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Quality manual Quality Assurance Department Sector 03


Columbia Tecnologia em Petróleo e Serviços LTDA. Headquarters Rua 7B, 111, LT 08 QD 14F, Civit II, Serra – ES Mailing Address P.O. Box 29.168-062 Tel: +55 (27) 3328-3827

Branch Serra Rua 7B, 183, LT 09 QD 14F, Civit II, Serra – ES Mailing Address P.O. Box 29.168-072 Tel: +55 (27) 3328-3827

Branch Fundão Av. dos Crisântemos, 2025, São José, Fundão – ES Mailing Address P.O. Box 29.185-000 Tel: +55 (27) 3267-1654

www.columbiatecnologia.com.br


Introduction Columbia Tecnologia em Petroleo e Serviços Ltda. developed and implemented a Total Quality Management in order to document the company’s best business practices, to better satisfy the requirements and expectations of its customers and improve the overall management of the company. The Total Quality Management of Columbia Tecnologia em Petroleo Ltda. meets the requirements of the international standard ISO 9001:2008. This system addresses the design, development, production, installation, and servicing of the company’s products. This manual is divided into ten sections that correlate to the Total Quality Management sections of ISO 9001:2008. Each section begins with a policy statement expressing Columbia Tecnologia’s obligation to implement the basic requirements of the referenced Quality Management System section. Each policy statement is followed by specific information pertaining to the procedures that describe the methods used to implement the necessary requirements. This manual describes the Total Quality Management, delineates authorities, inter relationships and responsibilities of the personnel responsible for performing within the system. The manual also provides procedures or references for all activities comprising the Total Quality Management to ensure compliance to the necessary requirements of the standard. This manual is used internally to guide the company’s employees through the various requirements of the ISO standard that must be met and maintained in order to ensure customer satisfaction, continuous improvement and provide the necessary instructions that create an empowered work force. This manual is used externally to introduce our Total Quality Management System to our customers and other external organizations or individuals. The manual is used to familiarize them with the controls that have been implemented and to assure them that the integrity of the Total Quality Management System is maintained and focused on customer satisfaction and continuous improvement.


SUMMARY I – INTRODUCTION TO QUALITY MANAGEMENT MANUAL II – QUALITY MANUAL CONTROL III – LIST OF AMENDMENTS Section 1: COMPANY PROFILE 1.1 - PRESENTATION 1.2 - HISTORY Section 2: COMPANY ORGANIZATION 2.1- PROCESS FLOW 2.1.1- PROCESS INTERACTION Section 3: PRODUCTS AND SERVICES OFFERED Section 4: QUALITY MANAGEMENT SYSTEM 4.1 - GENERAL REQUIREMENTS 4.2 - DOCUMENTATION REQUIREMENTS 4.2.1 - GENERAL 4.2.2 - QUALITY MANUAL 4.2.3 – CONTROL OF DOCUMENTS 4.2.4 – CONTROL OF QUALITY RECORDS Section 5: MANAGEMENT RESPONSIBILITY 5.1- MANAGEMENT COMMITMENT 5.2 – CUSTOMER FOCUS 5.3- QUALITY POLICY 5.4- PLANNING 5.4.1- QUALITY OBJECTIVES 5.4.2- QUALITY MANAGEMENT SYSTEM PLANNING 5.5- RESPONSIBILITY, AUTHORITY AND COMMUNICATION


5.5.1- RESPONSIBILITY AND AUTHORITY 5.5.2- MANAGEMENT REPRESENTATIVE 5.5.3- INTERNAL COMMUNICATION 5.6- MANAGEMENT REVIEW 5.6.1- GENERAL 5.6.2- REVIEW INPUT 5.6.3- REVIEW OUTPUT Section 6: RESOURSE MANAGEMENT 6.1- PROVISION OF RESOURCES 6.2- HUMAN RESOURCES 6.2.1- GENERAL 6.2.2 - COMPETENCE, AWARENESS AND TRAINING 6.3 – INFRASTRUCTURE 6.4- WORK ENVIRONMENT Section 7: PRODUCT REALIZATION 7.1- PLANNING OF PRODUCT REALIZATION 7.2- COSTUMERS RELATED PROCESS 7.3- DESIGN AND DEVELOPMENT 7.4- PURCHASING 7.4.1- PURCHASING PROCESS 7.5 – PRODUCTION AND SERVICE PROVISION 7.5.1- CONTROL OF PRODUCTION AND SERVICE PROVISION 7.5.2 - VALIDATION OF PROCESSES PRODUCTION AND SUPPLY PROVISION 7.5.3 - IDENTIFICATION AND TRACEABILITY 7.5.4 - CUSTOMER PROPERTY 7.5.5 - PRODUCT PRESERVATION 7.6 – CONTROL OF MONITORING AND MEASURING DEVICES Section 8: MEASUREMENT, ANALYSIS AND IMPROVEMENT 8.1- GENERAL 8.2- MEASUREMENT AND MONITORING 8.2.1 - COSTUMER SATISFACTION


