PIPING TECHNOLOGY & PRODUCTS, INC. P.O. Box 34506 Houston, TX 77234-4506 Supplier Type: OEM Facility Quality Manual

UNCONTROLLED COPY PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section0.2 Rev.D Rev. Date: 8/10/2011 Section Page 1 of3 TABLE OF CONTENTS & REVISION STATUS Uncontrolled Copy Do Not Duplicate GENERAL 0.1Manual ApprovalRev. C 0.2Table of Contents & Revision StatusRev. D 0.3Manual Revision LogRev. E SECTION 1 QUALITY POLICYRev. C SECTION 2 QUALITY OBJECTIVESRev. A SECTION 3 INTRODUCTIONRev. C SECTION 4 - QUALITY MANAGEMENT SYSTEMRev. E 4.1General Requirements 4.2Quality System Documents 4.3Control of Documents SECTION 5 - MANAGEMENT RESPONSIBILITYRev. E 5.1Management Commitment5.2Customer Focus 5.3Quality Policy 5.4Quality System Planning 5.5Responsibility Authority and Communication 5.6Management Review PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section0.2 Rev.D Rev. Date: 8/10/2011 Section Page 2 of3 TABLE OF CONTENTS & REVISION STATUS Uncontrolled Copy Do Not Duplicate SECTION 6 - RESOURCE MANAGEMENTRev. A 6.1Determination of Resource Requirements 6.2Provision of Resources 6.3Competency Awareness and Training 6.4Infrastructure and Facilities 6.5Work Environment SECTION 7 - PRODUCT REALIZATIONRev. B 7.1Product Requirements & Quality Objectives 7.2Customer-and Product Requirements 7.3Customer Communication 7.4Design and Development 7.5Purchasing 7.6Product and Process Control 7.7Validation of Processes 7.8Identification and Traceability 7.9Customer Property 7.10Preservation of Product 7.11Measuring and Monitoring Equipment PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section0.2 Rev.D Rev. Date: 8/10/2011 Section Page 3 of3 TABLE OF CONTENTS & REVISION STATUS Uncontrolled Copy Do Not Duplicate SECTION 8 - MEASUREMENT, ANALYSIS AND IMPROVEMENTRev. A 8.1Planning8.2Statistical Techniques 8.3Customer Satisfaction 8.4Internal Audit 8.5Monitoring of Quality SystemProcesses 8.6Monitoring and Measurement of Product 8.7Analysis of Data 8.8Control of Nonconforming Product 8.9Continual Improvement 8.10Corrective and Preventive Action PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section0.3 Rev.E Rev. Date: 8/10/2011 Section Page 1 of1 MANUAL REVISIONLOG Uncontrolled Copy Do Not Duplicated ApprovalsRev No. Effective Date Description of Revision SectionNo. Page No.V.P. Eng.QC Mgr. A6/19/06First Issue of DocumentAllAllR. BaileyH. Lippold D8/20/09Revised Table 4.3.5410R. BaileyH. Lippold D8/20/09Revised Organization Chart56R. BaileyH. Lippold C7/28/08Revised Quality Policy Statement11R. BaileyH. Lippold D8/20/09 Revised Section 4 to update record retention times. 411-12R. BaileyH. Lippold D8/20/09Revised Organization Chart56R. BaileyH. Lippold D8/20/09 General Requirements and Quality System Documents 4.1 & 4.2 1, 7R. BaileyH. Lippold C 7/28/08 Quality Policy11R. BaileyH. Lippold C 5/11/11 Introduction31R. BaileyH. Lippold D 8/20/09 Quality System Planning5.44R. BaileyH. Lippold C 8/10/11 Updated Manual Approval0.11R. BaileyA. Henrikson E 5/11/11 Added (3) ASMEsto the Quality Management System 4.2.55R. BaileyH. Lippold B 5/11/11 Updated Product Realization7.4.16R. BaileyH. Lippold E 6/10/11 Updated Organizational Chart5.5.15R. BaileyH. Lippold E 6/10/11 Manual Revision Log0.31R. BaileyH. Lippold PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section1 Rev. C Rev. Date: 7/28/08 Section Page 1 of1 QUALITYPOLICY Uncontrolled Copy Do Not Duplicate Piping Technology & Products, Inc. and its wholly owned subsidiaries, U.S. Bellows, Inc., SwecoFab,Inc.,andPipeShields,arecommittedtothecontinuousimprovementofour products and services.We understand the industry challenges; we eagerly serve not only our external customers, but also internal customers as well.Viewing ourselves as part of a team which includes our customers and suppliers, we understand our role in meeting the teams goal.Weplanandexecuteourworktomeetourcustomersspecifications.Working together we strive to... DO IT RIGHT THE FIRST TIME. Durga D. Agrawal, Ph.D., P.E. President PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section 2 Rev. A Rev. Date: 6/19/06 Section Page 1 of1 QUALITYOBJECTIVES Uncontrolled Copy Do Not Duplicate QUALITY OBJECTIVES ON-TIME DELIVERY OF CUSTOMER PRODUCT Ourtargetistoconsistentlymeetorexceedthedeliveryexpectationsofour customers 100% of the time. PRODUCT CONFORMS TO CUSTOMER REQUIREMENTS With qualified processes, personnel and procedures we aim to reduce our overall cost of poor quality. CONTINUAL IMPROVEMENT OF PROCESSES Bysystematicallyevaluatingourcoreprocessesduringimprovementinitiatives, process measurement, and management review, we aim to reduce operating cost. Durga D. Agrawal, Ph.D., P.E. President PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section3 Rev.C Rev. Date: 5/11/2011 Section Page 1 of1 INTRODUCTION Uncontrolled Copy Do Not Duplicate PipingTechnology&Products,Inc.anditswhollyownedsubsidiariesmanufacture products for the power, petrochemical, chemical and commercial markets. The scope of the quality management system described in this manual is for the manufacture and delivery of our Hot and Cold Pipe Supports product group. The purpose of this manual is: To define and describe the quality system To define authorities and responsibilities of the management personnel involved in the system Toidentifythegeneralproceduresusedforallactivitiescomposingthequality system Another purpose of this manual is to present the quality system to our customers and other external interested parties and to inform them of the controls that are implemented at Piping Technology & Products, Inc. to assure quality. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 1 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate 4.0 SCOPE ThissectiondefinesthescopeoftheQualityManagementSystemandthe documentation structure for control of the system documents and records. 4.1GENERAL REQUIREMENTS Piping Technology & Products, Inc. has established, implemented and maintained a quality management system and its effectiveness continually improved in accordance with the requirements of ANSI/ISO/ASQ Q9001. The quality management system has been implemented as follows: 4.1.1The Quality Manual provides the policy and intent of processes needed for the quality management system. Where any requirement of the International Standard cannot be applied and exclusion will be stated in Section 3 of the Quality Manual. 4.1.2The sequence and interaction of these processes is described in section 4.1.12 Quality System Description and graphically in Figure 4.1Quality System Structure. 4.1.3Theorganizationstructure,responsibilitiesandproceduresneededtoensurethe effective operation of the quality management process has been established in this Quality Manual with reference to documented Quality Assurance Procedures. 4.1.4Provisionofresourcesandinformationnecessarytosupporttheoperationand monitoring of these processes has been implemented. 4.1.5Regularmonitoring,measurementandanalysisofthequalitymanagementsystem processes are described in this manual. 4.1.6Any identified corrective, preventative and improvement actions are documented and implemented to ensure planned goals and continual improvement of these processes is achieved.4.1.7Outsourced Processes When processes that affect product confirmatory are outsourced, special controls are implementedtoensurethattheseprocessesmeetspecifiedrequirements.Such controlsmayinclude,asappropriate,evaluationandprequalificationofsuppliers, assessment of supplier realization process and requirements for inspection, testing or other records demonstrating product conformity, or containment and verification of the supplied product.4.1.8TheQualityManagerisresponsiblefordeterminingresourcesandinformation requirements necessary to support the operation and monitoring of the quality system processes and for communicating these requirements to Senior Management. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 2 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate 4.1.9TheQualityManagerreportstotheVicePresidentofEngineeringandQuality Assurance.TheQualityManageristhefacilityISOrepresentativeandhasthe authority to establish quality procedures, provide interpretation of customer quality requirements and management data reports. The Quality Department establishes and maintains a corrective action system and withholds from acceptance any product not meeting workmanship, standards, drawings and customer or contractual requirements.4.1.10The VicePresidentofEngineeringandQualityAssurance reports directly to the PresidentofPipingTechnology&Products,Inc.andisresponsibleforthe effectiveness and status of the quality system. Senior Management is responsible for ensuring the availability of necessary resources and information. 4.1.11Itistheresponsibilityofallcompanypersonnelinvolveddirectlyorindirectlyin meeting the stated quality goal and objectives and to dedicate their efforts towards the reduction, elimination and prevention of quality deficiencies. 4.1.12Quality System Description Adescriptionoftheinteractionbetweentheprocessesofthequalitymanagement system is described in the following paragraphs and illustrations in Figure 4.1 Quality System Structure (next page). A.Operating Processes Sales/Customer Services facilitate the negotiation of technical specifications and pricing agreements that are distributed to inside sales representatives for order taking. On going contact with the customer provides information tomanagement to respond to specific needs.During ordertaking the inside sales representative will determine the order requirements for delivery, pricing and generate a Job/Quote work order to describe and initiate the product realization and control process.Thecustomerinformationandproductspecificationsareenteredintoan electronic data base for tracking job status and answering customer inquires. The performance of product realization processes is monitored by measuring product characteristics resulting from the processes and through the program of inspections to the materials and product. The performance of processes required for the quality management system is monitored through internal quality audits. The overall performance of thequality system is monitored by measuring customer satisfaction. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 3 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate All activities are performed in accordance with Quality Assurance Procedures. Supplier control procedures ensure required materials, equipment andproducts are used in product manufacture. The customer product is identified and the inspection status is controlledduring manufacture, storage and shipping. The warehouse and shipping activities ensure the customer product is stored and shipped in accordance with applicable procedures. Figure 4.1 Quality System Structure SALESCUSTOMER SERVICESORDERTAKINGPRODUCTREALIZATION& CONTROLWAREHOUSE& SHIPPINGINVOICING& REPORTINGRequests For QuotesJ ob QuotePurchase OrderCustomer FeedbackVerbal OrderJ ob QuoteWork OrderProduction DrawingsJ ob FolderShop File FolderQuality Assurance ProceduresSupplier ControlPurchasingProduct IdentificationInspection & Test StatusControl of NonconformityIdentificationInventory ControlHandling PreservationShippingOPERATINGPROCESSES MANAGEMENT & SUPPORTACTIVITIES Develop and Manage Human Resources(Competence, Orientation, Qualification and Certification) Manage Physical Resources(Equipment Calibration, New Technology, Preventative Maintenance) Manage Information(Procedures, Records, Databases) Manage Improvement and Change(Business Objectives, Audits, Metrics, Opportunities, Customer SatisfactionPIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 4 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate B.Management and Support Activities In addition to the operating processes, the following management and support activities make up the quality system. *Developandmanagehumanresources: establish competencies, qualification and certification of required personnel, orientation of all personnel and onthe-job training as required.*Manage physical resources: provision for maintenance and calibration ofequipment,developmentofnewtechnology,maintenanceofbuildingsand storage areas, provide updated practical equipment and tools for employees. *Manage information: provision for establishment and maintenance ofprocedures, records and databases.*Manage improvement and change: establishment of company objectives,completionofinternalandexternalaudits,supplieraudits,measurementof service performance (metrics) including customer satisfaction, identification of nonconformance customer complaints and areas for improvement. 4.2QUALITY SYSTEM DOCUMENTS 4.2.1PipingTechnology&Products,Inc.qualitysystemdocumentationcomprisesthe following types of documents: 4.2.2Quality Manual 4.2.2.1 TheQualityManagerisresponsibleforthepreparation,approval,control, implementation, and updating of the manual. The manual is reviewed and approved by the Vice President of Engineering and Quality Assurance. 4.2.3Quality Assurance Procedures 4.2.3.1 TheQualityManagerisresponsibleforthepreparation,approval,control,and implementationandupdatingoftheprocedures.Theproceduresarereviewedand approved by the Vice-President of Engineering and Quality Assurance. 4.2.4Work Instructions 4.2.4.1 TheQualityManager,inconjunctionwiththerespectivedepartmentmanager,is responsible for the preparation, approval, control, implementation, and updating of work instructions. All work instructions are reviewed and approved by the Quality Manager and the General Manager of Manufacturing. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 5 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate 4.2.5Industry Standards 4.2.5.1 Allproductsofferedshallcomplywiththeindustrystandardslistedinparagraph 4.2.5.2 Related Industry Standards. 4.2.5.2 Related Industry Standards STANDARDTITLE AWS D1.1Structural Welding-Steel ASTM A36/A 36M-08Structural Steel ASTM A53/A 53M-07Black and Hot Dipped Zinc-coated Steel Pipe ASTM A123/A 123M-09Zinc Coatings on Steel Fabrication ASTM A153/A153M-09Hot Dipped Zinc Coated Hardware ASTM A307-07Bolts and Studs ASTM A325-10Bolts and Studs ASTM D1621-10Cellular Plastics ASTM D1622-08Cellular Plastics ASTM D1623-09Cellular Plastics ASTM D 4227-05Painter Qualification ASTM D4228-05Painter Qualification ASTM D4417-03Quality of Abrasives ASTM D4940-10Analysis of Water Soluble Ionic Contamination of Blasting Abrasives ASTM D 4285-83Indicating Oil or Water in Compressed Air ISO 9001-2008Quality Systems Management Systems MSS-SP-58-09Pipe hangers and support materials and design MSS-SP-69-03Pipe hangers and supports-selection and application MSS-SP-89 Pipe-03Pipe hangers and supports-fabrication and installation practices MSS-SP-90-00Guidelines on terminology for pipe hanger and supports. AWS.A2.4-07Standard Symbols for Welding, Brazing and Nondestructive Examination ASME B31.3 Process Piping ASME B31.1Power Piping ASME SEC. 9Qualification of Welding and Welders PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 6 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate 4.2.5.2 Related Industry Standards STANDARDTITLE SSPCPainting Manual Vol. 1 SSPCPainting Manual Vol. 2 SSPC-PA2Measurement of Dry Coat Thickness with Magnetic Gages SSPC-AB-1Requirements for Slag Abrasives SSPC-SP1Solvent Cleaning SSPC-SP5Very White Blast Cleaning SSPC-SP6Commercial Blast Cleaning SSPC-SP7Brush-off Blast Cleaning SSPC-SP10Near White Blasting 4.3CONTROL OF DOCUMENTS 4.3.1Documents in the quality management system are controlled to ensure the validity of all documentation that may have an influence on product quality. 4.3.2Document Approval and Issue 4.3.2.1 Allcontrolleddocumentsarereviewedandapprovedforadequacybyauthorized personnel prior to issue. 4.3.2.2 Documents are distributed to personnel and locations where they are used or needed for the effective function of the quality management system. 4.3.2.3 Distribution of procedures is through a transmittal receipt system which ensures the disposition of revised or outdated documentation. 4.3.2.4QAP-42-05DocumentControlMasterList is issued to identify the current revision status of controlled documents or data in the system. 4.3.3Document Changes 4.3.3.1 The quality manual and procedures are reviewed periodically to ensure they conform tothecurrentissueoftheinternationalstandard,regulatoryrequirementsand changing customer and company needs. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 7 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate 4.3.3.2 Theneedfordocumentrevisionisidentifiedduringinternalaudits,management reviews and nonconformance investigations. Any employee may submit a request for document change to the person responsible for review and approval. 4.3.3.3 If document revision takes place to correct a nonconformance, the outcome is verified to ensure the desired effect of the change was obtained. 4.3.3.4 Documentchangesarereviewed,updatedasnecessaryandapprovedbythesame authorityasfortheoriginaldocument.Pertinentbackgroundinformationshallbe made available for the review. 4.3.3.5 The controlling authority retains a copy of all previous revisions for historical or legal purposes (as electronic archives). 4.3.3.6 Obsolete controlled documents are promptly removed from all locations where they are used to control or verify a process. 4.3.3.7 A description of the changes made shall be noted in a revisions log contained in each document. 4.3.4Identification of Controlled Documents 4.3.4.1 Controlled or Uncontrolled documents within the scope of this quality manual may be issued to customer or other personnel outside the company at the discretion of the Quality Manager. 4.3.4.2 Uncontrolledcopiesofcontrolleddocumentsmaybemadeforinformationalor trainingpurposes,butshallbedestroyedafteruseorclearlymarkedas Uncontrolled. 4.3.4.3 Controlled documents shall be clearly identified as Controlled. 4.3.5Control of Records 4.3.5.1 Recordsarecontrolledtoensuretheyremainlegible,readilyidentifiableand retrievable.QAP-42-03ControlofQualityRecordsdefinestherequirementsand responsibilities for the identification, storage, protection, retrieval and disposition of records. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 8 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate 4.3.5.2 Retention periods vary with type of record and customer requirements. Table4.3.5 QualityRecordsRequirements (next page) specifies the record types and minimum retention time. 4.3.5.3 Pertinent supplier records are maintained as quality records. TABLE 4.3.5 Quality Records Requirements Record Responsibility Retention Time Sales/Customer Records Sales/Customer Serv. J ob File Folder 1 year Design Change Records Sales/Customer Serv. J ob File Folder 5 years Vendor/Sub Contractor Records Purchasing While subcontractor is still active Purchase Orders and Requisitions Purchasing Purchasing Dept. 1 year Training Records Safety Department QC Department 1 year after departure Calibration RecordsQualityManagerOnly current certificates Maintenance -Daily Maintenance Checklist -Equipment Maintenance Log Shop Foreman 1 year 1 year Nonconformance Reports Corrective ActionReports Verification of Purchased Product In-Process Inspections Final Inspections Control of Nonconforming Product Quality Manager1 Year Shipping Records Purchasing J ob File Folder 1 year PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section4 Rev.E Rev. Date: 5/11/11 Section Page 9 of9 QUALITY MANAGEMENT SYSTEM Uncontrolled Copy Do Not Duplicate TABLE 4.3.5 Quality Records Requirements (continued) Record Responsibility Retention Time Document Control Master List -Quality Assurance Procedures -Work Instructions -QualityManual Quality Manager3 Years Customer Feedback & ComplaintsCustomer Services/Sales1 year Internal Quality AuditsQuality Manager1 year Management Review Meetings Department Goals & Objectives Quality Manager3 years PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section5 Rev. E Rev. Date: 6/10/2011 Section Page 1 of6 MANAGEMENT RESPONSIBILITY Uncontrolled Copy Do Not Duplicate 5.0SCOPE Thissectiondefinesthemanagementresponsibilityandauthorityinestablishing, implementing, maintaining and continually improving the effectiveness of the quality system. 