Braddock Quality Assurance Manual

Transcription

1 Document Pages 1 of 30 Braddock Quality Assurance Manual Approved By:* George Gieger, President Roy Adkins, Corporate Director of Quality *(Actual Signature Page on file.)

2 Document Pages 2 of 30 Braddock Metallurgical has strategically developed and implemented a quality management system using; the organizational environment, changes in the environment, and the risks associated with that environment. Braddock s varying needs, particular objectives, the service we provide, the processes employed, and lastly the size and organizational structure, to demonstrate our ability to provide consistent activities that meet customer, statutory and applicable regulatory requirements applicable to the services we provide. Braddock addresses customer satisfaction through the effective application of the system, including continual improvement and the prevention of nonconformities. The quality system complies with the international standards ISO 9001:2008, and AS9100, other Customer Requirements, and Mil-I 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 operation of the system, and to provide general procedures for all activities comprising the quality system. Another purpose of this manual is to present the quality system to our customers and other external interested parties, and to inform them what specific controls are implemented at Braddock Metallurgical to assure quality. Braddock Metallurgical Locations included in the Scope of this Manual: Duval Place West Jacksonville, FL Chimney Rock Road Bridgewater, NJ S. 78 th Street Riverview, FL Industrial Way Boynton Beach, FL Fentress Boulevard Daytona Beach, FL (Includes Corporate Office) 1590 Huber Street NW Atlanta, GA Sam Wilson Rd. Charlotte, NC 28214

3 Document Pages 3 of GENERAL POLICY Braddock Metallurgical uses the process approach methodology when developing, implementing and improving the effectiveness of our quality management system to enhance customer satisfaction by meeting our customer requirements 1.1 Braddock has determined, managed and linked numerous activities known as a Braddock process. The Braddock definition of a process is an activity or a set of activities using resources and managed in order to enable the transformation of inputs into output and often the output from one process directly forms the input to the next. 2.0 Continuous Improvement is based on the methodology known as Plan-Do-Act-Check-Act and can be applied to all processes. A model of the Braddock Metallurgical Process-Based Quality Management System is shown below: Plan: Do: To establish the objectives and processes necessary to deliver results in accordance with customer requirements and Braddock policies. Implement the process. Check: Monitor and measure the processes and product against policies, objectives and requirements for the product and report the results. Act: Take the appropriate action(s) to continually improve process performance. Continual Improvement of the Quality Management System Management Responsibility Customers Requirements Input Resource Management Measurement analysis and improvement Product Realization Product Output Customers Satisfaction

4 Pages 4 of :2008/AS9100C The quality management system at is relevant to the nature of our organization, product / services and to customer and regulatory requirements. Those requirements of AS 9100C and/or ISO 9001 (2008) that do not apply are excluded from the scope of our quality management system. The Director of Quality Assurance is responsible for identifying and reporting to Top Management those sections of the AS9100 and ISO 9001 standards that do not apply to our organization or our products and services, and to propose exclusions to such requirements from the scope of the quality management system. Top management and the Management Representative have the responsibility and authority for evaluating whether the proposed exclusions are appropriate, and for approving them. EXCLUSIONS 3.0 Exclusions: AS 9100C/ISO 9001 (2008) Section 7.3, Design and/or Development, including all subsections. Section , Post Delivery Support, subsection a, c, d, e). 3.1 Justification of AS 9100C/ISO 9001 (2008) Section 7.3, Design and/or Development, including all subsections and , Post Delivery Support, subsection a, c, d, e): Braddock Metallurgical does not design or develop product. All principal product characteristics are specified by our customers or their consultants. Our engineering activities are limited to developing methods, means of processing and streamlining production. In addition, Braddock Metallurgical does not offer servicing or post-delivery support on any product other than warranty of our service(s). Our activities are limited to processing metals to customer requirements, specifications. Providing re-processing or rework when problems are detected after delivery. Note: The FAA Manual used by the Boynton Beach facility is not subject to the controls and requirements of this Quality Manual, the AS9100 certified QMS, or supporting procedures. The FAA Manual applies to the Boynton Beach Repair Station, Certificate # S2UR808J only. Although the Repair Station activities may generally follow the Braddock Metallurgical QMS, should contradictions occur; the FAA Manual will take precedence for Repair Station activities. All other activities at the Boynton Beach FL facility, excluding the FAA Repair Station, are covered by this Quality Manual, the AS9100 certified QMS, and supporting procedures.

