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"PEAR Problem" being escalated to IAF

As I wrote elsewhere, the IAQG's response to the "PEAR controversy" is less than acceptable,
and introduces more problems than it solves.
As an update, the short version: auditors are requesting/requiring clients to pre-complete PEAR
(and, in some cases, even the OERs) prior to their AS9100 audits. Discussion of the problem
here on LinkedIn with the IAQG led to the IAQG shutting down their entire LinkedIn page, and
one AS9100 training organization threatening a lawsuit for having the discussion at all. A formal
request for clarification of the practice to the Accreditation Bodies got kicked up the chain to the
IAQG. The IAQG refused to respond formally, and instead sent me a personal email indicating
that the practice was acceptable. In Boeing's Tim Lee's view, an auditor can have the client
complete the PEAR (and other forms) prior to an audit -- INCLUDING EVIDENCE -- so long as
the auditor transcribes it later.

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Many have argued that this undermines the entire confidence in accredited certification audits.
having the client complete their own evidence reports prior to audit is a pretty amazing breach
of objectivity. The IAQG's position is that since there's no specific rule disallowing it, therefore it
is allowed.
Alas, there ARE rules disallowing it, and those are in the accreditation rules. Therefore, I (along
with some key clients of mine) are pushing the issue directly to the IAF for an official response.
We are making the case that allowing auditees to complete audit evidence forms violates the
entire concept of third party auditing, and becomes nothing more than self-declaration.
Because ANAB has expressed an opinion roughly in line with the IAQG, I have asked Randy
Dougherty to recuse himself, since he is both the VP of ANAB and the Chair of the IAF. I expect
this to be acceptable, as he's usually pretty good about these things.
Hopefully the IAF will step up to its mandated responsibility and address this once and for all,
so we can get accredited AS9100 certifications back on track.
4 months ago

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Jack Fletcher How long do you anticipate a response from them will take? (I've never
had any dealings with them.)
I'm kind of with you, in that this really seems like the auditors job.... but, what do I know?
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Christopher Paris To be honest I don't expect them to reply at all.
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David Uhrich Well done! I have been following your crusade to make AS relevant. In
May 2011 I wrote an article on 'What have they done to AS9100?' that a colleague posted
on Elsmar Cove. I'm sad to see that it turned out much worse (sillier?) than I predicted.

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4 months ago Like

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Christopher Paris If you, or anyone else, would like to co-sign the eventual escalation
document being sent to the IAF, just contact me privately.

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Christopher

Right now I am waiting to hear back from the IAF on the proper procedure for submitting
such a request.
4 months ago Like

Jeffrey Flatten The issue of having our organization complete the PEARS came up
during our upgrade audit to Rev. C. I refused outright to do it and forced it back on the
auditors. It worked for me, not sure what will happen the next time.
4 months ago Like
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personally don't see the production of PEARs as an auditee's role but I wonder if the
adoption of Issue C has resulted in the consistant application of the standard which I
thought was the IAQGs objective. I have to declare that I am a fan of AS9100 and the
application of systems thinking to QA but I do have concerns regarding its interpretation
and application.

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Christopher Paris The issue is being raised by individual auditors, acting (apparently)
without the permission or direction of their particular CB. Having said that, the CB's are
allowing their auditors to do so, and certainly not stopping the practice.

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The typical defense is that the CB/auditor may require the client to fill out the "header"
information on the PEAR. However, people disagree on which sections of the PEAR are
"header" info, and which are actual evidence. And in Tim Lee's response, he didn't make
that distinction at all, leaving the entire PEAR up for grabs.
This give the CB's an official green light to MAKE it official policy, thus passing off to
clients a service they are paying the auditors for, and in effect filling out their own
evidence.
I can tell you this: for all the clients who handed off the job of completing PEARs to me
(because their auditors required it), when I was done, those PEARs made the clients look
like miracle workers. I filled in every single field, and the auditors never made a peep.
They loved it. But let's be honest: it's cheating, and it has to stop.
4 months ago Like