8.2.2 – INTERNAL AUDITS 8.2.3 – MEASUREMENT AND MONITORING PROCESS 8.2.4 – PRODUCT MEASUREMENT AND MONITORING 8.3- CONTROL OF NONCONFORMING PRODUCT 8.4 - ANALYSIS OF DATA 8.5 - IMPROVEMENT 8.5.1 - CONTINUAL IMPROVEMENT 8.5.2 - CORRECTIVE ACTION 8.5.3 - PREVENTIVE ACTION Section 9: ENVIRONMENT Section 10: SAFETY AT WORK


I – INTRODUCTION TO QUALITY MANAGEMENT MANUAL The quality manual outlines the policies, procedures and requirements of the Total Quality Management (TQM). The system is structured to comply with the conditions set forth in the International Standard ISO 9001:2008. We define quality not only as conformance to requirements, but also as a means of consistency and reliability. This handbook specify how our TQM meets Standard ISO and how we focus on reengineering toward competitiveness, safety and continuous improvement.

SCOPE Columbia Technology is a market leader in sand control components used in oil extraction reservoirs as well as all other components needed during the extraction, storage and treatment of oil. Our finest examples of such components is the Laser Cut Slotted Liner, Thermal Insulator Columns (used in steam injection operations and for thermal insulation purposes in offshore NGS injection – Nitrogen Generator System), Early Production Risers (EPR), as well as Elastomeric Clamps for offshore operations.

QUALITY MANUAL DEVELOPMENT The responsibility to design the quality procedures are of the board of directors and quality assurance department, but everyone in the company has the right to give inputs and the responsibility to ensure the correct implementation. We encourage workers to avoid the tendency to consider the processes they do repetitively dominated. Instead, we allow them to be innovative and voice their personal ideas.

Launch May 26th,2003.

REVIEW Review nº 15 on July 10th, 2013.

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APPRAISAL The board of directors are fully committed to ensure all required resources in order to guarantee quality procedures and maintenance of TQM.

Appraisal Name

Signature

Position

Date

André Penna de Oliveira

RD/Quality assistant

10/07/13

Eluandra Castaño

Quality and Environment Coordinator

10/07/13

II – QUALITY MANUAL CONTROL The printing versions of this manual are identified in the cover with sector addressee and code. Authorized copies have an original signature in item I and are distributed as follow:

Code

Sector

Addressee

MQ 001

01

Quality Office (Hangar I)

MQ 002

03

Management (Hangar II)

Uncontrolled copies may be printed without permission, but those do not have both original signature and watermark. Reviews and changes will be identified at items I and IV.

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REVIEWS Changes in this document can be made at any time under the supervision of Quality Assurance Department. Implementation of those changes, on the other hand, only after final approval. Manual keepers are responsible to store it, care for its integrity and application. Quality office is responsible for its update. Once the reference Standard SGQ changes significantly, a new quality manual will be printed from Review 00. A copy from the last version will be taken as a historical data.

III – LIST OF AMENDMENTS At least the three last reviews on the manual will be shown on the table below. The last review has to be detailed.

REVIEW 14

DATE

CHANGING DESCRIPTION

Change of all procedures and instructions covered in 10/07/2012 this manual code. Change the procedure name “Periodic evaluation of suppliers” to “Selection, evaluation and suppliers.”

ITEM All items 7.4.1

- Amendment of the DR/ Quality Assistant - Amendment of the Quality and Environment Coordinator;

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Section 1: Company Profile


1.1 - PRESENTATION Columbia Tecnologia em Petróleo e Serviços Ltda web site: www.columbiatecnologia.com.br Email: columbia@columbiatecnologia.com.br

Headquarters • NPJ (Brazilian Registration of Corporate Taxpayers): 00.691.219/0001-84 Address: 7B street, Lote 8, Bloco 14F, nº 111, Civit II, Serra-ES, P.O: 29.168-062 • Fax: 55 (27) 3328-3827

1.2 - HISTORY Founded in 1995, Columbia Technology is a Brazilian industrial company specialized in the manufacturing of oil and gas extraction components. The company’s manufacturing plants expands over a total area of 80,000 square meters and is well known for being at the forefront of technological advancements in its industry. Equipped with the finest professionals and equipment on

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offer, Columbia is able to produce a total of 10,000 tons a year of component goods – this makes us one of the largest petroleum and gas extraction component manufacturers in the world. Columbia Technology has also provided first rate bespoke units to our clients, which include, oil storage tanks, made to measure metallic structures, silos, skids, umbilical reels, boxes used in offshore loading of such equipment as well as heat exchangers. Our company prides itself on being able to provide whatever manufacturing needs our clients require. With a diverse range of equipment and highly skilled workforce at hand, we are also able to quickly understand our client’s needs and always strive to provide the highest quality products in the industry. Columbia Technology has thrived in Brazil and is a clear market leader in every technology we provide. Our investments in technology and new equipment means that few rival our innovation and capability to delivery world class products (we are also compliant with ISO 9001-2008). It is because of our quality of products and services that we have exclusivity rights with Petrobras (Brazil’s largest oil company) on all of our speciality components. Petrobras has maintained exclusivity rights with Columbia Technology for the products we specialize in since 2001, where we have continually surpassed expectations on what we deliver. During this partnership of 12 years, Petrobras has utilized Columbia’s Laser Cut Slotted Liners in over 300 oil wells and our Thermal Insulation Columns have been used in over 400 operations. Petrobras is well known as a market leader in deep sea oil extraction, where the technical requirements for components used must be of the highest standards. Columbia Technology has provided such unique components since 2001. Into the Social Responsibility Columbia Technology take pride in giving back to our local communities. In the past 18 years we have established and ran home centers for the underprivileged and elderly as well as sponsored numerous environmental schemes.