5 Document Pages 5 of General Requirements PROCEDURAL POLICIES Braddock Metallurgical is committed to establish, implement, and maintain a documented Quality Management System and continually improve its effectiveness, in conformance with requirements of the AS9100 and ISO 9001 Quality Standards, Statutory and Regulatory requirements, and the requirements of our Customers. Quality System Processes Processes needed for the quality management system have been determined, and are defined in this quality manual, and associated operational procedures and work instructions. This documentation shows the clear sequence and interaction of processes, and how to effectively implement and apply these processes throughout the organization. Quality system documentation also determines criteria and methods needed to ensure that the operation and control of quality system processes are effective. This includes assignment of responsibilities and allocation of resources needed, and definition of monitoring and measuring methods, analyzing data for effectiveness of the QMS processes. Resources and information The Quality Assurance Representative for each plant is responsible for determining resource and information requirements necessary to support the operation and monitoring of quality system processes, and for communicating these requirements to the top management. The top executive management is responsible for ensuring the availability of necessary resources and information. Section 6.1 of this quality manual, Provision of Resources, explains in more detail how resource requirements are identified and satisfied. Monitoring and measurement The performance of quality system processes is systematically monitored and/or measured. This is to ensure their effectiveness and identify opportunities for improvement. The performance of product realization processes is monitored by measuring process parameters and/or product characteristics resulting from the process; and through the program of inspections and tests applied to the product. The performance of processes required for the quality management system is monitored through internal quality audits, by review of data presented during Management Review meetings, and by measuring customer satisfaction. Monitoring and measuring activities are defined in Sections 8.1 and 8.2 of this quality manual, and in the corresponding operational procedures. Outsourced processes When processes that affect product conformity are outsourced, Braddock ensures that special controls are implemented to ensure that these processes meet specified requirements. Such controls shall include:

6 Pages 6 of 30 Risk assessment evaluation and pre-qualification of suppliers; assessment of supplier realization processes and quality system; monitoring of supplier quality performance; requirements for inspection, testing or other records demonstrating product conformity; or containment and verification of the supplied product. Section 7.4 of this quality manual and the corresponding operational procedures define the purchasing control system. Processes needed for quality management system referred to above, may include processes for management activities, provision of resource, product realization, measurement, analysis and improvement. An outsourced process is a process that the organization needs for its quality management system and which the organization chooses to have performed by an external party General The scope of the quality system documentation is defined. Establishment and revision of documents, records and their distribution are controlled. New documents, records and revisions are reviewed and approved prior to issue; and are identified with respect to their revision level. Appropriate documents and records are available at locations where they are used. Obsolete documents and records are removed from points of use. Documents of external origin determined by Braddock Metallurgical to be necessary for the planning and operation of the Quality Management System (QMS) are identified and their distribution is controlled. Quality records are identified and indexed to facilitate their retrieval, and are stored in a suitable environment to minimize deterioration. Quality records are retained for a period of time at least equivalent to the lifetime of the product. Scope Braddock Metallurgical quality system documentation comprises the following types of documents and records determined by Braddock to be necessary to ensure the effective planning, operation, and control of the processes: Quality manual (including a documented quality policy); Documented statements of quality objectives Quality system requirements imposed by the customer and/or regulatory authority Operational procedures required by the AS9100 standard; Travelers; Furnace Log Sheets; Furnace Records and other documented records; Work instructions; Standards and other technical reference materials; Engineering documents, including drawings, specifications, procedures, and other documents defining products;

7 Pages 7 of 30 NOTE: No O.E.M. Specifications shall be shared with any non Braddock Metallurgical Employee unless they have written authorization to view and research the specifications, due to Proprietary Agreements between Braddock Metallurgical and the various O.E.Ms. Customer engineering documents; Product realization and control plans; The Purpose, scope, and responsibility for controlling various types of documents are defined in Operational Procedure SOP-42-02, Control of Documents. A single document may address the requirements for one or more procedures. A requirement for a documented procedure maybe covered by more than one document Quality Manual The top level document defining the overall quality management system is the Quality Manual. It includes: The scope of the quality system, including details of and justification for any exclusions Description of quality system processes, their sequence and; References to documented procedures; Note: The FAA Manual used by the Boynton Beach facility is not subject to the controls and requirements of this Quality Manual, the AS9100 QMS, or supporting procedures. The FAA Manual applies to the Boynton Beach Repair Station, Certificate # S2UR808J only. Although the Repair Station activities may generally follow the Braddock Metallurgical Inc. QMS, should contradictions occur; the FAA Manual will always take precedence Document control Braddock Metallurgical is gradually transitioning from paper to electronic documentation. As this transition progresses, new categories of documents are transferred from paper to electronic document control system. Both systems are currently used, and are defined in Procedure SOP-42-02, Control of Documents. Documents of external origin determined by Braddock Metallurgical to be necessary for the planning and operation of the quality management system are identified and their distribution controlled and records are controlled in accordance with clause New documents and document changes may be initiated by anyone in the organization, but may only be issued by an authorized function. The authorized functions and the rules governing the issue of documents are defined in procedure SOP-42-02, Control of Documents. Documents may be distributed to personnel and locations where they are used. Electronic documents, which include the entire quality management system, are available to all employees and

