Trinity Operating Procedures - TOPs

TOP-IAUDT: Internal Auditing

Rev: 02/21/2023

Scope: This procedure covers internal auditing of the Trinity Forge quality and environmental systems, as opposed to external auditing which is performed by an independent outside registrar.

Procedure:

Administration of the Internal Audit Program

The QA Manager is responsible for updating the Internal Audit Schedule at least once each year to project the internal audit schedule out at least twelve months, and for administering all internal audits per this schedule. The QA Manager may call for audits in addition to those scheduled. 

The QA Manager is responsible for planning who will be involved in audit assignments for at least six months in the future and for coordinating with the HR Manager to ensure a diverse selection of team members are trained and qualified. Trinity shall have a minimum of 4 Qualified Internal Auditors at any point in time.

• To qualify as an Internal Lead Auditor, an employee must have gone through Trinity's Internal Auditor training and have been employed by Trinity for a minimum of 1 year.

The QA Assistant makes all audit assignments via e-mail, with instructions from the QA Manager. The auditor uses the provided Internal Audit Form (IAF) in Excel format for detailed documentation of the auditing process. The e-mailed IAF provides the basic record of the internal audit program.

• Where a minor deficiency is identified in an audit and is immediately resolved by the audited manager, no further formal resolution is required. 
• Where an audit identifies a deficiency per the standard, the QA Manager addresses the finding by implementing a TOP's change to address the deficiency (changes beyond correcting typos and updating obsolete team position titles require approval of the QA Manager to be considered "minor"). 
• For any deficiencies that the QA Manager determines to be severe in nature, he/she may formally request a corrective action per TOP-CARRR. A record of whatever action is taken is maintained as part of the audit. (Severe deficiencies may include items that can cause non-conforming product or result in an elevated risk of a process)

Preparing for Management Review (see TOP-MREVU), the QA Manager is responsible for ensuring that a full top-down audit is performed and documented as well as preparing an overall report of the results of the internal audit program.

Types Of Audits

Trinity Forge conducts six different types of audits, all under the oversight of the QA Manager:

• "Top-Down Audit" is performed annually to ensure that Trinity Forge quality and business systems meet all requirements of the standards specified in Section I of the Trinity Forge & Machine Quality Manual and in Section I of the Trinity Forge EMS Manual. Top-Down audits using a "Top-Down Audit Checklist" to verify that Trinity Forge internal audits are reviewing appropriate requirements for the standards stated in those Sections. 
• A Top-Down Audit is required to be performed annually for use in Management Review. 


• "Internal Audits" are performed on specific sections of the standard at the QA Manager's discretion to ensure that all Trinity's QMS system is properly addressing all sections of the standard. During these audits, individual TOPs that pertain to the specific section of the standard are to be reviewed for effectiveness, that they are being correctly executed, that risks are being considered and that each is fully covering its subject area. Also included in the review of each TOP is the integrity of all links within the TOP. After internal audits are completed to the QA Manager satisfaction, the audit results are communicated to the manager(s) of the area(s) being audited.
• "Internal Audits" are to be performed on a annual basis.


• "Mini Audits" are short audits performed to verify that selected activities are being performed and documented correctly. Mini audits are designed to ensure Trinity Forge employees are accurately performing routine job functions such as cycle counts, raw material data entry, non-destructive and hardness testing and other job functions that require accurate quality records. This may also include auditing of TOP's that do not tie directly to the standard.
•  Mini Audits are performed at the QA Manager's discretion.


• "Vendor Audits" are performed on suppliers and subcontractors. Details of the timing, scope and methodology of the audit for an individual vendor are specified by the QA Manager. Vendors are to be monitored to ensure that their quality management systems are up to date as necessary for the product or services they provide. Refer to TOP-SAPVL for specific instructions.
• Vendor audits vary in frequency based on customer requirements and functions being performed.


• "Vendor Audits - Nuclear" are conducted with any vendors performing work for Trinity that is required to meet the quality requirements of NCA-3800/4000, 10CFR21 and 10CFR50 Appendix B for the supply of Safety Related/Code Forgings. Audits will be performed to ensure the vendors capability to meet all quality requirements regarding the critical characteristics performed at their facility. 
• Where nuclear requirements need to be met, vendors are visited and audited annually.
• These audits shall be performed by a Qualified NQA-1 Lead Auditor.
  

• "Flight and Nuclear Safety Program Audits" are performed and documented annually to assure Trinity's compliance to NQA-1 2008/2009, NCA-3800 2021 and 10CFR21 requirements and that adequate controls exist TOP-FLSPG. Records of the flight and nuclear safety program are maintained in employee Training Files.
• "Flight and Nuclear Safety Program Audits" are conducted on an annual basis.
• These audits shall be perfomed by a Qualified NQA-1 Lead Auditor.

Any team member whose Training File documents him/her as being qualified may be called on to assist the QA Manager by acting in the role of Internal Auditor for an internal audit assignment. The QA Manager provides the type of audit to be perfomed and scope. The team member acting as Internal Auditor has these responsibilities:

• Verify that he/she has the time to complete the assignment by the due date and that he/she has no conflict of interest in the assignment (no one may audit an activity in which he/she works directly). Must immediately respond back to the QA Manager if there is a problem.
• Perform the audit to the best of his/her abilities exactly as assigned. It is not okay to try to personally solve a problem identified in the audit as doing so would constitute a conflict of interest.
• Provide detailed evidence to support the audit findings. Evidence must be relevant to the section of the standard or a Specific TOP and how it relates to standard.
  
• Reply back to the assignment email with a full, clear response by the due date. If a time extension proves necessary, request it prior to the due date.

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