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Section 2: Company Organization


The organization structure of Columbia chart is presented as:

The organizational structure of Columbia is composed by: • CEO: Overall company representative. It’s who makes major commercial and management actions; • Board Production: Representative of the productive sector. It who defines with the CEO management actions of production; • Financial/Commercial Board: Acts with the CEO in commercial actions. It’s also responsible for financial matters; • Administrative Board: Representative of the administrative sector. It who defines with the CEO the administrative actions and company assets; • Quality Committees, QHSE and CIPA (Commissions for Accident Prevention): Staff responsible for the dissemination and implementation of the activities of Quality, Environmental, Health and Safety; • Administrative Management: Management activities related of Financial / Commercial / Administrative processes areas. • Production Management: Manage areas related to the production process. The production management is divided according to the service to be performed. The definition of authority and responsibility of the components of this structure is documented and defined in the document “Framework for Defining Functions”.

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2.1 - PROCESS FLOW 1

Commercial S e r v i c e s

3

10 Material Acquisition

11

11

4

14

Inspection and Material Receiving

16

20

13 6

19 8

18

25 Production Flow

11

Verification of Customer Satisfaction

22

24 Preventive Action

Information Flow

21

23

Corrective Action

28

26 IQA Conducting

29

Materials and services Flow

29

Internal Processes External Processes

Customer Complaint

Instruments Calibration

Costumer

11

Preventive and Corrective Maintenance

Machining Services, Boilers and Manufacture of Slotted Liner

M a t e r i a l

M a t e r i a l

Toiletries Uniforms Maintenance of Machines

15

5

2 7

Provider

12

Painting Fold Sandblasting Transport

Nonconforming product control

9

Supplier Evaluation

Critical Analysis of Contract

QMS Documents Control

QMS Critical Analysis

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Conducting Training

15


2.1.1 - PROCESS INTERACTION INTERFACE

16

ENTRY

DESCRIPTION

OUTPUT

1

Quotation Request

Quote request sent by the costumer, which may be answered or declined

Critical Analysis of Contract

2

Customer Purchase Order or Contract

Preparation and issuance of the order of service for production.

Service Order and Documentation

3

Material specification for purchase

Issuance of Purchase Order for the materials purchase.

Purchase Order

4

Purchase Order and Invoice

Inspection of materials and products purchased.

Material inspected

5

Material Inspected

Release of materials for production.

Material for production

6

Material sent by the costumer

Transmission of material from the client to perform the services / product manufacturing.

Material for production

7

Production Process

Control of Nonconforming Product through inspection.

Nonconforming product control

8

Production process

Execution of the Service/Manufacture of the product to customer

Product/Service to Customer

9

Supplier data

Supplier Evaluation for acquiring materials.

Supplier Evaluation

10

Material Specification

Information for purchasing materials.

Purchase Order

11

Purchase Order

Procurement of materials and services to the process.

Material acquired

12

Material acquired

Revaluation of suppliers after the materials purchase / services.

Supplier Evaluation

13

Instrument to be calibrated

Calibration of instruments used in performing services.

Calibrated Instrument

14

External Services

Inspection of materials and services purchased externally.

External Material/Service

15

External Services

Acquisition of external services for additional procedures.

External Service

16

Data from incoming inspection

Treatment of Material/Service nonconforming.

Nonconforming product control

17

Equipment to be calibrated

Preventive and corrective maintenance on machines and equipment.

Equipment for production

18

Verification of customer satisfaction

Verification of Customer Satisfaction through research or spontaneously.

Survey of client satisfaction

19

Survey of client satisfaction

Customer complaints observed after customer satisfaction survey.

Customer Complaint

20

Spontaneous customer complaint

Customer Complaint in a spontaneous way.

Customer Complaint

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INTERFACE

ENTRY

DESCRIPTION

OUTPUT

21

Customer Complaint

Implementation of corrective action on non-compliance of customer complaint.

Corrective Action

22

Control of Nonconforming Product

Implementation of corrective action on nonconforming product detected in the process.

Corrective Action

23

Need for corrective action

Treatment of Non-Conformity emerged throughout the process.

Corrective Action

24

Need for corrective action

Implementation of Preventive Action throughout the process.

Preventive action

25

Preparation and Control of Documents

Preparation and Control of Company documents.

Documents

26

Need to check the QMS

Audit verification of conformity of the QMS.

IQA

27

Nonconformities of IQA

Implementation of corrective action for non-conformity in AIQ

Corrective Action

28

Need for training

Training of Employees.

Register for training

29

Every Case

Regular critical analysis of the Quality Management System.