8 Document Pages 8 of 30 Customers and/or regulatory authorities in the Q Drive and are accessible any terminal linked with the Braddock network. Document placement is regulated by Procedure SOP Obsolete documents are removed from points of use. Retained masters or copies of obsolete documents are properly marked and are kept separate from active documents. Obsolete electronic documents if retained, are stored in directories or areas that are only accessible to authorized personnel. Document changes are reviewed and authorized by the same function that issued the original document, or the current relevant authority. All electronic Master documents are be controlled by password access only. Read only electronic documents are open to anyone linked to the Braddock network. The server used for Visual Shop (all electronic processes which create Travelers) is backed up daily to prevent loss of data due to any failure. Due to varying activities performed at each individual Braddock Metallurgical Inc. plant, site specific procedures or work instructions may be created and established that apply to that particular plant only. These documents are created and approved in accordance with procedure SOP-42-02, Control of Documents Control of quality records Quality records shall be established, maintained and controlled to provide evidence of conformity to the requirements and of the effective operation of the quality management system: Records are established by personnel performing the task, operation, or activity the results of which need to be recorded. Records are dated; and identify the product, person, or event to which they pertain. Records are normally stored by the same department that initially established the record. Records are stored in dry and clean areas, and electronic records are regularly backed up. Quality records and documents may not be stored in private desk drawers, unauthorized computer drives, or other obscure locations that are not generally known. Retention periods for quality records are determined on the basis the lifetime of the product or the event to which the record pertains, and on regulatory and contractual requirements. Categories of quality records maintained by Braddock Metallurgical are listed in Operational Procedure SOP-42-03, Control of Quality Records. The list identifies specific types of records for each category; their storage location; and retention period. 5.1 Top Management For the purpose of administrating the quality management system, top management is defined to include the President and managers responsible for operations, engineering, marketing, sales, human resources, and quality assurance.

9 Document Pages 9 of 30 Customer requirements Top management is committed to communicate the importance of meeting customer as well as regulatory and legal requirements. Management representative is responsible for implementing this commitment by promoting awareness of customer requirements throughout the organization. This responsibility of management representative is stipulated in Section 5.5, Organization and Communication. Quality policy and quality objectives Top management defines the purpose and objectives for the quality management system. They are documented and communicated in the form of quality policy and quality objectives. Processes for establishing the quality policy and quality objectives are defined in this manual in Section 5.3, Quality Policy, and Section 5.4, Quality System Planning. Management Reviews Top management periodically reviews the quality management system to ensure its continuing suitability, adequacy, and effectiveness. The review evaluates current status and performance of the quality system and initiates actions for further improvement of the system. The process for conducting management reviews is defined in Section 5.6 of this manual and in Operational Procedure SOP-56-01, Management Review. Resources Top management is committed to providing resources necessary for establishing, implementing, and improving the quality management system. Section 6.1 of this manual defines processes for identifying resource requirements and allocation of resources for specific activities and projects. 5.2 Customer Focus Determining customer requirements Customer requirements are understood broadly to include all aspects of products and associated services that can influence customer satisfaction. When relevant, this may also include customer needs and expectations, measuring product conformity, and On Time Delivery (OTD) through trending and internal audits. When planned results are not met, the use of corrective action, preventive action, and customer depositions are used. Customer requirements are determined and verified through the process of order review. This process is defined in operational procedure SOP Customer Purchase Order/Contract Review. Customer needs and expectations Marketing is responsible for collecting and analyzing information on customer needs and expectations. Information about customer needs and expectations is also extracted from customer

