Is the management representative still required in AS9100 Rev D?

If you are familiar with how a Quality Management System (QMS) works, or any other management system for that matter, you will likely understand the concept of having a management representative for the QMS. This concept of having one member of top management who is the focal person for the management system has been a requirement for a long time, providing one point of access for QMS matters for customers, employees, external auditors, and interested parties when there is a question about the QMS.

However, if you follow the developments of ISO 9001:2015, upon which the requirements of AS9100 Rev D for an aerospace QMS are based, you may have heard that the management representative has been removed from the ISO 9001:2015 standard. This is not the case with the AS9100 Rev D standard. Here is more information about what it includes and some reasons why this was not removed.

What are the AS9100 Rev D requirements for the management representative?

The requirements for management representative have been added to clause 5.3 (organizational roles, responsibilities, and authorities), which is part of the leadership requirements in the standard and discusses the need for top management to assign responsibilities and authorities throughout the organization. There are five specific responsibilities that the standard requires top management to assign:

  • ensure QMS conformity
  • ensure process delivers outputs
  • report QMS performance and opportunities for improvement
  • promote customer focus in the organization
  • ensure QMS integrity when changes are made

These requirements are in common with ISO 9001:2015.

The additional requirements that have been added for an aerospace QMS involves top management appointing a specific person from the company management team to be the management representative, who is responsible to provide oversight to the above responsibilities. This person must also have the freedom and access to top management when there needs to be resolution of quality management issues. An additional note suggests that the management representative can also include responsibility to act as a liaison with external parties on QMS matters. So, the management representative has the overall responsibility and authority for the QMS throughout the company, just as in previous QMS standards.

Why was this not removed as with other QMS standards?

You may ask why this requirement for one person to have overall responsibility for the QMS has been removed from other standard, but not AS9100 Rev D – and this is a good question. While I cannot claim to have knowledge of what the technical committee was thinking, it seems that the decision came from the fact that for many companies, it does not matter whether the five listed responsibilities are done by one person, as long as they are assigned to a responsible person in the company. In smaller companies where people have many different responsibilities, it might be better to distribute these responsibilities, and in a larger company with many locations these responsibilities may be covered by different people at different sites.

However, one of the reasons that this has been added back for the aerospace QMS is likely due to legal requirements that exist for the aerospace sector. Many aviation authorities have the legal requirement that the person in the company or location who is responsible for quality has a direct reporting link to the top management of that company in order to avoid conflicts of interest in quality matters. For instance, the aviation authorities do not want the quality manager to report to the production manager, as this could cause problems if a decision on the acceptability of products or services comes up – this report needs to go directly to the top executive in order to mediate in such issues. The AS9100 Rev D standard includes the same freedom and access requirements, and this practice is also a good idea for other industries as well.

The management representative: A good idea for the QMS

It is important to remember that the requirements for a management representative have never been that this was the sole job for this person, and it was often filled by a manager who had other responsibilities, such as the quality manager. As such, these additional responsibilities were not an excessive burden and many companies that are not in the aerospace industry are still keeping this designation.

It can very often be helpful to have one person who is the focal contact for the QMS when customers or other interested parties have questions, and the management representative fulfills this role quite well. So, along with providing a good model for avoiding conflicts of interest when it comes to quality, the management representative position can help avoid duplication of efforts when it comes to QMS maintenance, saving you time, money, and other resources in the process.

Use this free downloadable AS9100 Rev D Implementation Diagram to manage implementation of AS9100 Rev D.

Advisera Mark Hammar
Mark Hammar
Mark Hammar is a Certified Manager of Quality / Organizational Excellence through the American Society for Quality and has been a Quality Professional since 1994. Mark has experience in auditing, improving processes, and writing procedures for Quality, Environmental, and Occupational Health & Safety Management Systems, and is certified as a Lead Auditor for ISO 9001, AS9100, and ISO 14001.