While the aerospace industry pushes through the pandemic, it is important that the highest levels of quality are maintained throughout all Nadcap-accredited processes.
At this point in 2021, we have all felt the effects of the COVID-19 pandemic both personally and professionally. Since early last year, we have seen its effect on our economy and business alike. For thermal processors in the aerospace industry who are Nadcap accredited, there have been frequent questions regarding anything from audit scheduling and auditor/supplier safety to audit extensions. With that, the Performance Review Institute (PRI) and its staff have not been immune to the effects either.
I spoke with Scott Klavon, director of the Nadcap Program and Aerospace Operations at Performance Review Institute, about the effect the COVID-19 pandemic has had on PRI and Nadcap as well as suppliers. We discussed ways to mitigate potential issues as we work through this pandemic.
Scott Klavon Bio Prior to joining PRI, Klavon held a broad variety of positions at SAE International over a 22-year career culminating with a position as part of the executive management team. During Klavon’s tenure at SAE, the majority of his time was spent focused on management of SAE’s Aerospace Standards Program. Klavon helped lead the SAE Aerospace Standards Program to become the largest aerospace consensus standards development program in the world. Prior to joining the staff at SAE, Klavon was an aviation maintenance engineer at the Naval Aviation Depot Pensacola supporting the U.S. Navy and Marine Corps H-1 aircraft. Klavon began his professional career as a commissioned officer in the U.S. Navy. Klavon holds a bachelor of science degree in aerospace engineering from Pennsylvania State University and is a graduate of the University of Pennsylvania Wharton School Executive Development Program. Klavon is an associate fellow of the American Institute of Aeronautics & Astronautics, a fellow of the Royal Aeronautical Society and served as a board of director for the American National Standards Institute. Klavon is a chartered engineer in the United Kingdom. |
COVID-19 had a profound impact on the number of Nadcap audits conducted in 2020. Despite the challenges presented by COVID-19 such as governmental travel/access restrictions, auditee site access restrictions and auditor cancellations, the Nadcap program successfully conducted more than 4,000 face-to-face audits in 2020.
The COVID-19 situation has had a significant impact on audit scheduling with the need to reschedule audits coming from a number of directions:
PRI scheduling has had to be creative in its approach to find workarounds and satisfy as many of our customers as possible while prioritizing the safety and well-being of all Nadcap audit participants. This has necessitated measures such as rescheduling audits to group them according to location and relative to the auditor’s prior location. With the situation evolving rapidly around the world, even within national borders, this requires continual focus and audit schedule adjustment.
At this time, the process defined in Operating Procedure (OP) 1107 is being followed. The staff engineer has the ability to grant up to a three-month extension, and the task group can grant additional extensions up to a year total from the original expiry date.
A key point, however, is that extensions do not change the scheduling quarter or expiry date of the next audit. For example, if an accreditation was set to expire on April 30, 2020, and a six-month extension was granted due to the next audit being audit of quarter, the expiration would still be April 30, 2021, if the audit received a 12-month accreditation; it’s not based on the extension date.
Between March and October 2020, the reschedule fee was waived for all COVID-19-related Nadcap audit rescheduling and cancellation requests. In October, an adjustment was made, permitting only audits that had to be rescheduled or canceled due to governmental or travel restrictions to be exempted from the reschedule fee.
In addition, COVID-19-related requests to reschedule audits prior to 30 days of the audit start date, where there are no governmental or travel restrictions, will incur a reduced fee to cover the associated costs. Meanwhile, COVID-19-related requests to cancel audits within 30 days of the audit start date, where there are no governmental or travel restrictions, will incur the standard fee as defined in the Auditee Agreement (s-frm-1103).
PRI is working with the Nadcap Management Council to explore how we can continue to meet the needs of our customers during these challenging times. Virtual audits are one potential solution.
The Nadcap Management Council continues to drive toward identifying the optimal solution for the current circumstance. In the meantime, companies holding Nadcap accreditation have been able to request an accreditation extension of up to 12 months. This prevents accreditations from lapsing, but it can only be a temporary answer as it extends the period of time where the facility has not had a Nadcap audit.
This obviously creates risk for all stakeholders — from the special processors to the OEMs — so it is not ideal. It is also accreditation time “borrowed” against the next accreditation period, meaning that the time between the next two audits will be reduced. Again, this is not desirable in ordinary circumstances, but these are unusual times.
Nadcap auditors are independent contractors who have spent their careers developing their expertise within their special process field in the aerospace industry. They enjoy the opportunity that the Nadcap program provides: to travel, to maintain their industry knowledge and professional network, and to control their own work schedule.
PRI has coordinated with them to ensure that they, along with other Nadcap audit participants, are as safe as possible. A number of factors are taken into account, such as the availability of the qualified auditors, location of the auditors relative to the auditee, local and national COVID-19-related restrictions and pre- and/or post-travel quarantine requirements.
There has long been a goal to have PRI staff engineers qualified as Nadcap auditors, and many of them are. They are subject to the same requirement to conduct a minimum number of audits per year in order to maintain their qualified auditor status, as the other auditors are.
During this COVID-19 period, they have been fulfilling that requirement and supplementing the existing auditor capacity as needed. With fewer Nadcap audits being conducted compared to recent years, they have also had the opportunity to spend time on process improvements and other value-added activities.
As the COVID-19 pandemic evolves, the safety and well-being of all our stakeholders remain our highest priority.
Where it becomes apparent to the auditee that the audit will not be able to take place as scheduled, we are asking that they communicate that to PRI as soon as possible. This not only facilitates our audit administration but means that we may be able to offer the auditor replacement work and satisfy another customer by offering them that audit slot.