5.1MANAGEMENT COMMITMENT5.1.1SeniorManagement(PresidentandVice-President)iscommittedtothefurther development, implementation and continual improvement of the effectiveness of the Quality Management System.They demonstrate this commitment by: Communicatingwithdepartmentmanagementtheimportanceofmeeting customer as well as statutory and regulatory requirements Establishing the Quality Policy Ensuring that quality objectives are established through out the company Conducting a management review at least annuallyEnsuring the availability of resources 5.2CUSTOMER FOCUS 5.2.1Determining customer requirements 5.2.1.1 Customerrequirementsareunderstoodbroadlytoincludeallaspectsofproduct offeringandassociatedservicesthatarerelevanttocustomersatisfaction.When appropriate, this may also include customer needs and expectations. 5.2.1.2 Customerrequirementsaredeterminedandverifiedthroughtheprocessoforder review. This process is defined in this manual in Section 7.2 Customer and Product Requirements, and in procedures QAP-72-01 Order Processing for Catalog Products, and QAP-72-02 Order Processing for Custom Products. 5.2.2Meeting customer requirements 5.2.2.1 Allprocessesandelementsofthequalitysystemaredesignedandimplemented specifically to ensure that customer requirements are met. This starts with provision ofrequiredtraining,adequateinfrastructureandsuitableworkenvironment(see Section 6 Resource Management). Next is planning and implementation of reliable andeffectiveproductrealizationprocesses(seeSection7,ProductRealization). Finally, there are activities related to product and process monitoring and verification (see Section 8, Measurement, Analysis and Improvement). PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section5 Rev. E Rev. Date: 6/10/2011 Section Page 2 of6 MANAGEMENT RESPONSIBILITY Uncontrolled Copy Do Not Duplicate 5.2.2.2 Meetingofcustomerrequirementsismonitoredand/orverifiedbythemethods defined in Section 8 and in the associated procedures. Results of these verification activitiesarerecordedtoprovideevidenceofproductconformity,asdefinedin Section 4.3.5 Control of Records. 5.2.3Customer satisfaction 5.2.3.1 Focusing on customer requirements and on meeting these requirements should result in enhancing customer satisfaction. The level of customer satisfaction is used as a measureoftheeffectivenessofthewholequalitysystem.Specificmethodsfor determining customer satisfaction are defined in this quality manual in Section 8.3 andintheassociatedprocedureQAP-82-01CustomerSatisfaction.Thisvaluable information is reported and used as described in Section 5.6 Management Review. 5.3QUALITY POLICY 5.3.1Piping Technology & Products, Inc. Quality Policy (Section 1) defines the companys commitmenttocomplywithcustomerrequirementsandcontinuallyimprovethe effectiveness of the Quality Management System.Senior Management is responsible for reviewing the Quality Policy for continuing suitability. 5.3.2TheQualityPolicyprovidesaframeworkforestablishingandreviewingQuality Objectives (Section 2) at all levels of the organization.5.3.3The Quality Policy is implemented at all levels in the organization.All employees are required to follow the processes described in this manual and supporting Quality System Procedures. 5.3.4TheQualityPolicyispostedinhightrafficareasofeachfacilityandprovidedin written form to each employee. 5.4QUALITY SYSTEM PLANNING 5.4.1Quality Objectives 5.4.1.1 Senior Management is responsible for establishing the Quality Objectives (Section 2) thatwillensuretheimplementationoftheQualityPolicyandthefacilitationof continual improvement. 5.4.1.2 Quality Objectives are reviewed at the annual Management Review (see QAP-56-01 Management Review) PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section5 Rev. E Rev. Date: 6/10/2011 Section Page 3 of6 MANAGEMENT RESPONSIBILITY Uncontrolled Copy Do Not Duplicate 5.4.1.3 Departmentmanagementisresponsibleforestablishingobjectivesthatare measurable and specific to the services that department provides consistent with the Quality Objectives.They are reviewed for effectiveness prior to the Management Review and reported up to Senior Management. 5.4.1.4 Datafrommeasurementofobjectivesisreviewedperiodicallybydepartment management.Record of quality actions deployed to achieve the Quality Objectives is maintained. (see QAP-42-03Control of Quality Records) 5.4.2Quality Management System Planning 5.4.2.1 TheQualityManual,QualityAssuranceProcedures,WorkInstructionsandother referenceddocuments(referencedinSection4.2)provideevidenceofQuality Planning for the Quality Management System in order to meet the requirements of our customers and ISO 9001. 5.4.2.2 PlanningforObjectivesandrecordingtheactivitiescompletedoccursduringthe Management Review (see QAP-56-01 Management Review). 5.4.2.3 Changes to the Quality Management System occur from time to time as a result of changingcircumstancessuchasorganizationalchange,continualimprovement activities or changing customer needs.Senior Management has the responsibility and authority for the following: EnsuringthatprocessandresourceplanningfortheQualityManagement System meet the requirements of ISO 9001, the company quality policy and objectives Maintaining the integrity of the Quality Management System when changes to the Quality Management System are planned and implemented 5.5RESPONSIBILITY, AUTHORITY AND COMMUNICATION 5.5.1Responsibility and Authority 5.5.1.1The QualityManager is authorized to prepare, implement and maintain the Quality Program described in this manual. 5.5.1.2 TheQualityManagerhastheauthoritytoresolveallqualitymatterswithinthe facilityandtoliaisewiththecustomersonallqualitymatterspertainingtothe product line. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section5 Rev. E Rev. Date: 6/10/2011 Section Page 4 of6 MANAGEMENT RESPONSIBILITY Uncontrolled Copy Do Not Duplicate 5.5.1.3 Department Managers/Supervisors are responsible for implementing and effectively maintainingqualitysystemprocessesinaccordancewiththisQualityManualand supportingprocedures.Thisincludeslocaltrainingrequirements,document maintenance, reporting, and equipment maintenance and calibration. 5.5.1.4 The Quality Steering Committee is responsible for quality system document reviews and making strategic decisions for ISO 9001 implementation. 5.5.1.5 The Management at Piping Technology & Products, Inc. is represented in Figure 5-1 ManagementOrganizationChart(nextpage).Theindicatedpersonnelhavethe responsibility to achieve and maintain a high standard of quality in the products and services provided and have the freedom and authority to: Identify and record a problem Investigate the cause of a problem Initiate, recommend or take preventive or corrective action Verify implementation of preventive or corrective action Interrupt or modify processing until an unacceptable condition is corrected PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section5 Rev. E Rev. Date: 6/10/2011 Section Page 5 of6 MANAGEMENT RESPONSIBILITY Uncontrolled Copy Do Not Duplicate 5.5.1 Responsibility and Authority (continued) Figure 5-1 Management Organization Chart PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section5 Rev. E Rev. Date: 6/10/2011 Section Page 6 of6 MANAGEMENT RESPONSIBILITY Uncontrolled Copy Do Not Duplicate 5.6MANAGEMENT REVIEW 5.6.1The purpose of management review is to: Evaluate the suitability, adequacy and effectiveness of the quality system Consider changes to the quality management system and to the quality policy and quality objectives Identifyopportunitiesforimprovementofthequalitysystem,processesand products. 5.6.2Management reviews are chaired by the QualityManager and are attended by the VicePresidentEngineering&QA, and all designated department managers as specified in QAP 56-01 Management Review. 5.6.3Management reviews are conducted at least once a year. More frequent reviews are scheduled in periods when organizational or product changes, or other circumstances require increased attention and input from senior management.5.6.4Input into the management reviews consists of information and data related to quality performance of the organization. At a minimum, this includes: Results of auditsCustomer feedback and complaintsProcess performance and product conformance dataStatus of preventive and corrective actionsChanges that could affect the quality systemFollow-up actions from earlier management reviews Recommendations for improvement5.6.5Section 8.7 Analysis of Data and procedure QAP-56-01ManagementReviewdefine the scope and method of presentation of the input information and data. 5.6.6Managementreviewsareconcludedwithactionsrelatedtoimprovementofthe qualitymanagementsystemandimprovementofprocessesandproductstobetter meet customer requirements. The review also identifies resource needs to implement these actions. 5.6.7Results of management reviews are documented in minutes of the review meeting. Theminutesincludeimprovementactionitemsresponsibilityassignmentand resource allocation for implementation. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section6 Rev.A Rev. Date: 6/19/06 Section Page 1 of5 RESOURCE MANAGEMENT Uncontrolled Copy Do Not Duplicate 6.0SCOPE Resources required for the implementation and improvement of the quality system, and for addressing customer satisfaction, may include people, suppliers, information, infrastructure,workenvironment,andfinancialresources.Thissectiondescribes those activities.6.1DETERMINATION OF RESOURCE REQUIREMENTS6.1.1TheQualityManagerandothermanagementpersonnelinvolvedintheQuality System are responsible for determining resource requirements for the implementation and improvement of the system. 6.1.2TheSales/CustomerServicesManagerisresponsiblefordeterminingresource requirements for addressing customer satisfaction. This is based on input from other managementpersonnelresponsibleforactivitiesrelevanttoparticularaspectsof customersatisfaction.ProcedureQAP-82-01CustomerSatisfactionexplainshow information about customer satisfaction is collected and analyzed. 