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.”
Design Acceptance Criteria
“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.”
Manufacturing Acceptance Criteria
“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
Who We Are
Qualified Specialists, International (QSI) is a professional consulting, training, and management systems technology firm headquartered in Houston, TX. Founded by R.T. (Bud) Weightman in 1989, QSI has a global presence and has implemented and assessed management systems in over 28 countries world-wide – with certifications ranging from ISO 9001, ISO 14001, OHSAS 18001, API Spec. Q1 / Q2, and more.
Our specialty spans quality, health and safety, and environmental (QHSE), and our products and services have been applied in engineering, manufacturing, fabrication, distribution, service, projects, and operations.
We excel in helping our clients to achieve regulatory compliance, certification, and industry licensing through our superior software solutions, consulting services, and industry-leading training.
Bud Weightman, President of QSI, is an international management systems expert involved with management and technical systems for over 40 years. As President of QSI, Bud is involved with the industry committees responsible for emerging requirements, including: revision of API specifications, leading various API Task Groups, and lead auditor for the accreditation of SEMS Audit Providers through the Center for Offshore Safety. Bud’s experience includes working with ISO 9001, ISO 14000, and OHSAS 18000 management systems, as well as industry-specific certification schemes such as API Q1 and Q2, AS9100, ASME systems, and numerous other standards.
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