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1.0 Purpose: The purpose of this Procedure is to establish a documented process to implement and perform Layered Process Audit at ArvinMerito r LVS Plants. 2.0 Scope: 1. Responsibility: The Site Manager is responsible for the implementation of this procedure at the plant. The Operations Production Manager is responsible for the e!ecution of this procedure. The "uality Manager is responsible for the support in the e!ecution of this procedure. 2. Defi nit ions: Lay ered Process Audits: #t is a "ualit y #mp rovement sys tem involv ing multiple layers of management$ chec%ing the high&ris% items in the process. #t is an ongoi ng syste m of pro cess che c%s tha t verifi es if pro per met hod s$ setti ngs$ tools$ gage s$ oper ator craftsman ship$ error proof ing devi ces and other imp ort ant inp uts are in pla ce and being fol lo'ed in ord er to assur e product (uality. LPA Auditor: )mployee trained in the LPA concepts and in the application of the *hec% List. #n this 'ay everyone is an auditor for Layered Process Audits and do not need "uality Management System auditor training$ since they are not "uality Management System auditors. 3. Scope: The scope of a Layered Audit Process is limited to the identified processes and pr ocess st ep s re(uiring special attent ion due to their cr itical it y to customer satisfaction$ rather than being a broad chec% of process compliance. +ot %eeping LPA,s to their original intent by$ for e!ample$ broadening them to include all processes or not updating their (uestion sets$ 'ould li%ely reduce the benefits of the Audits and discourage their use.

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1.0 Purpose: The purpose of this Procedure is to establish a documented process toimplement and perform Layered Process Audit at ArvinMeritor LVS Plants.

2.0 Scope: 1. Responsibility: The Site Manager is responsible for the implementation ofthis procedure at the plant.The Operations Production Manager is responsible for the e!ecution ofthis procedure.

The "uality Manager is responsible for the support in the e!ecution of thisprocedure.

2. Definitions:Layered Process Audits: #t is a "uality #mprovement system involvingmultiple layers of management$ chec%ing the high&ris% items in the process. #tis an ongoing system of process chec%s that verifies if proper methods$settings$ tools$ gages$ operator craftsmanship$ error proofing devices andother important inputs are in place and being follo'ed in order to assureproduct (uality.LPA Auditor: )mployee trained in the LPA concepts and in the application ofthe *hec% List. #n this 'ay everyone is an auditor for Layered Process Audits

and do not need "uality Management System auditor training$ since they arenot "uality Management System auditors.

3. Scope:The scope of a Layered Audit Process is limited to the identified processesand process steps re(uiring special attention due to their criticality tocustomer satisfaction$ rather than being a broad chec% of process compliance.+ot %eeping LPA,s to their original intent by$ for e!ample$ broadening them toinclude all processes or not updating their (uestion sets$ 'ould li%ely reducethe benefits of the Audits and discourage their use.

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3.0Instruction:

LPA must be implemented 'here they 'ill be more effective and can be developed to beoperation specific$ process specific$ department specific$ product line specific$ etc.)ach plant must define for 'hich processes and product line they 'ill implement the LPA$based on critical items$ customer issues$ internal metrics$ systemprocess audit results andcustomer re(uirements.

#n order to be implemented 'ith focus and be successful$ it should be firstly implemented at apilot areaprocess - higher ris% or ne' line 'ith critical process - to create the culture atleadership level and evaluate the procedurechec% sheet and ma%e any correction beforeimplementing at other areas or processes.Audit Items:

 A cross&functional team - minimum 'ith "uality$ Manufacturing )ngineering andProduction & must be formed 'ithin the plant to develop the list of items for the LayeredProcess audit. The Audits must include 'hatever the plant believes is critical to product(uality and are typically those that are high ris% to customer satisfaction.Processes$ procedures and other aspects of the operation that are critical to ensureproduct (uality are items that should be considered and also the team must consider thestatus and importance of the related process - Safety or *ritical.

To be most effective$ LPA,s must be relative short in duration$ typically bet'een 1 to /0minutes depending upon line siecomple!ity and therefore should include items that canbe verified (uic%ly.