10 Document Pages 10 of 30 Feedback, complaints, and customer satisfaction data. Operational Procedures SOP-72-03, Customer Feedback and Complaints, and SOP-82-01, Customer Satisfaction, define how this data is collected and used. Fulfillment of customer requirements The whole quality system is designed and implemented to ensure that customer requirements can be consistently fulfilled. 5.3 Quality Policy QUALITY POLICY/MISSION STATEMENT We are dedicated to providing our customers with an exceptional level of heat treating quality and customer service utilizing value added continuous improvement. We accomplish this by having the proper FOCUS on our customers and PRIDE among our employees. Facilitating partnerships with customers and employees Optimizing technology Continually improving Understanding customer s needs Sustaining organizational excellence And Personal Responsibility In Developing Excellence George Gieger, President The Quality Policy is established by the top management and is approved by the President and the board of directors and ensures the quality policy is appropriate to the purpose of Braddock Metallurgical. Any changes to the policy must be likewise approved by the President and the board.

11 Pages 11 of 30 The quality policy is posted throughout the company, and its role is explained to all employees. The quality policy is also communicated to customers, consumers and other interested parties. For this purpose, it is displayed in the reception area and posted on the company s internet site. The quality policy is periodically reviewed within the framework of management reviews of the quality system, to ensure its continual relevance and suitability Quality Objectives Quality objectives are established throughout the organization to implement the quality policy, to meet requirements for products and processes, and to improve quality system and quality performance Quality objectives define the direction and priorities for continual improvement. Use of quality objectives for facilitating continual improvement is explained in Operational Procedure SOP-85-01, Continual Improvement Quality objectives are classified into the following categories: Policy objectives: These are principal, strategic objectives that apply to the whole organization. They are communicated in memoranda from the top management. The President authorizes policy objectives. Quality performance objectives: These objectives set specific, measurable targets for improving operational performance to ensure product and process conformity and customer satisfaction. They apply to departments and functions having direct responsibility for activities that require improvement. Performance objectives are established, documented, and monitored within the framework of management reviews of the QMS. Product quality objectives: These objectives pertain to improvement of products and associated services. The President and top executive managers responsible for marketing and product development establish product objectives. They can be documented in product briefs, memoranda, or minutes of meetings; and apply to functions responsible for associated services, such as order handling, packaging and delivery Quality Management System Planning Quality system elements and processes are planned to ensure that the system is appropriate for its intended purpose, and that it is effective and efficient: To achieve the quality policy and objectives; To ensure and demonstrate our ability to provide consistently product that meets customer and regulatory requirements; To ensure high level of customer satisfaction; To facilitate continual improvement;

12 Pages 12 of 30 To comply with requirements of ISO 9001:2008/AS 9100C standards; and Maintain the QMS integrity when changes occur The output of quality system planning is documented in this quality manual, in associated operational procedures, and in other referenced documents. These documents identify and define all elements and processes of the quality system Planning of product realization, verification, and validation processes is addressed in Section 7.1 of this manual Improvements of the quality system are planned within the framework of management reviews. The output of this planning is expressed in the form of quality system objectives, as defined above in of this section, and in Operational Procedures SOP-85-01, Continual Improvement; and SOP-56-01, Management Review Responsibility and Authority Departments, groups and functions within the company, and their interrelations, are defined in the organizational chart enclosed at the end of this section. Procedures and Job descriptions further define roles and responsibilities All departments and functions in the company are responsible for implementing, maintaining, and improving the quality system, and providing training where needed. Following specific responsibilities and authorities are assigned: Top Management Formulates the quality policy and objectives Provides resources necessary to maintain and improve the quality system Conducts management reviews of the quality system Production Control Schedules production Established production work orders Production Plans production facilities, equipment, and processes Develops production processes Develops process operator and set-up instructions Controls and monitors processes Conducts in-process inspections Applies and maintains in-process product identification

13 Pages 13 of 30 Maintains production equipment Carries out contract and order reviews Process Owners By Process Specifications Internal Process Specifications Individual Work Instructions Individual Training Receiving Receives purchased products Performs first-stage receiving inspection Applies or verifies product identification for purchased products Operates the material stockroom Shipping Packages products (secondary packaging) Ships products to customers Operates the finished product stockroom Marketing and Sales Conducts market research to anticipate customer expectations Determines customer satisfaction Establishes specifications for new products (product briefs) Advertises and promotes company's products Monitors the quality performance of competitors Plant Human Resources and Plant General Managers Defines personnel qualification requirements Implements measures to motivate personnel Quality Assurance and Quality Control Establishes and maintains the quality management system Audits implementation and effectiveness of the quality system Identifies opportunities for improvement of the quality system Develops quality plans and control plans