Critical Analysis of the QMS

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Section 3: PRODUCTS AND SERVICES OFFERED


Working in the areas of mechanical and petroleum sectors, Columbia provides the following products and services:

Slotted liner Columbia Technology has always been at the forefront of this product’s technological developments. At Columbia, we utilize high precision laser beams in order to make the necessary incisions into our laser cut Slotted Liners. This allows the tube to be highly effective in filtering debris with far less impact on the tube’s structural characteristics than conventional methods. This makes all the difference and allows our laser cut Slotted Liners to be utilised in greater depths and more hostile environments.

A Slotted Liner being cut with a high precision laser at our manufacturing plant.

A laser cut Slotted Liner in action, filtering debris as the formation fluids flow throught the slots.

Thermal Insulator Columns Our Thermal Insulator Columns were developed in order to tackle the various challenges faced when producing oil offshore – maintaining a constant oil temperature throughout the production column above the paraffin crystallization temperature or of carbohydrates formation. Since seawater temperature decreases with depth, this provides oil extraction operations with an even greater challenge. What makes this challenge even greater is that any thermal insulators utilized need to be especially thin, durable and lightweight. Such thermal insulators need to be ultra-thin to reduce drag and vortex driven vibrations caused by sea currents on the production column. Any thermal aids used also need be lightweight to avoid compromising maneuvers needed during the installation phase.

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Examples of our Thermal Insulator Columns, from our manufacturing plants in Brazil.

As well as being an important component to utilize in offshore production columns, our Thermal Insulation columns are used by our clients in the removal of paraffin or carbohydrates, where a chemical solution (whose temperature can reach 270 Celsius, 518 Fahrenheit), is injected through the production column.

Stem Tubes Due to oil’s high viscosity and in particular “heavy oils”, it can be challenging at times to pump them through the entire production line without fault. To reduce oil’s viscosity, it is at times necessary to heat it up while still in its reservoir. Common methods in the market include a mixture of steam and water being injected directly into the reservoir, where the higher the steam fraction, the greater its diffusion into the reservoir – increasing the efficiency of the process being carried out. Steam is generated above sea level through Steam Generators and the steam is carried to the bottom of the extraction line though thermally insulated pipes. The complexity of this operation increases as the distance from the source to the Steam Generator increases, a highly efficient thermal insulated tube is necessary to carry out this operation. To help increase the efficiency of this task, a vacuum is created, however as a vacuum cannot be maintained permanently the service life of the insulated pipes used are limited. This is especially the case where the high pressure and temperature environment further corrodes the equipment utilized.

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Our Steam Tubes during their production phase (picture on the left), and examples of the finished products (right).

Columbia Technology has developed and patented an alternative to vacuum technology commonly used by our competitors, instead we utilize fumed silica, which is derived from nanotechnology as an insulating medium that does not compromise the thermal efficiency of the operation at hand. With our technology, the service life of the tubes utilized is no longer limited to the vacuum’s lifetime. In fact, our technology, when utilized correctly, has almost no impact on the thermally insulated pipes service life.

Machining Services Perform various services for milling, planing, grinding, turning and drilling. We also manufacture of various metal structures, such as tanks, bridges, pipelines, among others.

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Section 4: QUALITY MANAGEMENT SYSTEM


4.1 - GENERAL REQUIREMENTS Columbia has established, documented, implemented and maintained his Quality Management System (QMS) in accordance with the requirements of ISO 9001:2008. The system is maintained and continually improved through the use of the quality policy, quality objectives, audit results, analysis of data, corrective and preventive action and management review. To design and implement the QMS Columbia Tecnologia em Petróleo e Serviços Ltda. has: • Identified the processes needed for the QMS and their application throughout the organization and documented them on the Process Flow Diagram at the end of this section of the Quality Manual • Determined the sequence and interaction of these processes, and illustrated them on the Process Flow Diagram • Determined criteria and methods needed to ensure that the operation and control of the processes are effective. • Ensured the continuing availability of resources and information necessary to achieve planned results and continual improvement of these processes. • Established systems to monitor, measure and analyze these processes, and Established processes to identify and implement actions necessary to achieve planned results and continual improvement of these processes.

4.2 - DOCUMENTATION REQUIREMENTS 4.2.1 - GENERAL Columbia establishes a mode of organization and control of documents, allowing the preparation and distribution of Quality System documents, with information on procedures and offered services. The Columbia QMS documentation includes: Quality Manual: Describes the Quality Management System as a permanent reference. Procedures: Documents that describe how Columbia attends the norm requirements. Instructions: Documents containing detailed instructions on how to perform an activity. Records: Documents that provides objective evidence of activities performed or results obtained.

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Forms: Documents used for release information, data and orientation of QMS. May still be other additional documents referenced by the Quality Management System, as: Drawings, Technical Standards, Manual Equipment, etc... Quality Policy is documented in Section 5.3 of this manual, in 5.4.1 item the quality objectives and are documented in the “Quality Objectives”. The Management Representative (DR) makes the management, monitoring and maintenance of QMS, fitting the areas to prepare documents under the guidance and control of the quality office.