6.1.3The principal forum for determining and communicating resource requirements are managementreviewsofthequalitysystem.ProcedureQAP-56-01Management Review explains this process. 6.2PROVISION OF RESOURCES6.2.1SeniorManagementhastheauthorityandresponsibilityfortheprovisionof resources. 6.2.3Allocationofresourcesforparticularactivitiesisintegratedwiththeprocessof defining and initiating the activity. It may take the form of personnel assignments, allocation of space or equipment, training, procurement decisions, budgets, etc.6.2.4AllocationofresourcesmaybedocumentedintheQualityManual,Quality AssuranceProcedures,minutesofmeetings,memoranda,oranyotherform. Approvals of resource allocations may also be communicated verbally with follow-up documentation.6.2.5Managementreviewofthequalitysystemistheprincipalforumforallocationof resources for the operation and improvement of the system. All actions initiated by thereviewaresupportedbyallocationofspecificresourcesnecessaryfortheir implementation. Procedure QAP-56-01 Management Review defines this process. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section6 Rev.A Rev. Date: 6/19/06 Section Page 2 of5 RESOURCE MANAGEMENT Uncontrolled Copy Do Not Duplicate 6.3COMPETENCY AWARENESS AND TRAINING 6.3.1The Human Resources department is responsible for identifying training needs and awarenessprogramsforcompany-wideparticipation,suchas:generalorientation, rules and regulations and other company-wide systems and issues. 6.3.2 The Quality Manager, in coordination with Department managers, is responsible for identifyingandprovidingISOorientationandqualitysystemtrainingtoall employees.6.3.3 The Safety Department is responsible for identifying and providing training to all employees on safety requirements and responsibilities. 6.3.4Departmental managers are responsible for identifying competency requirements and trainingneedsintheirdepartments,andforestablishingdepartmentaltraining programs. Departmental training is primarily focused on increasing the level of skills in operating equipment and processes and conducting inspections and tests. 6.3.5Trainingneedsmaybeidentifiedinresponsetocorrectiveorpreventiveaction requests (CARs), as nonconformities caused by inadequate training. 6.3.6Piping Technology & Products Inc. provides, or supports, the following categories of company-wide and departmental training and awareness programs: GeneralISOorientationandqualitysystemawarenesstrainingexplains howtheproductisusedandhowthequalitysystemworkstoensureproduct quality. Provided to all employees. Safetytraining Instructs in safe working practices, use of personal protective equipment, first aid, etc. Provided to all employees. Useofcompany-widesystemsExplainsinterdepartmentalsystems,suchas productnumberingrequirements,inventorysystems,useofcomputers,etc. Provided to wide groups of employees. ExternaltrainingExternalseminars,conferences,andcourses.Providedto individual employees on as-needed basis. Self-studyReadingmagazines,books,andreports.Whileallemployeesare encouraged to broaden their knowledge through reading, in some cases self-study may be required as formal training. Skilltraininginengineering,production,andqualitycontrol departmental training in specific skills. Often provided as on-the-job training. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section6 Rev.A Rev. Date: 6/19/06 Section Page 3 of5 RESOURCE MANAGEMENT Uncontrolled Copy Do Not Duplicate 6.3COMPETENCY AWARENESS AND TRAINING (continued) 6.3.7Procedure QAP-62-01TrainingandAwareness describes in detail the training and awareness programs provided by Piping Technology & Products, Inc. 6.3.8Effectiveness of training is evaluated using the following approaches: Follow-up performance evaluation of trained employees Review of the overall performance in areas relevant to particular training programs Considerationofcompetencyandtrainingwheninvestigatingcausesofquality system failures and product or process nonconformities Aglobalreviewofalltrainingandawarenessprograms,conductedwithinthe framework of management reviews of the quality system 6.3.9ProceduresQAP-62-01TrainingandAwareness,andQAP-56-01Management Review,describesthemethodsforevaluatingparticularcategoriesoftrainingand awareness programs. 6.3.10Trainingrecordsareestablishedforalltypesoftraining.Recordsarenormally establishedandmaintainedbythedepartmentthatprovidesthetraining.Human Resourcesmaintainqualificationrecords,andmayalsohavecopiesofsome departmental training. 6.4.INFRASTRUCTURE AND FACILITIES 6.4.1Planningofnew,and/ormodificationofexistinginfrastructureandfacilitiesare usually conducted in conjunction with product or process changes; capacity and/or work force expansions; and other such events. Facilities may also be expanded or modified to improve productivity and/or quality, or to improve the work environment. 6.4.2Departmental managers are responsible for identifying the need and requirements for new, and/or modification of existing infrastructure and facilities in their departments. Requests for significant changes and/or expansions of facilities are submitted to the top management for review and approval. 6.4.3When relevant, Quality Assurance reviews the proposed facilities changes to ensure that they enhance the achievement of product conformity and quality. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section6 Rev.A Rev. Date: 6/19/06 Section Page 4 of5 RESOURCE MANAGEMENT Uncontrolled Copy Do Not Duplicate 6.4.4SupportingservicesrequiredbyPipingTechnology&Products,Inc.include transportation, communication, and Information Technology services:Transportationservicesareusuallypurchasedfromparceldeliveryandcourier services,andfromtruckingorothertransportationcompaniesorconsolidators. PurchasingoftheseservicesismanagedbytheShippingDepartment,andis conductedinaccordancewithproceduresQAP-74-01SupplierEvaluation,and QAP-74-02 Purchasing. Communication services are provided by various telephone, wireless, and internet accesscompanies.InformationTechnologyservicesisresponsiblefor administrating and coordinating these contracts. ITsystemsmaybedesignedandimplementedbyexternalconsultants,andare operatedinternallybytheInformationTechnologyDept.Thesecontractsare managedbytheITdepartment.Controlofdocumentsanddataontheinternal network system is governed by procedure QAP-42-02 Control of Documents. 6.4.5Maintenance of buildings and facilities is performed by the Maintenance Department or by external contractors. This includes regularly scheduled maintenance of lighting systems, air conditioning and heating systems, landscaping, and cleaning. Repairs of buildings and other such facilities are contracted as needed. Purchasing is responsible for coordinating and managing maintenance contracts. 6.4.6Key process equipment, machines, hardware, and software are regularly maintained inaccordancewithmaintenanceplansspecifiedbyequipmentmanufacturersor departmentalmanagersresponsiblefortheequipment.Requirementsforthe maintenanceofproductionequipmentarespecifiedinprocedureQAP-63-01 Equipment Maintenance. 6.5WORK ENVIRONMENT 6.5.1Human Resources and departmental managers are responsible for ensuring suitable social and psychological conditions in the workplace. This is to include such aspects asinteractionandcommunicationbetweenemployees,employeeharassmentand conflictresolution.Relevantworkplacepoliciesareimplementedmainlythrough training and awareness programs and, where necessary, disciplinary actions. (Refer to procedure QAP-62-01 Training and Awareness.) PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section6 Rev.A Rev. Date: 6/19/06 Section Page 5 of5 RESOURCE MANAGEMENT Uncontrolled Copy Do Not Duplicate 6.5.2ProductionandQualityAssuranceareresponsibleforidentifyingthoseoperations whereextremeenvironmentalconditionscouldimpactquality,performanceof personnelandresultinproductnonconformities.Whereappropriate,limitsof exposureand/ormitigatingmeasuresshallbedefinedandimplementedforthese operations. 6.5.3Thehealthandsafetymanagementsystemisindependentfromthequality management system. It is administrated by the Safety Director and is documented in the company Safety Policy and Procedures Manual. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 1 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.0SCOPE This section describes Piping Technology & Products, Inc. methods for planning and developing the processes needed for product realization. 7.1PRODUCT REQUIREMENTS AND QUALITY OBJECTIVES 7.1.1Product requirements and quality objectives for product manufacture are defined and communicatedindrawingsandspecifications,contractdocuments,internaland externalstandards,productionshopfiles,andapplicablelegalandregulatory requirements. 7.1.2For custom products manufactured to customer design (or custom changes to standard catalogproducts),productrequirementsandqualityobjectivesarespecifiedinthe technicaldocumentationprovidedbythecustomer.Sales/CustomerServices, Estimating,Engineering/DesignLiaisonandQualityAssurancereviewthese specifications before acceptance of the contract and commencement of production, as instructed in procedure QAP-72-02 Order Processing for Custom Products.7.1.3Forstandardcatalogproductsthatmeetfunctionalandperformancerequirements definedbySales,productrequirementsandqualityobjectivesaredeterminedby Piping Technology & Products Inc.7.1.4Product realization planning includes, as applicable: Definition and evaluation of manufacturing operations and processes Development of adequate and capable processes Identificationofspecialprocessesandconsiderationofassociatedrisksand consequences Establishment and implementation of appropriate process control measures Development of instructions and training for process operators Requirements for records necessary to demonstrate process conformity 7.1.5ProductrealizationplansareestablishedincollaborationbetweenProduction, Engineering/DesignLiaison,andQualityAssurance.Theplansaredefinedin various types of production documents, such as process flowcharts, production shop files, and work instructions.7.1.6Productverificationandvalidationplansdeterminetheinspectionandtesting programforaproduct,andformaterialsandcomponentsincorporatedintothe product. This includes: PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 2 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate Identification of inspection and testing points, Inspection and testing scope and frequency Acceptance criteria Requirements for records necessary to demonstrate product conformity 7.1.7QualityAssuranceandtheEngineering/DesignLiaisonareresponsiblefor development of product verification plans. The plans are defined in various types of documents, such as specifications, production shop files, purchasing documents, and inspection and testing procedures. 