14 Pages 14 of 30 Initiates corrective and preventive actions Maintains and may calibrate measuring and test equipment Carries out subcontractor quality surveys and audits Performs inspections and testing Selects qualified supplies and subcontractors Prepares and approves purchasing documents Monitors and evaluates supplier performance Identifies the need for the use of statistical techniques Handles nonconforming products Coordinates document control activities Carries out contract and order reviews Maintains, or coordinates the maintenance of quality records Coordinates collection of quality performance data Provides, delegates, and ensures required training for its personnel Management Representative Braddock Metallurgical has appointed the Corporate Director of Quality as the Senior Quality Management Representative and has the authority and responsibility to: Ensure that the quality management system is implemented, maintained and continually improved; Promote awareness of customer requirements throughout the organization; Report to the top management on the performance of the quality system, including needs for improvement; Has the organizational freedom to resolve all matters pertaining to Quality; and Coordinate communication with external parties on matters relating to the quality system, AS 9100 and ISO 9001 registration. Has the organizational freedom and unrestricted access to top management to resolve quality management issues and can liaison with external parties on matters relating to the quality management system. Note: Each site Quality Manager has been designated as Deputy Management Representative for their site by the Corporate Director of Quality.

15 Pages 15 of Internal Communication Internal communication regarding the quality system flows two ways: Management has ensured that appropriate communication processes are established within the organization and that communication takes place regarding the effectiveness of the QMS. Each site Quality Manager has the overall responsibility for ensuring that all pertinent documents, reports and records are distributed to appropriate departments and functions, and that information and data about quality performance and the effectiveness of the quality system are reported to the top management. Flow of Internal Organizational Reporting

16 Pages 16 of Top management conducts periodical reviews of the quality system. Goals and Quality Objectives are determined and set forth by top management during Management Review Meetings. The purpose of management reviews is to: Evaluate the suitability, adequacy and effectiveness of the quality system at planned intervals; Consider changes to the quality management system and to the quality policy and quality objectives; and Identify opportunities for improvement of the quality system, processes and products. Management reviews are chaired by the President and are attended by the Management Representative, and other managers representing Quality Assurance, Plant, Marketing, Production, Purchasing, and Human Resources, at the request of the President. Management reviews of the entire QMS are conducted at least annually. More frequent reviews may be scheduled in periods when organizational or product changes, or other circumstances require increased attention and input from the top management Review Input. Input into the management reviews consists of information and data related to quality performance of the organization, per Operational Procedure SOP-56-01: Management Review Review Output. Management reviews are concluded with actions related to improvement of the quality management system, and improvement of processes and products to better meet customer requirements. The review also identifies resource needs to implement these actions. The results of Management Reviews are documented in minutes of the review meeting. 6.1 Provision of Resources. Top Management is committed to provide adequate resources for the implementation and improvement of the quality system, and for addressing customer satisfaction and the following: The Quality Assurance Representative, Plant Manager, and/or other management personnel involved in the quality system are responsible for determining resource requirements for the implementation and improvement of the system. Top Management has the responsibility and authority for provision of resources. Allocation of resources for particular activities is integrated with the process of defining and initiating the activity. It may take the form of personnel assignments, allocation of space or equipment, training, procurement decisions, budgets, etc.

17 Document Pages 17 of Human Resources General. All Braddock personnel competency is based on their education, training, skills, and experience Competence, training and awareness. Braddock Metallurgical identifies personnel training needs, provides required training, and evaluates the effectiveness of the training provided to achieve competence. Personnel assigned to perform specific tasks, operations, and processes are qualified on the basis of appropriate education, experience, or training. Employees are made aware of the relevance and importance of their activities and how they contribute to the achievement of quality objectives. Records of personnel qualifications and training are maintained. The Plant General Managers, Production Manager and/or QAR are responsible for identifying training needs and awareness programs for company-wide participation, such as: general orientation, rules and regulations, quality system, safety, and other company-wide systems and issues. Personnel performing work effecting conformity to product requirements must be competent on the basis of appropriate education, training, skills and experience. Departmental managers are responsible for identifying competency requirements and training needs in their departments, and for establishing departmental training programs. Departmental training is focused on increasing the level of skills in operating equipment and processes, conducting inspections and testing, and the use of analytical and statistical techniques. Operational Procedure SOP-62-01, Training and Awareness, describes in detail the training and awareness programs provided by Braddock Metallurgical. Follow-up performance evaluations of trained employees through the use of written examinations, quizzes, and on-the-job training / certification, are used to determine the effectiveness of training. Training records are established for all types of training. Records are normally established and maintained by the department that provides the training. Human Resources and /or Quality Assurance maintain as-hired qualification records, and may also have copies of some departmental training. 6.3 Infrastructure. Suitable infrastructure, facilities and work environment are provided as required to achieve product conformity. This includes planning, provision, and maintenance of employee facilities, workspaces, equipment, software, and supporting services and the following procedures; Infrastructure and Facilities Planning of new, and/or modification of existing infrastructure and facilities is 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