4.2.2 - QUALITY MANUAL This Quality Manual has been prepared to describe Columbia Tecnologia em Petroleo e Serviços Ltda QMS. The Quality Manual have the scope of the Quality Management System, the description of interaction between system processes and documented procedures established by Quality Management System.

4.2.3 – CONTROL OF DOCUMENTS All of the QMS documents are controlled according to the Document Control Procedure PRO. SGQ.001 – Control of Documents and Records and defines: • The documents generated internally in the company. • External documents received from customers, suppliers and third parties (applicable to the system);improvement of these processes.

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4.2.4 – CONTROL OF QUALITY RECORDS This procedure requires that quality records remain legible, readily identifiable and retrievable. The procedure defines the controls needed for identification, storage, protection, retrieval, retention time and disposition of quality records. In order to maintain control over all records cited throughout the system documentation was created at the end of each document (which references a record) a “Record Control Framework”. This frame defines: • The identification of all required records to provide evidence of conformity with the requirements and evidence for the system effective operation. • The place where these records should be stored keeping them readily identifiable and retrievable. • The storage form of these registrations ensuring it remains legible and protected. • The retention time of each record and the way of disposing after this retention time. In addition to the disposal defined in “Frames”, any record after the retention time can be available as an extension of their maintenance. Note: After the retention time set in the “Frame” (active or inactive file), every record will have to dispose their destruction (or the electronic file will be deleted). For the records in electronic media, it is the responsible department to define the best way to - Back Up.

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Section 5: MANAGEMENT RESPONSIBILITY


5.1 - MANAGEMENT COMMITMENT Our directors, Marcos Rogerio Pegoretti, Gerlyson Pegoretti, Moacir Domingos Alves and Julimar Mees have been actively involved in implementing the quality management system (QMS). It has provided the vision and strategic direction for the growth of the QMS and established quality objectives and the quality policy. To continue to provide leadership and show commitment to the improvement of the QMS, management will do the following. • Communicate the importance of meeting customer, statutory, and regulatory requirements; • Establish quality objectives; • Establish the quality policy; • Conduct quarterly management review; • Ensure the availability of resources.

5.2 – CUSTOMER FOCUS Top management of Columbia ensures that customer requirements are understood and met according to item 7.2.1. The customer satisfaction survey is done according to the procedure PRO.SGQ.010 - Customer Satisfaction, being conducted through telephone contact, e-mail, fax or customer visit and identifies the satisfaction, opportunity to improve, possible complaints, etc. When the client presents his own results satisfaction through reporting, research or complaints, Columbia presents a proposal to the costumers of improvements actions.

5.3 - QUALITY POLICY Top management ensures that the quality policy is communicated to all employees. It is included in new employee training and training on the QMS. It is posted in prominent places throughout the offices to maintain high standards within our organization.

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Management reviews the quality policy at each management review meeting to determine the policy’s continuous suitability for our organization.

QUALITY POLICY “To provide products and metalworking services that meet the needs of our customers, seeking technological advancement and continuous improvement of our Quality Management System”.

5.4 - PLANNING 5.4.1 - QUALITY OBJECTIVES Quality objectives are established to support our organization’s efforts in achieving our quality policy and reviewed annually for suitability. Quality objectives are measurable, and reviewed against performance goals at each management review meeting. Top management ensures that quality objectives, including those needed to meet the product requirements, are established for functions and relevant levels within the organization. The Management Representative (DR) in the document “Quality Objective” approves the quality objectives presented below.

QUALITY OBJECTIVES • Meet the needs to our customers, seeking their satisfaction. • Provide improvement / development activities to our employees. • Improve our processes in order to achieve positive results in audits. • Place in portfolio of Slotted Liner sector, pipes with specifications have not yet worked in our production line. • Reduce rework in production.

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5.4.2 - QUALITY MANAGEMENT SYSTEM PLANNING The quality system has been planned and implemented to meet our quality objectives and the requirements of 4.1 of the ISO 9001 standard. Quality planning takes place as changes that affect the quality system are planned and implemented as well as the quality objectives according to item 5.4.1 of the QMS. This planning system represents the organization of business decision-making. In case of planned changes in the company the QMS integrity is ensured, through internal audits and critical analysis of the QMS according to items 8.2.2 and 5.6 respectively.

5.5 - RESPONSIBILITY, AUTHORITY AND COMMUNICATION 5.5.1 - RESPONSIBILITY AND AUTHORITY An organizational chart has been established to show the interrelation of personnel in the organization. Job descriptions define the responsibilities and authorities of each of the positions on the organizational chart. Job descriptions and the organizational chart are reviewed and approved by top management for adequacy. These documents are available throughout the organization to help employees understand responsibilities and authorities. According to the document FOR.SGQ-09_ Framework Functions Defining.

5.5.2 - MANAGEMENT REPRESENTATIVE The Customer Service Representative was appointed by André Penna de Oliveira as the management representative. As management representative, they have the following responsibility and authority: • Ensure that processes needed for the quality management system are established and implemented. • Report to top management on the performance of the quality management system, and note needed improvements. • Promote awareness of customer requirements throughout the organization. • Act as a liaison with external parties such as customers or auditors on matters relating to the QMS.