7.1.8ProceduresQAP-74-03VerificationofPurchasedProduct;QAP-82-04In-process Inspections;andQAP-82-05FinalInspection,explainhowoutputsofproduct verification and validation planning are used. 7.2CUSTOMER AND PRODUCT REQUIREMENTS7.2.1Catalog Versus Custom Products 7.2.1.1 In determining and reviewing customer and product requirements, Piping Technology &ProductsInc.distinguishesbetweenordersforstandardcatalogproductsand custom products. 7.2.1.2 Standardcatalogproductsareproductsmanufacturedfromengineeringstandard specificationsandwithoutanymodificationorcustomizing.Customproductsare products designed and/or manufactured to unique customer requirements. 7.2.2Catalog Product Requirements7.2.2.1 Forstandardcatalogproducts,ordersarereviewedinconjunctionwithorder processing.Thesemaybeproductavailability,deliveryrequirements,special packaging or handling requirements, etc. Procedure QAP-72-01 Order Processing for Catalog Products, instructs on how to carry out this review. 7.2.3Custom product requirements7.2.3.1 Forcustomproducts,productrequirementsaredeterminedandreviewedbythe Sales/CustomerServicesManager.ThisofteninvolvesinputfromEngineering, Production, Purchasing, Estimating and Quality Assurance, depending on the nature and complexity of the order, and whether a similar order has been recently processed. 7.2.3.2 Customproductrequirementsaredeterminedandreviewedwithregardto requirementsspecifiedbythecustomer;otherrelevantproductrequirementsnot specifiedbythecustomer,andthecompanyscapacityandcapabilitytomeetall PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 3 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate applicablerequirements.ProcedureQAP-72-02OrderProcessingforCustom Products, instructs on how to carry out this review. 7.2.4Incomplete or conflicting requirements 7.2.4.1 Any incomplete or conflicting requirements are resolved with the customer before acceptance of the order. 7.2.5Verbal orders 7.2.5.1 Verbal orders are confirmed before acceptance. This may be by repeating the order requirements back to the customer, or by sending a confirming fax or e-mail.7.2.6Amendments 7.2.6.1 Change orders are received and reviewed by the same functions that are responsible for the review of the initial orders. J ob Revisions are communicated to all functions within the organization that may be affected by the change of customer requirements.ProceduresQAP-72-01OrderProcessingforCatalogProducts,andQAP-72-02 OrderProcessingforCustomProducts,provideinstructionsonhowtoprocess change orders. 7.2.7Records7.2.7.1 Reviewsofproductrequirementsarerecorded.Establishmentandmaintenanceof contract review records are explained in procedures QAP-72-01 Order Processing for Catalog Products, QAP-72-02 Order Processing for Custom Products, and QAP-42-03 Control of Quality Records. 7.3CUSTOMER COMMUNICATION7.3.1Product Information7.3.2TheSales/CustomerServicesdepartmentisresponsiblefordevelopingthecontent andformatforcompanysbrochures,catalogs,internetsite,andotherformsof promotionalandproductinformationmaterial.Thisisbasedontechnical specifications developed by Engineering. 7.3.3Mastercopiesand/orfilesofdocumentscontainingproductinformationare controlled. They are reviewed and approved before release, and identified by a unique numberandarevisionlevel.Supersededandobsoletematerialsarewithdrawnto prevent them from being passed or communicated to customers. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 4 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.3.4OnlydesignatedpersonnelfromSales/CustomerServicesandEngineeringare authorized to communicate with customers regarding product information. The Sales managerisresponsiblefordesignatingthesepersonnel,andsupportingthemwith training and current product information. 7.3.5Inquiries and order handling7.3.5.1 TheSales/CustomerServicesdepartmentisresponsibleforreceivingcustomer inquiries and orders. Orders for standard catalog or custom products are reviewed and further processed by the Sales/Customer Services department. Inquiries and orders for custom products may be reviewed by the Sales Manager. Engineering, Production, Purchasing, and Quality Assurance departments. 7.3.5.2 Handling of order amendments is controlled to the same extent as the handling of initialorders.Amendmentsarereviewedtoverifythatthenewormodified requirementscanbemet,andaconfirmationofacceptanceissentbacktothe customer. 7.3.5.3 ProceduresQAP-72-01OrderProcessingforCatalogProductsandQAP-72-02 OrderProcessingforCustomProducts direct how to handle inquiries, orders, and amendments for standard catalog products and custom products, respectively. 7.3.6Customer feedback and complaints7.3.6.1 Customer Service department is responsible for receiving and processing customer feedback and complaints. All received customer communication is recorded in the customer feedback and complaints log. 7.3.6.2 Customer feedback and complaints are classified into categories to allow for better tracking of trends and evaluating improvement in specific aspects. Every complaint is communicatedtorelevantfunctionswithinandoutsidetheorganization. Sales/Customer Services, the responsible department, and Quality Assurance decide how to respond to the customer and, when appropriate, what corrective or preventive actions should be implemented internally. 7.3.6.3 ProcedureQAP-72-03CustomerFeedbackandComplaintsprovidesdetailed instructionsonhowtoreceive,process,andrespondtocustomerfeedbackand complaints. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 5 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.4DESIGN AND DEVELOPMENT 7.4.1Piping Technology has the ability to design and develop Hot and Cold Pipe Supports. All Design and Development activities are in accordance to Procedure QAP-73-01 7.4.2Design Changes 7.4.2.1 AlldesignchangesaredoneinaccordancetoprocedureQAP-73-01Designand Development 7.5PURCHASING 7.5.1Supplier Evaluation 7.5.1.1 All new suppliers are evaluated with regard to their quality and process capability. Purchasing and Quality Assurance establish the criteria for selection of suppliers, and conductsupplierevaluation.SuppliersareratedAPPROVED,PROVISIONAL,or NOTAPPROVED.TheApprovedandProvisionalsuppliersareenteredonthe approvedsupplierlist.Existingsupplierswithasatisfactoryqualityperformance historymaybeexemptedfromtheinitialevaluationandbeinitiallyratedas APPROVEDorPROVISIONAL.Recordsoftheinitialsupplierevaluationare maintained.SupplierevaluationprocessisgovernedbyProcedureQAP-74-01 Supplier Evaluation. 7.5.2Supplier Quality Performance Monitoring 7.5.2.1 Qualityperformanceofsuppliersismonitored.Suppliersshowinginadequate performance may be asked to implement corrective actions, and be downgraded to the PROVISIONAL rating. If the requested corrective actions are not implemented and there is no improvement, the supplier is further downgraded to the NOT APPROVED ratingandisdiscontinued.Recordsofsupplermonitoringandre-evaluationsare maintained. The system for monitoring suppliers is defined in procedure QAP-74-01 Supplier Evaluation 7.5.3Approved Supplier List7.5.3.1 Purchasingmaintainsanapprovedsupplierlist.Ordersmayonlybeplacedwith vendors that are on the list. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 6 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.5.4Purchasing Information 7.5.4.1 Purchasing documents are prepared by the Purchasing department. The documents clearlyandcompletelydescribeorderedproducts,includingpreciseproduct identificationandqualityrequirements.Purchasingreviewsandapprovesall purchasing documents prior to release. 7.5.4.2 Thepreparation,review,andapprovalofpurchasingdocumentsareexplainedin procedure QAP-74-02 Purchasing.7.5.5Verification of Purchased Product 7.5.5.1 Purchased products are inspected by the receiving clerk. This includes verification of productidentityandquantity,visualinspectionand,whereapplicable,verification that all requested certificates and quality records are available. Designated products are further inspected or tested by QC. 7.5.5.2 QCinspectionortestingmaynotbenecessarywhenproductsaresuppliedwith recordsorcertificatesdemonstratingconformity;orwhenthesupplierisqualified based on their quality system certification or supplier audits, and a satisfactory quality performance history. 7.5.5.3 QualityAssuranceisresponsibleforselectingappropriatemethodsforpurchased product verification and acceptance. Procedure QAP-74-03 Verification of Purchased Product sets forward detailed rules for selecting product verification methods. 7.5.5.4 Whenverificationofpurchasedproductistobeperformedatsupplierspremises, purchasing documents specify the intended verification arrangements and method of product release.7.6PRODUCT AND PROCESS CONTROL7.6.1Information specifying product characteristics is communicated to production in the form of drawings, specifications, instructions, production work orders, and product-specifictemplatesandothertooling.Thisinformationiscontrolledinaccordance with procedure QAP-42-02ControlofDocuments. The Engineering, Production and Quality Assurance departments determine the scope, form, and distribution of product specifications. 7.6.2Productandprocessinformationrequiredbyprocessoperatorsiscommunicated throughaproductionShopFilefolderwhichisissuedtorelevantsectionsofthe Production Shop. Procedure QAP-75-01 Production Control describes this process. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 7 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.6.3Work Instructions7.6.3.1 Work instructions may be in the form of manuals, procedures, sheets, posted signs, or samples. They instruct on how to carry out a local process or perform an operation or task.Theneedforworkinstructionsisevaluatedonthebasisofcriticality, importance and complexity of the process; the ability to verify results of the process; operator qualifications; and history of quality problems associated with the process.7.6.3.2 Procedure QAP-42-04 Work Instructions specifies criteria for determining when work instructionsareneededandprovidesguidelinesforissuing,authorizingand controlling work instructions. 7.6.4Equipment Maintenance7.6.4.1 Maintenanceofkeyprocessequipment,machines,hardware,andsoftwareare addressed in procedure QAP-63-01 Equipment Maintenance. 7.6.5Measuring and Monitoring Equipment7.6.5.1 Requirements for measuring and monitoring equipment are determined by Production andQualityAssurance.Thisisinaccordancewithproductverificationprograms defined in product realization planning (refer to Section 7.1.4 of this manual). 7.6.5.2 The control system for measuring and monitoring equipment is defined in procedure QAP-76-01 Measuring and Monitoring Equipment. 7.6PRODUCT AND PROCESS CONTROL (continued) 7.6.6Process Monitoring and Control7.6.6.1 Processes are monitored and controlled through a variety of approaches, activities and techniques. The system is designed to control: Information, material and human (operator) input into the processProcess environment and performance Process output ProcessmonitoringactivitiesarefurtherdefinedinSection8ofthismanual.Activities related to process control are defined in procedures QAP-75-01 Production Control; QAP-42-04 Work Instructions; and QAP-82-03 Statistical Process Control. 7.6.7Product Release and Delivery7.6.7.1 Productsarereleasedfordeliveryonlyafterallspecifiedactivitieshavebeen satisfactorily completed and conformity of the product has been verified.Procedure PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 8 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate QAP-82-05FinalInspectiondefinesthesystemforfinalproductverificationand release. 7.7VALIDATION OF PROCESSES 7.7.1Special ProcessesProcesses where the resulting output cannot be verified by subsequent measurement or monitoring are designated as special processes. 7.7.2ProductionandQualityAssuranceareresponsibleforidentifying,validating,and documenting special processes. Where applicable, the Engineering department may assist with establishing validation specifications and testing of samples. 7.7.3Specialprocessesarevalidatedandcontrolledbyapplicablemethods,suchas destructivetestingofproductsamples,equipmentandpersonnelqualification,and work instructions and process procedures. 7.7.4ProductionandQualityAssuranceareresponsibleforselectingandimplementing appropriate process validationand control measures for each special process. At a minimum, all special processes are documented in work instructions. 7.7.5Special process records are established and maintained as appropriate. Depending on the control measures implemented, these records may include process qualification and validation reports, maintenance records, inspection and testing reports, operator qualification and training records. 7.8IDENTIFICATION AND TRACEABILITY 7.8.1Purchasedproductsareidentifiedwithuniquenumbers,colors,ornames.The identificationisthesameas,oriscross-referencedwith,thedesignationsusedin drawings,specifications,billsofmaterials,partslists,purchaseorders,work instructions, etc. Purchased products are identified by marking, labeling, or tagging the products or their packaging, or by identification of the area where the products are held. 7.8.2During all stages of production, products are identified by a production J ob Number and other documents contained in the J ob File and Shop File folder that accompany them through the production cycle. Parts and components may also be identified by labels or tags, or the containers in which they are held. 7.8.3Finalproductsareidentifiedbytheirmodelnumberorsize,whichislabeledor marked on the products and/or is printed on the primary product packaging. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 9 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.8.4Rules and activities related to identification of products are governed by procedure QAP-75-03ProductIdentificationandTraceability. Additional relevant procedures are: QAP-75-01 Production Control; QAP-74-03 Verification of Purchased Product; QAP-82-05 Final Inspection; and QAP-75-06 Packaging, Labeling and Shipping. 7.8.5Traceability7.8.5.1 When required by contracts, laws and regulations, or voluntary standards traceability isimplementedtotheextentspecified.Traceabilitymayalsobeimplementedfor internal reasons to facilitate corrective action. 7.8.5.2 Asrequired,traceabilitymayapplytomaterials,components,parts,production processes,environmentalconditions,inspectionandtesting,andpersonnel responsible for processing and verification of products. The scope of traceability is documented in product manufacturing specifications or the production Shop File. 7.8.5.3 Activitiesrelatedtoestablishmentandmaintenanceoftraceabilityisregulatedby proceduresQAP-75-03ProductIdentificationandTraceability,andQAP-75-01 Production Control. 7.8.6Inspection Status Identification7.8.6.1 Following every inspection or test, products are identified to indicate whether they have passed or failed the inspection. This is to prevent nonconforming product from being used or dispatched. Physical location of product can only be used as inspection status identification when the location is designated and contained. 7.8.6.2 QCinspectors,receivingclerks,andproductionpersonnelauthorizedtocarryout inspections and testing are responsible for identifying product inspection status. All personnel handling products are responsible for maintaining the identification. 7.8.6.3 Products that have passed the receiving inspection are moved to the material stock locationsordesignatedmaterialstagingareasinproduction.Whereintermingling with other product is a possibility, the inspected items are also appropriately tagged or labeled.Detailedrulesforidentifyinginspectionstatusofpurchasedproductsare provided in procedure QAP-74-03 Verification of Purchased Product. 7.8.6.4 Statusofanin-processinspectionisidentifiedbyasign-offontheproduction Traveler document accompanying the product. The status may be also identified by tagging or labeling, or holding products in designated containers or area. Procedure QAP-82-04 In-process Inspections provides detailed instructions. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 10 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.8.6.5 Products that pass the final inspection are stamped by the QC Inspector with a QC number stamp. Approval for product release is indicated on the work order on the line wherethefinalinspectioniscalledout.Rulesforidentifyinginspectionstatusof finished products are provided in procedure QAP-82-05 Final Inspection. 7.8.6.6 Products that fail any inspections or tests are labeled with a REJ ECTED sticker or tag, and are segregated and/or quarantined. Whenever a nonconforming product is identified, the nonconformity is documented using a Nonconforming Product Report. ProcedureQAP-83-01ControlofNonconformingProduct,instructsonhowto identify and process nonconforming product. 7.9.CUSTOMER PROPERTY7.9.1Customer-supplied products are received and inspected following the same procedure that applies to purchased products - QAP-74-03 Verification of Purchased Product. In the event the supplied products fail receiving inspection or are not suitable for any other reason, the customer is contacted. 7.9.2Marking, Storage, and Handling7.9.2.1 Marking, storage, handling, and preservation of customer supplied products follow the same procedures that apply to purchased products. The applicable procedures are QAP-75-03,ProductIdentificationandTraceability; QAP-75-04ProductHandling and Preservation; and QAP-75-05 Storage Areas.7.9.2.2 Customer-owned tooling and returnable packaging are permanently marked so that ownership of each item is visually apparent. 7.9.2.3 Customers software, documents, and other intellectual property are protected to the sameextentasinternaldocumentsofsimilarcontent,unlesstherearecontractual requirements for special measure to protect customers intellectual property. 7.9.3Special Requirements 7.9.3.1 When specified in a contract, special handling instructions from customers will take precedent over the company's standard procedures.7.9.4Loss or damage 7.9.4.1 Customers are contacted in the event of loss, damage, deterioration, or unsuitability of their products. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 11 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.10.PRESERVATION OF PRODUCT7.10.1Production is responsible for product handling and preservation; and in particular for ensuringthatcontainersholdingproductsaresuitableandingoodcondition,that equipmentusedforinternaltransportationofproductsiswellmaintainedandis properly operated, and that products are adequately protected during production and storage. Procedure QAP-75-04 Product Handling and Preservation describes in detail how these policies are implemented.7.10.2Stock locations, storage, staging and holding areas are controlled by the department that brings in new stock or uses the area. Only products that are properly identified and that have passed required inspections are authorized to enter and leave the stock locations.7.10.3When special storage conditions are specified (for example, temperature or humidity), productsarestoredinspecialrooms,boxes,orcontainerswherethespecified conditions can be continuously maintained. These special conditions are monitored to ensurethattheyaremaintainedwithoutinterruptionandthattheproductisnot compromised at any time.7.10.4Products with limited shelf life are identified with expiration dates. These perishable products are also rotated in their stock locations to ensure that the oldest product is used first.7.10.5ProcedureQAP-75-05StorageAreasgovernstheoperationofstockroomsand storage, staging and holding areas. 