18 Pages 18 of 30 productivity and/or quality. Examples such as, but limited too: lighting, housekeeping practices, employee safety and health, employee facilities or to improve the work environment. Plant Managers are responsible for identifying the need and requirements for new, and/or modification of existing infrastructure and facilities in their plants. Requests for significant changes and/or expansions of facilities are submitted to the top management for review and approval. Supporting services and maintenance of facilities Maintenance of buildings and facilities is performed by the maintenance personnel unless otherwise dictated by the Plant Manager or top management. 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. The Plant Manager in conjunction with maintenance personnel is responsible for coordinating and managing maintenance contracts. Production equipment maintenance is addressed in Section 7.5 of this manual and Operational Procedure SOP-75-03, Equipment Maintenance. 6.4 Work Environment. Executive Management and Plant General Managers are responsible for ensuring suitable working environment for personnel. This is to include human, physical, environmental and other factors such as noise, temperature, humidity, lighting, or weather. 7.0 Product Realization 7.1 Planning of product Realization Planning of product realization processes includes determination of quality objectives for products; development of required processes and process documentation; and establishment of product verification, validation, monitoring, measurement, inspection and test activities specific to the product and the criteria for product acceptance. The plan also defines requirements for records necessary to demonstrate process and product conformity. The quality objectives and requirements for the product may include: Consideration of aspects such as product and personal safety, reliability, availability and maintainability, producibility and inspect ability. Suitability of parts and materials used in the product selection and development of embedded software, and recycling or final disposal of the product at the end of its life. The need to establish processes and documents, and to provide resources to support the use and maintenance of the product. Required verification, validation, monitoring, measurement, inspection and test activities specific to the product and the criteria for product acceptance;

19 Pages 19 of 30 Records needed to provide evidence that the realization processes and resulting product meet requirements (see 4.2.4); Configuration management appropriate to the product; The output of quality planning includes documented quality plans, processes, and procedures Project Management/Product Quality Requirements As appropriate to the facility, plans and manages product realization in a manner which meets the requirements at acceptable risk, within resource and schedule constraints. BMI uses Visual Shop (production software) to manage customer PO inputs. Production reviews parts on the traveler to prioritize the work schedule. Quality requirements for heat-treat processing is defined in drawings, specifications contract documents, internal and external standards, product samples and workmanship standards, and applicable legal and regulatory requirements. Quality Assurance is responsible for identifying product quality objectives and requirements. This may be integrated with the process of determining customer and product requirements (Refer to Operational Procedure SOP-72-02, Customer Purchase Order /Contract Review) Risk Management Braddock Metallurgical has established, implemented and maintained a process for managing risk to the achievement of applicable requirements, that includes as appropriate to the organization and the product through the use of; Contract review to identify new standard requirements, Contract review to identify PO requirements, Assignment of responsibilities for risk management, Definition of risk criteria (e.g., likelihood, consequences, risk acceptance), Identification, assessment and communication of risks throughout product realization, Identification, implementation and management of actions to mitigate risks that exceed the defined risk acceptance criteria, and Acceptance of any risks remaining after implementation of mitigating actions Product realization planning includes, as applicable: Definition and evaluation of manufacturing operations and processes, Development of adequate and capable processes, Identification of special processes and consideration of associated risks and consequences, Establishment and implementation of appropriate process control measures,