5.5.3 - INTERNAL COMMUNICATION Processes are established for communication within the organization. Methods of communicating the effectiveness of the QMS include department and management meetings, management Columbia Tecnologia em Petróleo e Serviços Ltda

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review, circulation of minutes of management review meetings, Internal Audit Closing meetings, and other routine business communication.

5.6 - MANAGEMENT REVIEW 5.6.1 - GENERAL According to the document PRO.SGQ.002 - Management Review Board. Top management reviews the QMS quarterly at management review meetings. Those reviews are made every six months, after the Internal Audit Quality (AIQ). These meetings quality objectives review, the implementation of the Quality Policy, opportunities for improvement and QMS changes, using “entries for review” information.

5.6.2 - REVIEW INPUT Assessment of the QMS is based on a review of information inputs to management review. These inputs include the following: • Results of audits; • Answers or feedback from customers; • Process performance and product conformity; • Status of preventive and corrective actions; • Follow-up actions from previous management reviews; • Planned changes that could affect the quality management system; • Recommendations for improvement.

5.6.3 - REVIEW OUTPUT During these review meetings, management will identify appropriate actions to be taken regarding the following issues: • Improving the QMS effectiveness and his processes; • Improvement of product related to customer requirements; • Resources required. Responsibility for required actions is assigned to members of the management review team. Any decisions made during the meeting, assigned actions, and their due dates are recorded in the minutes of management review.

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Section 6: RESOURcE MANAGEMENT


6.1 - PROVISION OF RESOURCES Columbia Tecnologia em Petróleo e Serviços Ltda has implemented a Total Quality Management System that complies with the ISO 9001 2008 standard. This implementation was achieved with management commitment and with sufficient resources for the implementation. To effectively maintain and continually improve the system, management determines and provides necessary resources.

6.2 - HUMAN RESOURCES 6.2.1 - GENERAL To ensure competence of our personnel, job descriptions have been prepared identifying the qualifications required for each position that affects product quality. Qualifications include requirements for education, skills and experience. Appropriate qualifications, along with required training, provide the competence required for each position.

6.2.2 - COMPETENCE, AWARENESS AND TRAINING Columbia set the necessary skills in FOR.SGQ 08_Framework Functions Definition. This setting is used in new employees selection and as well the basis for preparing the training program of the company. Human Resources maintain records of employee qualifications. The “Annual Training Plan” is prepared, defining actions to be developed to meet the staff competence requirements. The oversight of the training is the responsibility of the personnel department making use of the procedure PRO.SGQ.003 - Human Resources. For each planned activity, objectives and resources are defined, developing programming skills. After the external training activities, an evaluation of its effectiveness is made by checking whether objectives were achieved using FOR.SGQ-08 form - Training Evaluation. For integration and recycling activities, the evaluation effectiveness is done by monitoring the employee during his service. This analysis is the responsibility of the heads of each area. If it is not considered effective, corrective action must be defined.

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The Columbia ensures that his staff are aware of the relevance and importance of their activities and how they contribute to achieving the quality objectives. Constant guidance and information are held by the immediate superior addition to conducting internal events not foreseen in the “Annual Training Plan”.

6.3 – INFRASTRUCTURE The infrastructure has been provided and includes buildings, workspace, utilities, and supporting services, are appropriate to their production process. All products are offered, ensuring the customers requirements. The equipment and instruments used are in suitable condition and sufficient quantities. The procedure PRO.SGQ.004 - Preventive and Corrective Maintenance, ensures the condition of the equipment doing frequent inspections and corrections when necessary.

6.4 - WORK ENVIRONMENT Columbia ensures the right conditions in your workplace, having appropriate facilities for their activities, keeping them clean and organized. The company ensures that regulatory standards are met, security conditions according to their activities and provides individual and collective safety equipment.

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Section 7: PRODUCT REALIZATION


7.1 - PLANNING OF PRODUCT REALIZATION The product realization of Columbia is defined by the direction and executed by the production responsible area for the transformation of input resources, such as feedstock, in the final company product. Quality planning is required before new products are implemented. The quality planning may take place as a design project, or according to the “Product Matrix x Process”. Columbia has established and implemented a planning system represented in PRO.SGQ.012 procedures - Manufacture of Slotted Liner and PRO.SGQ.013 - Machining Services and Boiler. This system is established in a consistent way with the other requirements of QMS company processes. For the presented cases, the objectives and requirements related to the product are defined, being identified and also quantified the necessary resources to meet the market requests. In the procedures, the production system are defined as their methods of execution, as well as the verification, validation, monitoring and inspection of the product. These procedures are also identified, as well as the registers needed to promote the evidence that realization processes and the resulting product meet the established requirements. PRO.SGQ.012 – Manufacture of Slotted Liner and PRO.SGQ.013 – Machining Services and Boiler procedures, assist in planning and developing of Columbia productive process.

7.2 - COSTUMERS RELATED PROCESS All Systematics of Determination and Critical Analysis from Requirements Related to the Product (Commercial) as well as the systematic Customer Communication are defined in PRO. SGQ.005 - Customer Related Processes.