 All (uestions in the *hec%list must re(uire only a yes or no as an ans'er$ in order toavoid confusions and ma%e it simple and faster.The Layered Process Audit *hec% Sheet should contain specific items as listed belo' tobe audited as minimum2

• )rror proofing or error detection e(uipment

• Process machine parameters

• Set up result records - 3irst piece

• Product identification & *ontrol of non conforming parts

• 4ages and measuring e(uipment calibration

• Safety Procedures• 5ocumentation related to high&ris% items - 6or%ing instructions$ *ontrol plan$

records$ etc.

• *orrective actions from past (uality issues 7if applicable8

• 9e'or% procedure 7if applicable8

• "ualification of #nspectors and 6elders 7if applicable8

• Tor(ue monitoring 7if applicable8

Other items that could be included on the Layered Process Audit *hec% Sheet are2

• Visual Aids

• Stac%ing pac%ing re(uirements

• Preventive maintenance

• :ouse%eeping• Part feature inspection

• Traceability

• )nvironmental re(uirements

• Metrics update

• Tooling control

See attachment 1 for an e!ample of a LPA *hec% List.

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Audit Layers and re!uency:LPA gets its name from the re(uirement that multiple layers of the organiation conductthe same audit. LPA places these people ;'here the 'or% is being done< to verify criticalitems. This facilitates communication bet'een management and 'or%ing level teammembers and also demonstrates to all team members that these critical items are veryimportant$ because all levels in the plant are verifying that they are being done properly.The follo'ing levels and fre(uency are re(uired in order to ma%e LPA,s effective2

• Le"el 12 The Line or *ell Team Leader 'ill perform an audit every shift to assurethat the high&ris% items are in conformance 'ith the specifications or documentedprocess.

• Le"el 22 The Area Supervisor 'ill perform an audit on a daily basis to assure the

high&ris% items are under control and being verified every shift$ completing alsothe items assigned to his level.

• Le"el 32 The Area Manager 'ill perform an audit on a 'ee%ly basis to assure the

high&ris% items are under control$ being verified by the previous levels andcomplete the items assigned to his level.

• Le"el #2 The Site Manager 'ill perform an audit on a monthly basis to assure all

items are being verified by the previous levels and complete all items in the

*hec%list.• $%ecuti"e Le"el2 The Operations and "uality 5irector - or other business

e!ecutives & responsible for the plant$ 'ill perform a revie' during plant visits toverify compliance to LPA re(uirements. See section =.

#n case of smaller plants 'here the Operations structure is not as defined above$ otheravailable technical personnel - "uality #nspector and "ualityManufacturing )ngineers &may be used to substitute the Team Leader or Area Supervisor. The number of levelsmay be reduced to / only in case the plant 'or%s in only one shift or does not have thecomplete structure and technical personnel as defined above.

 A schedule for levels >$ / and ? must be prepared and communicated by the "ualityarea in order to define 'hich cellline 'ill be audited by each auditor. The responsibilityfor e!ecuting the LPA cannot be delegated by the auditor@ therefore any conflict in the

schedule must be agreed 'ith the "uality area at the beginning of the month.See attachment > for an e!ample of a LPA Schedule sho'ing Audit Areas$ Audit Layersand Audit 3re(uency.

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Audit &on'conformance Reaction Plan:The area leadersupervisor is responsible to solve any non&conformance detected duringthe LPA.+on&conformances detected during audits must be fi!ed immediately$ or an action planmust be developed 'ith responsible and timing clearly defined in order to be verified bythe area manager at least once per 'ee%.3or each item in the *hec%list it is necessary to have a documented reaction plan in

case the item is not in conformance. All non&conformances must be addressed using theappropriate defined reaction plan and documented by the auditor in an attachment ofLPA *hec%list.#t must be clearly stated in the reaction plan 'hen the non&conformance detected re(uiresstopping the linecell in order to solve it before resuming production. The reaction plan mayinclude a validated method for 100 containment of the identified non&conformance onparts already produced$ in order to avoid any suspect part going into ne!t steps of processor to the customer.Audit ()ners*ip:Operations Manager of the areas 'here the audits are conducted must o'n LPA.The "uality area and other functions must participate and support the Layered Process

 Audits System to be effective.

