Q: Can you please explain API Q1, Clause 5.10.3?

A: This section of Q1 has always been a bit confusing.

As you will notice, there is no “accept-as-is” disposition in API Spec. Q1. API addresses this condition as “acceptance under concession.” Acceptance under concession outlines the steps a manufacturer must take in determining whether or not the product disposition can be accepted.

In essence this section is stating that you cannot have any nonconforming concessions that violate the company’s design acceptance criteria.

The company’s design criteria could include a plethora of input requirements from many different sources; however, it will also address API product specification requirements.

The methodology outlined in 5.10.3 takes you through the steps of nonconformance acceptance determination. You must read 5.10.3 along with the definitions of DAC (Q1, 3.1.8) and MAC (Q1, 3.1.15) in order to obtain a better understanding of its requirements.

Once you read through 5.10.3, “a” through “c,” you can better understand that API is providing the 3 methods of being able to accept a nonconforming condition. However, as part of the design changes, you must note that API product specification requirements may NOT be changed. Any changes to the API product specification requirements would be a violation of the API Monogram Program License Agreement.

5.10.3 Release of Nonconforming Product Under Concession

“The evaluation and release under concession of nonconforming product that does not satisfy manufacturing acceptance criteria (MAC) shall be permitted when the organization’s relevant authority and the customer (where applicable) have authorized the release provided that:

a) products continue to satisfy the applicable DAC and/or customer criteria; or
b) the violated MAC are categorized as unnecessary to satisfy the applicable DAC and/or customer criteria; or
c) the DAC are changed and the products satisfy the revised DAC and associated MAC requirements.”

3.1.8
Design Acceptance Criteria
DAC

“Defined limits placed on characteristics of materials, products, or services established by the organization, customer, and/or applicable specifications to achieve conformity to the product design.”

3.1.15
Manufacturing Acceptance Criteria
MAC

“Defined limits placed on characteristics of materials, products, and services established by the organization to achieve conformity to the manufacturing or servicing requirements.”

Note: If a company has a design exclusion, replace the term DAC with API product specification (and the spec. number). The conditions identified above will still apply. However, remember, that API Product Specification requirements may NOT be changed.

— Bud Weightman
President, Qualified Specialists, International