7.3 - DESIGN AND DEVELOPMENT The products and services provided by Columbia may be of two different sorts. On the first one the construction follows the client requirements and design, therefore the performance of these services does not depend only of Columbia, since the customers already determine their products characteristics in a documented way. On the other hand, we also provide our

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own solutions and for those services and products, we are consistently improving based on technical papers and clients feedback.

7.4 - PURCHASING 7.4.1 - PURCHASING PROCESS Columbia acquisitions that affect your business and the quality of their products are: supplies, raw materials, safety equipment and outsourced services (calibration, maintenance, transportation, inspection and non-destructive testing, painting, etc.). The products acquisition is defined in PRO.SGQ.006 - Acquisition. All evaluation, selection and re-evaluation of products supplies in Columbia are defined by the PRO.SGQ.007 - Selection and evaluation of suppliers as well as the verification of purchased products.

7.5 – PRODUCTION AND SERVICE PROVISION 7.5.1 - CONTROL OF PRODUCTION AND SERVICE PROVISION Columbia Tecnologia em Petróleo e Serviços Ltda plans and carries out production and service provision, listed below: • The availability of work instructions; • The use of suitable equipment; • The availability and use of monitoring and measuring devices; • The implementation of monitoring and measurement; • The implementation of release, delivery and post-delivery activities; • The availability of information that describes the characteristics of the product;

7.5.2 - VALIDATION OF PROCESSES PRODUCTION AND SUPPLY PROVISION Columbia checks all its products and services before their release and delivery to the customer through inspections as defined in item 8.2.4.

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7.5.3 - IDENTIFICATION AND TRACEABILITY The Service Order number identifies Columbia Tecnologia em Petr贸leo e Servi莽os Ltda products and services. Delivery of these services, appropriate data are recorded being referenced in the procedures and forms of Columbia. These records are properly filed in the responsible areas, allowing access to data services and procedures. Under specific conditions, the product is marked with number of Service Order, marked in low relief ink or label, as appropriate. Below is a traceability flow, which is an indicative scheme to reach data and registration forms for processes and services.

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7.5.5 - PRODUCT PRESERVATION Columbia Tecnologia em Petróleo e Serviços Ltda preserves the conformity of product during internal processing and delivery to the intended destination. This preservation includes identification, handling, packaging, storage and protection. Preservation also applies to the constituent parts of a product. The “Preservation Framework” presents a list of items and products used for the preservation of its features.

7.6 – CONTROL OF MONITORING AND MEASURING DEVICES Columbia Tecnologia em Petróleo e Serviços Ltda, throughout its production process and its documented procedures, defines and identifies measurements and monitoring, used for control of products and processes. Columbia Tecnologia em Petróleo e Serviços Ltda has defined and documented procedure PRO. SGQ.009 - Measurement and Monitoring Equipment Control, which identifies and presents the data of equipment and instruments used for measurement and inspection of product quality. The “Annual Calibration Map” shows the projected calibration of instruments used in the production process that are calibrated externally. This map only include instruments that need externally calibration. The “Measuring Equipment Register” shows the projected calibration of internally instruments, as well as the result of external calibrations. Traceability is maintained through labels attached in the equipment and / or in sandboxes of inspection and measuring instruments, which also indicate the calibration status. The label shows the calibration date and the validity date. When it is executed externally, the calibration is kept as records, reports or certificates. For the instrument to be released to production, It might be necessary to have a stamp for the Production Supervisor, Mechanical Technician and / or Responsible Planning Area in which the instrument / equipment will be used.

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Section 8: MEASUREMENT, ANALYSIS AND IMPROVEMENT


8.1 - GENERAL Columbia Tecnologia em Petróleo e Serviços Ltda plans and implements the monitoring, measurement, analysis and improvement processes as needed

• To demonstrate conformity of the product • To ensure conformity of the quality management system • To continually improve the effectiveness of the quality management system

These processes are identified and documented as procedures and include determination of applicable methods, including statistical techniques, and the extent of their use. It is the management responsibility and / or supervisors of areas to identify, define and develop statistical indicators applied to their activity, using to results analysis and implementation of fixes and needed improvements.

8.2 - MEASUREMENT AND MONITORING 8.2.1 - COSTUMER SATISFACTION Columbia Tecnologia em Petróleo e Serviços Ltda aiming accompany the customers requirements, has developed and implemented the procedure PRO.SGQ.010 - Customer Satisfaction. It has researches that spontaneously depart from customers. In the case of complaints, the procedure PRO.SGQ.005 - Customer Related Process, which guides how to register and handle dissatisfactions, if the reason for the claim proceed. Since it is improvements, the identified opportunities are documented, analyzed and formally proposed, putting in evidence the needed benefits and resources. If approved, are implemented recording the results. The treatment of customer complaints and of improvements implementation are described in item 8.5 of this manual.

8.2.2 – INTERNAL AUDITS An instrument for the Top Managers Management are internal audits – which are systematic reviews, independent and periodic tests performed to determine if the Management System

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conforms to the planned arrangements, to the requirements of ISO 9001. Columbia Tecnologia em Petróleo e Serviços Ltda has established and maintains in the PRO. SGQ.011 - Internal Audit, the systematic for planning and implementation of internal audits in all sectors involved in the QMS.