20 Pages 20 of 30 Identification of resources to support the process and maintenance of the product, Development of instructions and training for process operators, and Requirements for necessary records which demonstrate process conformity. The identification of resources to support the operation and maintenance of the product Product realization plans are established in collaboration between Production and Quality Assurance. The plans are defined in various types of production documents, such as process flowcharts, shop orders/job cards, control plans, operator instructions, process validation reports, etc Operational procedures related to Section 7.5, Operations, explain how outputs of product realization planning are used Configuration Management Configuration management is defined by our customers through the use of part numbers and part configuration. Braddock does not manufacture or change part numbers. Any special purchases such as material needed for the process is covered in SOP 7.4 (Purchasing). All product identification is identified on the traveler. All parts numbers used on blanket orders or are used repetitiously will be stored in Visual Shop for future use Control of Work Transfers When or if work is transferred, Braddock will address, implement and maintained a process to plan and control the temporary or permanent transfer of work (e.g., from one organization facility to another, from the organization to a supplier, from one supplier to another supplier) and to verify the conformity of the work to requirements. Braddock will also ensure the transfer of work will be in accordance with SOP (Evaluating Suppliers) when transferring any work. 7.2 Customer Related Processes Product requirements are determined to include customer requirements and legal, regulatory, delivery and post delivery requirements and other necessary requirements that may not be specified by customers. Orders are reviewed to ensure that product and order requirements are defined and can be met, and to resolve any incomplete or conflicting requirements. Verbal orders are confirmed in writing before acceptance. Order amendments and changes are likewise reviewed and are communicated to all relevant functions.order reviews are recorded. Arrangements for communication with customers applicable to product information, order handling, and customer feedback and complaints are defined and implemented. Where appropriate, operational procedures and instructions for these activities are established and implemented. Including any additional requirements or special aspects of the product which have been determined and met, risks (e.g., new technology, short delivery time frame) will also be identified and given necessary consideration by the organization.

21 Document Pages 21 of Determination of Requirements Related to the Product For custom processing, processing requirements are determined and reviewed by the Plant Manager and the Corporate Director of Quality or his designee. This often involves input from the Heat Treat Supervisor, and Quality Assurance, depending on the nature and complexity of the processing, and whether a similar order has been recently processed. Custom process requirements are determined and reviewed with regard to requirements specified by the customer; including delivery and post-delivery activities, other relevant process requirements not specified by the customer, (e.g. any statutory, regulatory, or other a d it ion a l requirement s, which are c o n s i d e r e d Necessary by BMI Review of Requirements Related to the Product Braddock conducts reviews of product requirements prior to accepting a commitment to supply product services to ensure requirements are defined and understood and t h a t the company has the capacity and capability to meet all applicable requirements and risks associated with the purchase order. This includes reviewing and ensuring any requirements differing from those previously expressed are resolved, any special requirements are determined, and that risks such as short delivery or new technology requirements have been identified. Operational Procedure SOP-72-02, Customer Purchase Order /Contract Review, instructs on how to carry out this review. Any incomplete or conflicting requirements are resolved with the customer in writing before acceptance of the order. Verbal orders are not accepted. Orders from customers are accepted only by receiving/sending a written request (purchase order), faxed purchase order or e-mai1ed purchase order. Change orders are received and reviewed by the same functions that are responsible for the review of the initial orders. Change orders are communicated to all functions within the organization that may be affected by the change of customer requirements. Operational Procedure SOP-72-02, Customer Purchase Order/Contract Review, provide instructions on how to process change orders. Reviews of processing requirements are recorded on the Traveler in the Contract Review block. For custom processing, the contract review is on the Traveler as explained in Operational Procedures SOP-72-02, Customer Purchase Order/Contract Review, and SOP-42-03, Control of Quality Records.

22 Pages 22 of Customer Communication All employees of Braddock Metallurgical may receive customer feedback and complaints. The Office Manager or designated department is responsible for processing customer feedback and complaints. All received customer communication is recorded in the customer feedback and complaints log. Customer feedback and complaints are classified into categories to allow for better tracking of trends and evaluating improvement in specific aspects. Every complaint is communicated to relevant functions within and outside the organization. Procedure SOP-72-03, Customer Feedback and Complaints, provides detailed instructions how to receive, process, and respond to customer feedback and complaints. 7.3 Design and Development Excluded: Design is not performed at Braddock Metallurgical, Inc. 7.4 Purchasing Purchasing Process A documented procedure SOP is followed to ensure that purchased product conforms to the specified purchase requirements. The procedure outlines the extent of control required for suppliers. A list of approved suppliers is maintained electronically by corporate quality and contains their scope of approval. Suppliers are evaluated for risk and selected based on their ability to supply product in accordance with requirements as outlined in procedure SOP Criteria for selection, evaluation and re-evaluation are documented in the procedure. Third party ISO accreditations may be accepted in lieu of standard evaluations. ISO accredited suppliers are preferred and considered to be low risk suppliers. Records of the evaluation and any necessary actions are maintained as quality records. Each plant on Braddock Metallurgical is responsible for the quality of all products purchased from suppliers, including any customer-designated sources Purchasing information Purchasing information describes the product to be purchased, including where appropriate, requirements for approval of product, processes and equipment and qualification of personnel. Specific requirements for purchasing information and PO generation, including right-of-entry, notification of Nonconforming Material, flow-down to sub-tier suppliers, etc. is outlined in the Purchasing Procedure SOP 74-02, Purchase Order use and Control.. The purchasing documents are reviewed to ensure the adequacy of requirements before orders are placed with the supplier.