7.10.6Primarypackagingsareboxes,bagsorotherpackaginginwhichproductsare presented to the end users.7.10.7Packagingandlabelingoperationsarecontrolledfollowingthesamepoliciesand procedures that apply to production operations and processes. Product packaging and labelingaredefinedindrawings,specificationsandworkinstructions.When appropriate,personnelinvolvedwiththeseprocessesareprovidedwithwork instructions and/or special training.7.10.8The Shipping Department is responsible for establishing specifications for secondary packagingandlabeling.Thespecificationsarecompatiblewithrequirementsof commonlyusedcarriersandforintendedmeansofdelivery(ground,sea,air). Packagingspecificationsaredocumentedindrawings,writtenstandards,and/or packaginginstructions.Packagingspecificationsaremaintainedandcontrolledby Shipping. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 12 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.10.9Packaging and labeling activities are governed by procedure QAP-75-06Packaging, Labeling and Shipping. 7.10.10Shipping of finished products is initiated by the shipping order. The order identifies the shipping consignee address, shipping due date, products to be shipped, labeling requirements,andtransportationmodeorcarrier.Beforeproductsaredispatched, shipping personnel verify that the shipment contains the same products and quantities asspecifiedintheshippingorder,andthatpackagingandlabelingconformwith customer and/or carrier requirements. Only orders that have been verified and signed off by the shipping department can be loaded for shipment. 7.10.11Activitiesrelatedtoshippinganddeliveryoperationsareregulatedbyprocedure QAP-75-06 Packaging, Labeling and Shipping. 7.11MEASURING AND MONITORING EQUIPMENT 7.11.1Thescopeofthecalibrationcontrolsystemextendstothemeasuringandtest equipment, comparative reference hardware (such as gauges and templates), and test software used for: Monitoring of environmental conditions Verification of product conformity Operations where defined accuracy of a measurement is required to assure product conformity 7.11.2Equipmentusedforotherpurposesmaybeexemptedfromcalibration.Such equipment is labeled with stickers warning that it is not calibrated or calibration is not required. Uncontrolled measuring equipment is prohibited in QC inspection areas and during QC inspection processes. 7.11.3Gauges, instruments, and other measuring and monitoring equipment are selected on the basis of their capability to provide the necessary accuracy of the measurement. Quality Assurance is responsible for selecting appropriate measuring and monitoring equipment. 7.11.4QualityAssuranceisresponsibleforcalibratingandmaintainingmeasuringand monitoringequipment.Allactiveequipmentisinventoriedinacontrolledlist, indicating equipment calibration status and location. 7.11.5Measuringequipmentiscalibratedusingwritteninstructions,unlesscalibrationis simpleandobvious.Onlycalibrationinstrumentsandstandardshavingknown relationship to the nationally recognized standards are used for calibrating measuring and test equipment. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section7 Rev. B Rev. Date: 5/11/11 Section Page 13 of13 PRODUCT REALIZATION Uncontrolled Copy Do Not Duplicate 7.11.6Calibration is recorded in a calibration record and the calibrated equipment is labeled with a calibration sticker. 7.11.7Calibration-related activities are regulated by procedure QAP-76-01Measuringand Monitoring Equipment. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 1 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.0SCOPE Thissectiondescribestheimplementation,monitoring,measurement,analysisand improvement process utilized in product manufacturing. 8.1.PLANNING 8.1.1Measurement and monitoring activities to assure and verify product conformity are definedinengineeringspecificationsanddrawings,productionJ obFiles,and inspection and testing procedures. 8.1.2Theeffectivenessofthequalitysystemismonitoredbyinternalauditsandby measuring quality performance and customer satisfaction. Results of these activities arereportedtothetopmanagementandareusedtoidentifyopportunitiesfor improvement.8.2STATISTICAL TECHNIQUES (may be applied to) Testing and validation of processesEstablishment of sampling plans for inspections and testingEvaluation of measurement systems Analysis of quality performance and other company-level data 8.2.1Departmental managers are responsible for identifying the need for using statistical techniques in their departments and in other activities for which they are responsible. Quality Assurance may be called upon to assist other departments in selecting and documenting specific techniques. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 2 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.3.CUSTOMER SATISFACTION 8.3.1TheSales/CustomerServicesdepartmentisresponsiblefordevelopingsuitable indicatorsofcustomersatisfaction,andfordefiningmethodsforcollectingand analyzing the pertinent information. 8.3.2Information and data pertaining to customer satisfaction are collected from several sources. Specifically, these are: Customer feedback and surveys,Product returns and warranty claims,Repeat customer rates, andMarket share. 8.3.3ProcedureQAP-82-01CustomerSatisfactiondefinesthesystemforcollectingand analyzingthepertinentinformationanddata,andforreportingresultstothetop management. 8.3.4Customer complaints, spontaneous expressions of satisfaction, and other unsolicited customerfeedbackarecollectedandprocessedbytheSales/CustomerServices Department.TheseactivitiesaredefinedinprocedureQAP-72-03Customer FeedbackandComplaints. The resulting data is periodically analyzed by the Sales manager, and is presented and discussed at management review meetings. 8.3.5TheSales/CustomerServicesdepartmentconductsquarterlycustomersatisfaction surveys. Survey results are compiled and analyzed, and are combined with customer satisfactiondataforcompatibleaspectsofproductsandservices.Conclusionsare presented and discussed at management review meetings. 8.3.6Information about the rate of product returns and warranty claims is extracted from accounting,quality,andservicingrecords.Resultsandtrendsarereportedand analyzed at management review meetings. 8.3.7Sales records are periodically analyzed to identify repeat customers and track their ordering frequencies and patterns. The ratio of repeat customers is one of the most importantindicatorsofcustomersatisfaction.Statisticsonrepeatcustomers frequencies and trends are presented and discussed at management reviews. 8.3.8The Sales/Customer Service department is responsible for collecting and analyzing dataregardingcompetition,competitiveproducts,andmarketshare.Thisdatais periodically analyzed and presented at management review meetings. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 3 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.4INTERNAL AUDIT 8.4.1The QualityManager establishes an internal audit plan and schedule in accordance with procedure QAP-82-02 Internal Quality Audits. Every activity and area is audited at least once a year. Selected activities are audited more frequently, depending on their importance and quality performance history. 8.4.2Only personnel independent of the audited activities are assigned to conduct internal audits. The Quality Manager leads the audit team except when QA activities are being audited.AuditsofQAactivitiesareusuallyconductedbyadesignatedoutside auditor. 8.4.3Auditorsprepareforauditsbyreviewingapplicablestandardsandprocedures, analyzing quality records, and establishing questionnaires and checklists. Selection of auditors and preparation for the audit are explained in procedure QAP-82-02 Internal Quality Audits. 8.4.4Conducting the audit, auditors seek objective evidence indicating whether the audited activities comply with the requirements of the documented quality system and ISO 9001,andwhetherthequalitysystemiseffective.Theevidenceiscollectedby observing activities, interviewing personnel, and examining records. 8.4.5Nonconforming conditions are documented and recorded using the Nonconformance Report (form number QAP-85-02-form 1).Instructions on how to use the form are providedinprocedureQAP-85-02NonconformanceCorrective&Preventative Action. 8.4.6Audits are conducted in a way that minimizes disruption of the audited activities. 8.4.7Whennonconformingconditionsareidentified,themanagerresponsibleforthe affected area or activity is requested to propose and implement a corrective action. Implementation and effectiveness of the action are verified by a follow-up audit. The CorrectiveActionResponse(formnumberQAP-85-02-form2)isusedfor verification and recording the implementation of the corrective actions. 8.4.8When the auditing cycle is completed, all nonconformity reports established during the cycle are compiled and analyzed, and are presented at the management review meeting. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 4 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.5.MONITORING OF QUALITY SYSTEM PROCESSES 8.5.1Quality system processes are monitored by variety of approaches and techniques, as appropriate for a particular process and its importance. These include: Conducting internal audits of the quality system; Monitoring trends in corrective and preventive action requests; Analyzing product conformity and other quality performance data and trends; Measuring and monitoring customer satisfaction; 8.5.2Whenaqualitysystemprocessdoesnotconformwithrequirements,Quality Assurancemayrequestthemanagerresponsiblefortheprocesstoimplementa correctiveaction,inaccordancewithprocedureQAP-85-02Correctiveand Preventive Action. 8.6.MONITORING AND MEASUREMENT OF PRODUCT 8.6.1Inspection and testing requirements for a product are defined in the customer Shop File folder which contains various types of documents, such as product drawings and specifications, production work orders, purchasing documents, inspection and testing procedures.8.6.2Verification of purchased product: All purchased products are subjected to a visual inspection by the receiving clerk, and then some designated products are subjected to a more detailed and technical QC inspection. Procedure QAP-74-03Verificationof PurchasedProductsetsforwarddetailedrulesforperformingreceivingandQC inspections. 