Richard Murdock No where in AS9100C is AS9101D called out as the means to perform
internal audits (see 8.2.2). Also the scope of AS9101D (section 1.2) clearly states
AS9101D is to be used by CB's for certification. As with AS9100C no where in AS9101D
does it call for organizations to audit themselve using this standard.
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Christopher Paris To be clear, the CB auditors are not asking for PEARs as part of
internal audits, but to have the client prepare PEARs prior to the CB's EXTERNAL audit.
Meaning they are filling out the registrar's forms for them, ahead of time.
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I have had auditors ask to see some type of PEAR for internal use as well, but that's a
different argument entirely, and can be defeated exactly on the grounds you stated.
Likewise, the standard also does not require turtle diagrams, but auditors routinely ask for
them. Auditors routinely ask clients to grade internal audit findings as "major" or "minor"
even though it's not required for internal audits. If you read the standard closely, you find
that the standard does not even require objective evidence be put on an audit report, but
auditors will write you up if you don't have it. and of course they love writing
nonconformities against internal auditor training, even though the standard has no
requirements whatsoever for it.
4 months ago Like

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Richard Murdock Hi Chris, over the past year and a half, Ive been through three
AS9100C audits for clients and in each case the CB has specifically asked for PEARs
(internal) to be performed as this is the new approach to conducting audits. Once I pointed
out that I (acting as my clients internal auditor) did not use the PEAR form because it is
not required they all backed off. AS9100 only tells the reader what has to be done, not
how to do it. If all they wanted was for me to fill in the name of the processes I would have
been more than happy to accommodate them.
Since I started performing internal audits in 2006, I have always done so in a process
oriented fashion and found it to be far superior to just using the old clause method. Using
the process method we caught quite a few holes in processes that would never have been
found using the clause method. Interactions with supporting process, the inputs and
outputs between those processes went overlooked.
So in summary I believe that AS9100C should require organizations to employ a process
method as opposed to a clause based approach and leave it up to individual organizations
to best decide how they will show how they performed them.
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Lynn Cuperus We have implemented the forms from AS9101D into our internal audit
program, not because we find that it helps our work force to understand the external audit
outcomes, it forces newer auditors to follow the process and has enhanced our training. It
also helps us to better support our external auditors by talking from the same formats.
However, I don't fill them out for the auditor, that is their responsibility to measure our
compliance and effectivity.
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management likes the simple "rating system" to get a quick heartbeat on the health of
company processes.
But it's a METHOD, and the standard should not dictate methods. For example, IAQG
pulled out the AS9100 Rev B requirement for validation of test reports because it
considered that a "prescriptive" method, not a requirement. It's probably also why the
PEAR doesn't appear in AS9100, but instead AS9101.
As I told Tim Lee at IAQG/Boeing, there is no consensus that the PEAR form is the gold
standard for determining process effectiveness. It appears in no industry Bodies of
Knowledge, it is not trained on in universities (as, say, x-bar charts), and process
engineers have never heard of it. The IAQG invented in (in MS Word, I'd bet) out of thin
air, and now they are saying it will "teach companies about process effectiveness." It's not
the standard's job to teach, it is to provide an auditable benchmark.
This is being done because auditors are overworked, not paid for hotel and travel time,
and they can't get the work done in the audit days being charged by the CB's. I feel bad
for them, but they can't have clients do their work for them -- gross breach of impartiality.
3 months ago Like

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Jack Fletcher Chris, I don't think the "validation of test reports" was too prescriptive..... it
was just poorly understood. Basically, all it said was that if you rely on certs and supplier
provided test reports for acceptance, once in a while you should validate them to prove
that you aren't getting lied to. It never said how or how often.... that was left up to the
buyer. It needed some training material and suggestions.
3 months ago Like

Christopher Paris I was quoting IAQG. According to their official "comparison

document":

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"Deleted the requirement to validate supplier test reports. Test reports are a tool and
prescriptive, suggesting a "how to" and are not applicable to all stakeholders and for all
types of products."
They also did add "often misunderstood," however.
My point is that its difficult to see how the IAQG can issue that statement on test report
validation, and then come back and say forcing clients to complete PEARs is okay
because it's a teaching tool.
3 months ago Like

Richard Murdock One of my clients was written up a couple of years ago for not
validating test test reports from vendors. Validation came down to "were the correct tests
run and were the results of those test within specified tolerences". How they validated the
test report was up to them but they were required to perform a validation.
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I agree that the PEAR is a method and should not be dictated by IAQG or any other
agency. I would not have a problem with "suggested methods" within the aerospace
standards. The PEAR is not the end all to a perfect audit but the concept of process
auditing can be a very powerful tool to ensure there are no gaps within inter-related
processes.
3 months ago Like

Shirley Barras He's not hearing you :-)