As we continue to conduct onsite audits in locations where the situation permits, we have a shared responsibility with the auditees to do as much as we can to mitigate the risk to all audit participants. We have asked that auditees assure the following measures are in place while the auditor is on-site:
We have asked our employees and independent contractors who are conducting Nadcap audits to observe the following precautions:
NCR responses are required to follow the requirements of OP 1106, which does not allow for extensions on response time. The cumulative delinquency day system — which permits up to 45 additional days — is available for those who are unable to respond by the required due date. This system is used in place of the ability to grant an extension.
However, exceeding seven cumulative days of delinquency prohibits the ability to achieve 24-month merit, exceeding 14 cumulative days of delinquency restricts the ability to obtain 18-month merit, and exceeding 30 cumulative days of delinquency could result in failure. However, Nadcap Task Groups have the ability to consider the current pandemic situation when making a determination on merit and failure.
As with the Nadcap program, PRI Training has been affected by the inability of individuals — both instructors and learners — to travel due to restrictions related to COVID-19. As you indicate, PRI Training was able to pivot relatively quickly to virtual training where the trainer and the learners are in separate locations, and the training is conducted live online. We are pleased to report that overall, demand for our training has remained high, and, in some cases, offering the courses online has allowed us to support a broader global audience.
Face-to-face training is still taking place where circumstances allow. We are being guided by local and governmental rules and guidance. Our customers and instructors and venue support are able to offer training with comprehensive social distancing measures in place. Private in-house training, where a number of people from the same company are trained at the company site, provides an even safer option, as only the instructor is new to the venue.
We recently also piloted a blended model where some of the learners were in the same room as the instructor, and others were participating virtually. This is, in a way, the optimal solution as it allows people to benefit from the training in the way that best meets their own needs.
Conducting Nadcap meetings virtually is not a new idea. It is something that has been considered for a number of years, and in fact, the Nadcap Management Council and Task Groups regularly hold their own meetings virtually in between the face-to-face Nadcap meetings that have traditionally taken place three times per year. COVID-19 hastened the implementation of full Nadcap meetings online. This has presented challenges, as you would expect. It is a significant shift in the organization and operation of the Nadcap meetings. In addition, Nadcap meetings are very interactive, with a large volume of subscribers and suppliers actively engaging in discussions for the betterment of the Nadcap program, the audit criteria and much more.
Facilitating these discussions online instead of face-to-face is a challenge. As Nadcap is a global program, another key challenge has been that the meeting times have not been ideal for participants in some parts of the world. We are grateful for the professionalism and support of our stakeholders as we adapt our practices for optimal online meetings.
The COVID-19 pandemic has not affected the revision of the pyrometry audit criteria — AC7102/8 - to bring it in line with AMS2750 Rev F. The checklist is being reviewed and modified by a Nadcap Heat Treat Task Group sub-team that meets between Task Group meetings, either by call or virtually or similar.
This working practice has not been changed by COVID-19, and the sub-team support remained strong. The Task Group then has the chance to review the checklist and make comments via a formal ballot process and at Task Group meetings, which are being held virtually. The AC7102/8 checklist revision is on schedule.
Absolutely. The staff engineers are a valuable resource prior to, during and after the Nadcap audit:
Due to the ongoing COVID-19 pandemic, there continued to be restrictions on travel and large gatherings in the build-up to, and at the time of, the Nadcap auditor conference. Consequently, after consultation with the Nadcap Management Council, PRI canceled the 2020 Nadcap auditor conference.
There is great value in holding annual auditor conferences face-to-face, so it was disappointing to miss the opportunity to interact in person with auditors, subscriber representatives and PRI staff members. In lieu of the 2020 auditor conference, Nadcap Task Groups provided commodity-specific refresher training online.
In August 2020, the MedAccred program (which is like the Nadcap program but for medical device manufacturers) published the following guidance for heat treaters in Industrial Heating magazine. It is also relevant for aerospace heat treaters.
Maintain your self-audit activity.
Even if it is limited to a desktop review at this point, ensuring a continued focus on your procedures and records means that they remain front of mind and may help to avoid silly mistakes once normal operations resume. This could be an opportunity for heat treaters to ensure that the following records are current:
Communicate openly and often.
Your customers, registrar, regulator, suppliers and other stakeholders want to know how you are doing. The performance of your business affects more than your business. We are all experiencing many of the same challenges, so you may be able to obtain extensions, waivers, etc., to cover you for this period.
Adapt where possible.
When “business as usual” is just not an option, work with your customers and regulators to identify what adaptations you can make that enable you to continue to provide the service they need at the level they expect. While you maintain control of any activity granted a temporary deviation from a requirement, avoiding the disaster of not returning to compliance once this situation has passed will be critical for ongoing conformity.
Update your process controls.
You must be able to demonstrate that you have reviewed the process control requirements for each of your customers and that you have an internal procedure and “system” that documents compliance, including other testing and controls required by specifications. Make sure that you have updated your internal documents to reflect any contingencies you have in place for the current situation. Some of the process controls to think about include:
Learn lessons from available data.
The Nadcap program publishes an overview of some common non-conformances that arise in heat-treatment audits. Any heat treater looking for opportunities to assure the robustness of their operation should consider the following:
While the aerospace industry pushes through this pandemic, it is important that we all maintain the highest level of quality throughout all of our Nadcap-accredited processes. PRI staff is working hard to manage their resources and help suppliers by having an open line of communication and maintaining flexibility.