8.6.3In-process inspections: In-process inspections may be in the form of operator or QC defined inspections, random inspections, or defined sampling inspections. The focus isondefectpreventionratherthandetection.In-processinspectionactivitiesare regulatedbyproceduresQAP-82-04In-processInspections,andQAP-82-03 Statistical Process Control. 8.6.4Finalinspection: Finished products are subjected to the final QC inspection. First, inspectorsverifythatallspecifiedreceivingandin-processinspectionshavebeen carriedoutsatisfactorily.Thentheyperformtheremaininginspectionsandtests necessary to complete the evidence of product conformity. Only products that pass the final inspection can be shipped. Procedure QAP-82-05 Final Inspection regulates these activities. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 5 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.6.MONITORING AND MEASUREMENT OF PRODUCT (continued)8.6.5Results of inspections and tests are recorded. Instructions for establishing records for specifictypesofinspectionsaredefinedinproceduresQA-74-03Verificationof PurchasedProduct,QAP-82-04In-ProcessInspectionandQAP-82-05.Final Inspection. Filing and maintenance of inspection records are regulated by procedure QAP-42-03 Control of Quality Records. 8.6.6Productsarereleasedfordeliveryonlyafterallspecifiedactivitieshavebeen satisfactorilycompletedandconformityoftheproducthasbeenverified.Only personnel performing final product inspections and tests have the authority to release products.Theidentityofthepersonauthorizingproductreleaseisrecorded. Procedure QAP-82-05 Final Inspection defines specific methods for product release. 8.7ANALYSIS OF DATA 8.7.1Dataandinformationrecordedinqualityrecordsarecompiledandanalyzed periodically to determine trends in the performance and effectiveness of the quality system and to identify opportunities for improvement. 8.7.2Quality Assurance is responsible for coordinating these activities, and for reporting conclusionsandtrendstothetopmanagement.Thisisusuallydonewithinthe frameworkofmanagementreviewsofthequalitysystem,inaccordancewith procedure QAP-56-01 Management Review. 8.7.3Thefollowingcategoriesofinformationanddataarerecorded,compiledand analyzed: 8.7.3.1 Conformity to product and customer requirements: Product/ProcessNonconformancesauditnonconformancerecordedinaudit findings, nonconforming product reports - reviewed for trends by QA. On-timedeliveryperformancerecordedincustomerfeedbacksurveysand evaluated for trends by the General Manager. 8.7.3.2 Suppliers: Supplierqualityperformancerecordedinsubcontractorqualityperformance files and evaluated for trends by Purchasing and Quality Assurance. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 6 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.7ANALYSIS OF DATA (continued) 8.7.3.3 Customer satisfaction and dissatisfaction: Customersatisfactionlevelsrecordedincustomersatisfactionsurveysand reports(QAP-82-01-CustomerSatisfaction)andevaluatedfortrendsbythe Sales/Customer Services department. Customercomplaintsrecordedincustomersatisfactionsurveysandreports (QAP-82-01 Customer Satisfaction) and evaluated for trends by the Sales/Customer Services department. 8.7.3.4 Quality System: Effectiveness of training recorded in evaluation reports (QAP-62-01-Training and Awareness) and evaluated for trends by departmental managers. Effectiveness of quality system recorded in internal audit reports (QAP-82-02 Internal Quality Audits) and evaluated for trends by top management. 8.8CONTROL OF NONCONFORMING PRODUCT 8.8.1PipingTechnology&ProductsInc.identifiesanddocumentsallproduct nonconformitiesthatcannotbeeasilyorcosteffectivelyresolved.Product nonconformity records are invaluable for tracking performance and trends, and for identifying areas where corrective or preventive actions should be implemented. 8.8.2Nonconforming products are documented using a Nonconforming Product Report. It describesthenonconformity,documentsthedispositiondecision,andrecords closeout of follow-up activities (re-inspection, concessions, corrective actions, etc.). TheuseofNonconformingProductReportanditsprocessingareexplainedin procedure QAP-83-01 Control of Nonconforming Product. 8.8.3Topreventnonconformingproductsfrombeingusedorshipped,theproductsare marked with a REJ ECTED tag or sticker and are segregated when applicable. 8.8.4QC inspectors and the production foreman may make the disposition decision for a nonconformingproductwhenitisobviousthattheproductmustbescrapped,re-graded, returned to vendor or when it can be reworked by a simple process without affecting its quality or appearance. In all other cases, the Quality Manager together with production and, when required, the Engineering / Design Liaison are responsible for making disposition decisions. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 7 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.8CONTROL OF NONCONFORMING PRODUCT (continued) 8.8.5Thedispositiondecisionmaybe:Rework, Repair,UseAs-Is,Re-grade,Returnto Vendor or Scrap. 8.8.6Detailed rules for nonconformity review, for making the disposition decision, and for recordingtheseactivitiesareprovidedinprocedureQAP-83-01Controlof Nonconforming Product. 8.8.7Repairedorreworkedproductsarere-inspectedinaccordancewithapplicable proceduresQAP-74-03VerificationofPurchasedProduct;QAP-82-04In-process Inspections; or QAP-82-05 Final Inspection, as applicable). 8.8.8When product nonconformity is detected by the customer after delivery or use has started,thecustomerisinstructedtoreturntheproduct,orapart,throughthe Sales/Customer Services department for evaluation. 8.8.9When product nonconformity is detected internally after delivery or use has started, customers are informed and instructed what to do with the product. In situations when the nonconformity may create a safety or other hazard, the product may be recalled. Only the General Manager is authorized to make recall decisions. 8.9CONTINUAL IMPROVEMENT 8.9.1Opportunitiesandprioritiesforimprovementareidentifiedbycomparingpresent quality performance to objectives defined in the quality policy and quality objectives.8.9.2Qualityperformanceisdeterminedbyanalyzinginformationaboutcustomer satisfaction, records of product and process nonconformity, results of internal audits, and other data and information relevant to quality performance. Section 8.7 Analysis of Data, defines the scope and system for collecting and analyzing such information. 8.9.3Qualityperformanceisevaluatedbymanagementreviewsofthequalitysystem. Where quality performance falls short of a defined objective, the management review identifiesspecificimprovementactionstoreachtheobjective.Whenaquality objective is reached, the management review may set a new, higher objective in this area and specify new improvement actions for reaching it. 8.9.4Theprocessoffacilitatingcontinualimprovementthroughtheuseofthequality policy,objectives,andanalysisofdata,isdefinedinproceduresQAP-85-01 Continual Improvement, and QAP-56-01 Management Review. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 8 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.9CONTINUAL IMPROVEMENT (continued) 8.9.5Inadditiontomanagementreviews,departmentalmanagersidentifyimprovement opportunitiescontinually,basedondailyfeedbackfromtheiroperationsandother activities. Employees are also encouraged to come forward with ideas for improving products,processes,systems,productivity,andworkingenvironment.These improvement opportunities are evaluated and prioritized by Quality Assurance and, where appropriate, are implemented though the system of corrective and preventive actions. 8.9.6Improvement projects are usually implemented through management review actions andthroughcorrectiveandpreventiveactions.Whereappropriate,improvement projects may be also initiated by management directives, such as policy statements, announcements and memoranda. 8.10.CORRECTIVE AND PREVENTIVE ACTION 8.10.1Preventiveactionsarerequestedandimplementedwhentherearetrendsof decreasing quality capability and/or effectiveness of the quality system that create a riskforapotentialnonconformity.Correctiveactionsareusedwhenanactual nonconformity is identified. 8.10.2Recognizingthisdifference,PipingTechnology&Products,Inc.hasseparate systems for identifying the need for corrective and preventive actions. However, once theneedisidentified,acommonsystemisusedtoprocessbothtypesofactions. Forms,logsandotherdocumentsandrecordsforprocessingofcorrectiveand preventive actions are the same. 8.10.3Theneedforcorrectiveactionisdeterminedonthebasisofidentifiedactual nonconformities. Corrective action requests are typically triggered by such events as a failed inspection, customer complaint and/or product return, nonconforming delivery from a supplier, or a quality system audit finding. 8.10.4The need for preventive action is determined on the basis of information and data regardingcapabilityandperformanceofprocesses,productnonconformityrates, post-production experience feedback, customer complaints, and quality system audit findings. Such information and data are collected and analyzed to detect unfavorable trends that, if not checked, will increase the risk of nonconformities. The system for collectingandanalyzingqualityperformanceinformationanddataisdefinedin Section 8.4 of this manual. PIPING TECHNOLOGY & PRODUCTS, INC. QUALITY MANUAL Section8 Rev.A Rev. Date: 6/19/06 Section Page 9 of9 MEASUREMENT, ANALYSIS AND IMPROVEMENT Uncontrolled Copy Do Not Duplicate 8.10.CORRECTIVE AND PREVENTIVE ACTION (continued)8.10.12 Preventive and corrective actions are initiated, processed and followed up using a Nonconformance Report/Corrective Action Response form. This form documents the unsatisfactory condition and the corrective or preventive action to be taken is used to record the verification and closure of the action. Open CARs are reviewed regularly toensurethattheactionsareimplementedandfollowedupinatimelymanner. ProcedureQAP-85-02CorrectiveandPreventiveActionexplainshowtousethe system.