Operations manager must ensure the follo'ing2• Layered Process Audits are conducted on time and according schedule@

• Layered Process Audits are conducted by the designated team members@

• The results are recorded and revie'ed regularly@

• 9esources are available and focused on corrective actions for the non&

conformances identified.+onductin, Layered Process Audits:Once the *hec%list 'ith the audit items$ non&conforming reaction plans$ audit layers andfre(uency has been determined$ the trained auditors can begin conducting the LPA,s.The most significant part of the audit process is ensuring that the audits are performed toschedule and that the results of the audits are recorded.#t is imperative that site management instills discipline early in the process to completethe audits according to schedule$ sho'ing commitment to the LPA process.The results of all LPA,s must be 'ell recorded and maintained. The non&conformancesdetected must be vie'ed as an opportunity for improvement and the auditor must follo'the documented reaction plan to assure that containment 'as implemented if necessaryand record the actions on the *hec%list attachment.The auditor must advise the area supervisor before starting the audit and e!plain all non&conformances detected$ specially the ones that cannot be fi!ed immediately$ re(uiringan action that 'ill be follo'ed up by the leader.The plant should use the established corrective action procedure to resolve$ documentand report to management any systemic non&conformances detected during the LPA,s.

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Re"ie)in, LPA Results: A designated person in Operations should be responsible for summariing 'ee%ly theLPA results and report them to Operations Management and to "uality area$ 'ho 'ill beresponsible for revie'ing the non&conformances in such a 'ay that systemic issues -reoccurrences and trends &'ithin the areas can be identified and corrected across theentire plant and at other facilities.Operations Manager and Site Manager should conduct scheduled revie's of LPA results

in order to sho' management commitment to the audits and to have an opportunity tomonitor the impact of the Audits on the plant,s metrics. These revie's should beperformed during the monthly PO9 & Plant Operations 9evie'.The area must have a chart to summarie the Planned vs. Actual LPA,s performedduring the month and to summarie the Percent of Audited #tems in *ompliance.This chart must be displayed on the area metrics information board to be used on theteam meetings and the consolidated information must be displayed on the plant 'idemetrics information board-aintainin, Layered Process Audits:The items in the LPA *hec%list must be revie'ed regularly by the plant area teams$ toensure that it continues to include those items that are critical to (uality.#tems can be added to or changed in a LPA in situations such as the follo'ing2

+e' customer re(uirements@• +e' or modified procedures in the plant that are critical to product (uality@

• *orrective actions to address e!perienced (uality issues@

• *ritical to (uality items that must be communicated to all sta%eholders@

• +e' process setup re(uirements@

• Verification of corrective actions ta%en in response to previous LPA findings.

#tems can be deleted from a LPA in situations such as the follo'ing2

•  Automated e(uipment replaces a previously manual&dependent operation@

• )rror Proofing is added to an operation.

*areful analysis must be made before an item is deleted from a LPA$ because even ifautomated e(uipment replaces a manual operation$ it may be necessary to add itemsrelated to the ne' e(uipment in the *hec%list. *ustomer specific re(uirements should bereferenced and the customer contacted before deleting any item from the *hec%list.

 Any change on the LPA *hec%list must have the approval of "uality and Operationsareas.Auditin, +ompliance to Layered Process Audit Re!uirements:The Operations 5irector or the "uality 5irector responsible for the plant 'ill perform arevie' during plant visits to assure that the LPA System implemented in the plant meetsall the re(uirements from this procedure and customer re(uirements.This verification is not focused on the *hec%list items that an audit is to verify$ but toverify that the plant,s Layered Audit System 'as effectively implemented and is used todrive (uality improvement overall.See attachment / for an e!ample of Auditing *ompliance to LPA 9e(uirements.Reference:

• LPA Process 75*B8• "SC 9e(uirements 74M8

• *"#&D Layered Process Audits 4uideline 7A#A48

See flo'chart

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#.0 Procedure istory:Re" Le"el Date Re"ision +*an,e

Prepared Cy2 Edson Yamashita 10&0D&0=Director, Quality, Latin America 5ate

 Approval2 Stefan Land  10&0D&0=Vice President, Quality, LVS 5ate