that are quite prevalent are AS9102 (FAI), AS9145 (APQP & PPAP), AS5553 (Counterfeit Parts), AS6174 (Counterfeit Materials), AS9146 (FOD), etc.
  • Greater emphasis on ethics – If there is a complaint or notification of an ethical nature, the CB has 30 days to conduct a special audit to evaluate the claim.  If the claim is substantiated with objective evidence by the CB, it is grounds for suspension of the AS certification.
  • AS9100, AS9110 and AS9120 are now following automotive where advance data will be required to be submitted to the CB greater than 90 days in advance of the audit. This data will be used for the CB audit planning and risk analysis, and may be used to justify more audit days.  This information includes reporting on the previous 12 month’s:
    • Quality performance
    • Delivery performance
    • Customer satisfaction/complaint data, which includes any CAR and complaint data in OASIS
    • Internal audit results to evaluate robustness of the internal audit program
    • PEAR (Process Effectiveness Assessment Report) process effectiveness and historical scoring. These are completed every audit by the CB auditors for any of the core processes they cover
    • Organizational changes that can affect the QMS

How to prepare for the AS9104/1A changes

• More attention will be placed on audit and key performance indicator (KPI) data which will impact audit time so it’s to your benefit to make these a key focus internally when planning your annual audit schedule.
• Annual internal audit schedules that are the same year after year will be scrutinized and challenged, especially if you only audit each process once per year and KPI data suggests there may be problems.
• Consider your site structure and work with your certification body if you are a Campus or Complex site.
• In the audit planning process be sure to complete the data forms issued by your certification body and ensure the data is true and accurate.
• Turn in advance data requested by the CB before their deadlines (>90 days prior to your next audit).  Work with your CB to clearly identify what they need and the due date.
• How is your OTD (On Time Delivery) and quality performance? If there are discrepancies between customer scorecard data and your internal data, be prepared to explain differences in results.
• Are your internal auditors doing a good job and finding issues?  It not, what training have your internal auditors received? How are you evaluating auditor competency and performance?
• What are your PEAR scores from your last certification body audits? Poor scores will be targeted at the next audit.

More information about AS9104/1A is included in our blog Major Revision for AS9104/1.

SimpleQuE is not associated with the IATF®, IAOB, ANAB®, IAQG®, and is not a certification body. SimpleQuE is an independent consulting, training, and second-party auditing service provider that assists a company on a path to obtain and maintain certification through accredited certification bodies.