Clarifying AS9100 8.4.3 and Flow Downs to External Providers

Clause 8.4.3 in AS9100 specifies the requirements that organizations need to flow down to providers. But do companies need to include all the items in the list every time?

To answer this, let’s consider the clarification provided by IAQG:

ISO 9001:2015 has removed the ‘where appropriate’ wording from ISO 9001:2008, clause 7.4.2. ISO 9001:2015 clause 4.3 allows organizations to apply requirements only when applicable. Organizations can determine what portions of the clause 8.4.3 listing are applicable or not applicable to a certain PO or their organization. Not applicable requirements are required to be justified with documented information.

In short, each organization is allowed to define and determine the appropriate flow downs for their needs based on their context, including their interested parties.

Although it may be tempting to take a position of omission by defining that nothing needs to be flowed down, an organization must consider that a customer may mandate the flow down of certain items based on customer-facing contractual obligations in purchase orders, statements of work or similar.

Commonly flowed information is:

• right of access to the suppliers
• obligation to report nonconforming products
• customer’s additional terms and conditions
• AS91XX:2016 additions regarding product safety, ethical behavior and contributions to product or service conformity.

Other legal obligations for flow down may be identified in the same documents, such as Defense Federal Acquisition Regulations Supplement (DFARS) clauses, Defense Priorities Allocations System (DPAS), export controls and the like.

While these obligations may be misunderstood, ignorance is not a defense against a failure to adhere to contract requirements. But more importantly, these regulations often exist to ensure that a nation’s sensitive information is prevented from making its way into the hands of their adversaries. A seemingly sound practice.

Another request for clarification regarding clause 8.4.3 asked whether 9100 requires flow down of 9100 into supplier and sub-tier supplier contracts.

IAQG’s response was:

No. It is only a requirement to flow down 9100-series if there is a customer contractual or organizational QMS requirement. Regardless, the organization can also decide to flow down QMS requirements to its supplier, see clause 8.4.3k.

Again, the organizational context permits a company to flow down the level of controls needed to meet the needs of their interested parties. While some may mandate their supply chain to adhere to the requirements of AS9100, its flow down to sub-tier organizations is not typically mandatory, but a business decision.

The benefits are a seemingly uniform approach to the management system of their supply base. A disadvantage would certainly be the higher cost of working with a certified supplier with a demonstrated capability to understand customers’ needs and ensure that these direct and indirect costs are accounted for in their pricing model. The tradeoff, however, is that when a supplier has accounted for all their business costs, they’re more likely to remain financially solvent for years to come.