23 Pages 23 of Verification of purchased product Purchasing procedure SOP describes the process used to verify that purchased product meets specified purchase requirements. The organization has established and implemented the inspection or other activities necessary for ensuring that purchased product meets specified purchase requirements. Where purchased product is released for production use pending completion of all required verification activities, it shall be identified and recorded to allow recall and replacement if it is subsequently found that the product does not meet requirements. When delegates verification activities to the supplier the requirements for delegation are defined and a register of delegations maintained. When or its customer intends to perform verification at the supplier's premises the intended verification arrangements and method of product release are stated in the purchasing information. 7.5 Production and Service Provision Control of production and service provision Braddock Metallurgical plans and carries out production and service provision under controlled conditions. Planning considers, as applicable, the establishment of process controls and development of control plans where key characteristics have been identified, the identification of in-process verification points when adequate verification of conformance cannot be performed at a later stage of realization, the design, manufacture, and use of tooling so that variable measurements can be taken, particularly for key characteristics, and any Special processes. Controlled conditions include, as applicable, the availability of information that describes the characteristics of the product, work instructions, the use of suitable equipment the availability and use of monitoring and measuring devices, the implementation of monitoring and measurement the release, delivery and post-delivery activities, accountability for all product during production, evidence that all production and inspection/inspection operations have been completed as planned, or as otherwise documented and authorized, provision for the prevention, detection, and removal of foreign objects, monitoring and control of utilities and supplies such as water, compressed air, electricity and chemical products to the extent they affect conformance to product requirements, and criteria for workmanship specified in the clearest practical manner Production Process Verification The Braddock Metallurgical will use a representative item from the first production run of a new part or assembly to verify that the production processes, production documentation and tooling are capable of producing parts and assemblies that meet requirements. This process will be repeated when changes occur that invalidate the original results (e.g., engineering changes, manufacturing process changes, tooling changes).

24 Document Pages 24 of Control of Production Process Changes: Authorized people for approving changes to production processes are identified in SOP Braddock Metallurgical will control and document changes affecting processes, production equipment, tools or software programs. The results of changes to production processes will be assessed to confirm that the desired effect has been achieved without adverse effects to product conformity Control of Production Equipment, Tools and Software programs Production equipment, tools and software programs used to automate and control/monitor product realization processes, are validated prior to release for production and shall be maintained Post-Delivery Support (Exclusion: , subsection e). Post-Delivery support performed by is limited to processing metals to customer requirements and specifications, and providing reprocessing or rework when problems are detected after delivery via warranty of service(s) provided Validation of processes for production and service provision Braddock Metallurgical validates any processes for production and service provision where the resulting output cannot be verified by subsequent monitoring or measurement. This includes any processes where deficiencies become apparent only after the product is in use or the service has been delivered. Validation demonstrates the ability of these processes to achieve planned results Identification and traceability Purchased parts are identified with unique numbers, codes, or names. The identification is the same as, or is cross-referenced with, the designations used in drawings, specifications, bills of materials, parts lists, purchase orders, etc. Purchased parts are identified by marking, labeling, or tagging the parts or their packaging, or by identification of the area where the parts are held. During all stages of processing, parts are identified by the traveler and other documents that accompany them through the processing cycle. Parts and other components may also be identified by labels or tags, or the containers in which they are held. Final parts are identified by their name and identification number, which is labeled or marked on the parts and/or is printed on the primary part packaging Rules and activities related to identification of parts are governed by SOP-75-04, Part Identification and Traceability. Additional relevant procedures are: SOP-75-01, Production Traveler; SOP-74-03, Verification of Purchased Part; SOP-82-05, Final Inspection; and SOP-75-08, Packaging, Labeling and Shipping.