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Comments and Documents
Date/Time Commenter Comments Supporting Document
01/25/2017 11:34AM  Bonnie Dang  The change to para 11.1 of AR 29 should be resisted, we are not supporting it. It is badly worded and is likely to result in no-value-add findings during witness audits. Basically, the proposed change requires that if a single location is comprised of multiple co-located buildings (permitted for Single Site certification structure), the OASIS entry will have only one address / location, but our certificate will have to have some way of uniquely identifying and listing every building within the location. There are no qualifiers on the types of buildings that would be included, such as that they must be routinely occupied or otherwise have a direct contribution to the scope and value stream of the site. Many companies have unmanned storage sheds for hazardous materials, cold cells for composite raw materials, remote ordnance bunkers, utility enclosures for power panels, and tornado evacuation shelters. If we have to have auditors search these out for certificate documentation (itself a waste of auditor time), and we miss even one that is subsequently found on a witness audit, we may get a finding for a ‘defective certificate’.   
02/15/2017 3:56PM  Scott Neas  The changes to paragraph 11.1 are not value added and are not required per AS9104. By definition, there is not a “central function” for a single site by default as there is only one site, which is the controlling location and not a specific building. A “site” could consist of 1 to hundreds of buildings at a single location. Including this on a certificate does not add any value and is impossible to include in OASIS. This will also have a direct impact on valuable audit time and does not add or reduce any confidence of an organization’s QMS using the process approach. Also, if this requirement for a ‘single site’, would redefine the AS9104 definition of a site and require CBs to list every building for every site on a certificate. Suggest removing this change and matching the AS9104 requirements for certificate structure definitions.