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Christopher Paris Update: no update to update you with. IAF still in radio silence.
I'm told they are busy.
3 months ago Like
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Christopher Paris As predicted, IAF has "no problem" with the practice. Of course no
stakeholders were contacted to come up with this position, and it was only provided in a
hastily written email, in response to my query about HOW to ask the question. In short,
they provided the answer before they ever read the full problem.
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Worsening matters, the IAF email almost mirrors the IAQG one, and does not limit this to
merely PEAR "header" information. At least ANAB cited acceptable form fields a client
could complete. The IAQG and IAF make no distinction, effectively permitting every bit of
evidence on every related form to be completed by the client, so long as the auditor signs
off at the end.
The IAF even goes further, saying that this is in line with many "other accreditation

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evidence. The logic? Even though it says "the audit team" will gather evidence, since
there's no explicit rule to the contrary, ALLOWING the contrary is fine.
This is why the decision will have a snowball effect, far beyond the dopey PEAR form. The
IAQG and IAF are taking positions that ANY audit practice is allowed, provided that there
is no explicit rule preventing it... even if the practice violates core concepts like objectivity
and impartiality, or violates the CB/client contract (auditor offloading work that the client is
paying the CB for.)
CB's are going to take this and run with it. Imagine the savings!
Meanwhile, the CMMI guys will be rubbing their hands in glee. Smart customers will
continue to jump ship when they realize the IAF is asleep at the switch. Good day to be
the SEI.
This is a script playing out, so not much unexpected. What comes next will be interesting,
though. Keep watching!
My only concern: we're playing beat the clock. I can smell a disaster coming, and we need
to get this resolved beforehand, so that maybe we can prevent it, by returning audits to
some semblance of a responsible, professional activity. That will NOT be a day when I
want to say "I told you so."
3 months ago Like

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Richard Murdock When CB's ask my clients where the completed PEARS are, I will
refer them to 7.2.2 for internal audits. They all have planned internal audit schedules, audit
procedures, record keeping and CAPA in place. The only PEAR's they will be given are
those labeled "Internal Audit". If CB auditors expect us to do their job we should expect a
huge discount on their services. This has the decision of my clients so far. We'll see what
the future brings.
One of my clients told me last week that they have decided to opt out of their AS9100C
certification citing the lack of cost benefit. This company has no intention of eliminating
their QMS which was built around AS9100C and will continue to perform their own internal
audits.
They informed their aerospace customers last month of their decision and have told them
point blank that if they want to continue to receive quality products, then they will have to
accept this move. All of their aerospace customers have agreed to this which I found
surprising as well as a very bold move on their part. Well have to see how this plays out
over the next six months or so.
3 months ago Like

Christopher Paris I am now advising clients to hold off and implement ISO 9001 unless
there is a contractual mandate for AS91xx. It's a shame, I actually really like AS9100C.

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It's 9101D that's the problem. The audits by CB's are hell, and not because the standard
"has teeth" but because the audits are a clown show.
3 months ago Like

Richard Murdock Chris - I wish I could do the same but 90% of my clients are
aerospace suppliers and are contractually mandated to AS9100C and do not wish to rock
the boat. I'll attend the circus in two week at a clients facility.
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Christopher Paris A while back I added "Audit Defense Services" to my company's

offerings; basically help in crafting challenges to bogus CB findings (only after we have
confirmed them to be bogus.)
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This caused a ruckus on another forum among the general population of consultants who
prefer to kowtow (and collude, sometimes) with their client's CB auditors.
Ironically, I could now theoretically add "PEAR and AS9100 Audit Report Preparation"
services to my offerings, and I would not only be in complete compliance with the
standard, but the practice is actually ENDORSED by IAF.
Can you imagine the uproar? I'd love to see the fight play out, though. The other guys
wouldn't know WHO to side with -- the IAF? The CB's?
Going further, I actually got an email from someone at ANAB suggesting they would pass
my information around to companies needing PEAR preparation, if I wanted to start doing
this as a side offering. The rationale given was "it is a question of whether the client pays
you or pays the CB. I think CB auditor time is better spent confirming that the information
is accurate and then focusing on its effectiveness rather than having to add audit time to
complete the forms."
Never mind that (a) the client is ALREADY paying the CB to do this, and they'd be paying
double if they paid me, too, and (b) that the CB is supposed to GATHER the evidence, not
merely verify what PR nonsense the client has spoon fed them.

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