Audit N program for subcontracted work

By Mikeqc1 (****)

Date 08-27-2010 17:06

I’m going to Audit a facility for our nuclear program for subcontracted work, the work being done is out side the Scope of NCA. NCA -3125 SAYS THERE ARE NO REQUIRMENTS FOR SUBCONTRACTING WORK BEYOND THE SCOPE OF THIS SECTION.
Has Any1 ever audited a subcontractor for a N program?
Any help or advice on this would be a big help.
I can’t imagine that an audit is not required.
If you have any input on this please reference the section or sections that may help me.

By G.S.Crisi (****)

Date 08-27-2010 20:32

Could a glance at the ASME Nuclear Vessels Code give you any clue? Just an idea.
Giovanni S. Crisi
Sao Paulo - Brazil

By flamin

Date 08-27-2010 21:24

"nuclear program....." + "THERE ARE NO REQUIRMENTS....." that just doesn't sound right.
Isn't there a QSP (Quality System Provision) that your subcontractors have to be in compliance with before contracts are even awarded to them? We don't do nuke work, but we are AS9100 certified (Aerospace). When we subcontract work, our subcontractors don't necessarily have to be AS9100 accredited, but they do need to prove to us that they are capable up upholding the quality standards that we are held to. When we work with a subcontractor, we give them a list of quality requirements that they need to adhere to. If they choose not to follow the requirements (which happens) they don't get the contract. If they agree, then they WILL be audited by our internal auditor(s) for compliance. How else will you know they are doing the right thing?

By CHGuilford (****)

Date 09-08-2010 13:36 Edited 09-08-2010 13:40

I am not familiar with the nuclear programs, but I read that statement as meaning: The subcontractor wouldn't have any extra requirements but they must fully comply with the NCA 3125 requirements.

Ie: whatever you would need to do, the sub would need to do. (Of course that is assuming the work being done is equavalent. Other scopes of work could have more or less stringent requirements.)

By Mikeqc1 (****)

Date 09-08-2010 18:56

thanks

By js55

Date 09-09-2010 12:54

Audits are not required for everything under NCA. QSC's and A2LA accreditation are examples. However, the NRC takes a different view.
I would recommend you consult with your ANI on this one.
When in doubt utilize your standard audit checklist.