8.2.3 – MEASUREMENT AND MONITORING PROCESS The manufacturing and support processes, are measured and monitored continuously to achieve planned results and certain targets. Office and RD is responsible, along with areas to identify, define and prepare, measurement methods and their statistical indicators applied to his activities, using them to analyze the results and implemented the corrections and improvements needed. Columbia Tecnologia em Petróleo e Serviços Ltda uses Internal Audit and Quality Objectives as a tool to measure and monitor all Management System Processes. This demonstrate the processes ability to achieve planned results. When planned results are not achieved, correction is made and corrective action taken, as appropriate, to ensure the product conformity. Corrective and preventive actions, are implemented following the system described in Section 8.5 of this manual.

8.2.4 – PRODUCT MEASUREMENT AND MONITORING Columbia Tecnologia em Petróleo e Serviços Ltda monitors and measures the characteristics of the product to verify that product requirements are fulfilled. The products are retained and not used until its inspection has been completed. Evidence of conformity with the acceptance criteria is maintained. Records indicate the person authorizing release of product. Product release and service delivery does not proceed until all the planned arrangements have been satisfactorily completed, unless otherwise approved by a relevant authority.

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8.3 - CONTROL OF NONCONFORMING PRODUCT Nonconforming Product are those produced by Columbia Tecnologia em Petróleo e Serviços Ltda or contractors who do not meet the customer’s specifications, detected by final inspection, customer complaint or during the process and involving rework, scrap or breach of contracted terms. These products are identified by the inspection activities, customer complaints and also for the execution and processes control. The procedure PRO.SGQ.014 – Nonconforming Product Control, presents activities for identification, segregation, causes evaluation, treatment and disposal of these nonconforming products. In some situations, suitable records are made for non-compliant products identification and referrals to correction, determined by the responsible department. When is not possible reclaim the non-conforming products for rework or reprocessing, these are discarded and may be scrapped as reusable or sale.

Review and Disposal of Nonconforming Product The nonconforming product may be supplied, since formally accepted by the customer, reclassified, reworked or even scrapped. When not, the product will be discarded. When nonconforming product is identified, the filled field is “Nonconforming Item” in the “Inspection Report”, describing the incident and indicating the action to be taken for correction. The evaluation of these products is made for the production supervision and posteriorly quality committee review is made. The non-conforming product is identified by label, being directed for a specific nonconforming product area. After correction was done, the nonconforming product is inspected again as specific procedures of that activity. The area is responsible for execution of the process that generated the non-conforming product, as well the definition of treatment where the non-conforming product has affected the customer service or the target set. A study of cause and corrective definition action for their elimination will be done according to section 8.5.2 of this manual.

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In case of customer complaint should be agreed with it, repair or new delivery of service to meet the specified requirements. Correction records of non-conforming product are kept containing: • Non-conformities found in these products • Implemented corrective actions • Concessions obtained from clients or legal authorities (when applicable).

8.4 - ANALYSIS OF DATA Columbia Tecnologia em Petróleo e Serviços Ltda determines, collects and analyses appropriate data to demonstrate the suitability and effectiveness of the quality management system and to evaluate where continual improvement of the quality management system can be made. Appropriate data includes data generated as a result of monitoring and measurement and from other relevant sources. The analysis of data provides information relating to: • Customer satisfaction • Conformance to product requirements; • Characteristics and trends of processes and products including opportunities for preventive action; • Suppliers. Are used for data analysis: charts, indicators, statistical techniques. The analyses are discussed in Meetings Review (see item 5.6 of MQ), to demonstrate the effectiveness and adequacy of the Quality Management System and identify opportunities for improvements.

8.5 - IMPROVEMENT 8.5.1 - CONTINUAL IMPROVEMENT Columbia Tecnologia em Petróleo e Serviços Ltda continually improves the effectiveness of the quality management system by the quality policy, quality objectives, audit results, analysis of data, corrective and preventive actions and management review.

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Columbia Tecnologia em Petróleo e Serviços Ltda believes every employee should contribute to continuous improvement and guarantee every idea of improvement is properly analyzed and if positive, the company puts it into practice. Columbia Tecnologia em Petróleo e Serviços Ltda give priority to people, believes the main improvement effort must come from a new mindset and work style of people (staff focus on quality, teamwork, cultivation of wisdom, high morale, discipline, individual or group quality circles and practical suggestions). Besides the fact of being always open to new ideas, not getting a fixed pattern but a pattern of continuous improvement.

8.5.2 - CORRECTIVE ACTION Columbia Tecnologia em Petróleo e Serviços Ltda takes action to eliminate the cause of nonconformities in order to prevent recurrence. Corrective actions are appropriate to the effects of the nonconformities encountered, following the procedure related in PRO.SGQ.015 - Corrective Action.

8.5.3 - PREVENTIVE ACTION Columbia Tecnologia em Petróleo e Serviços Ltda determines action to eliminate the causes of potential nonconformities in order to prevent their occurrence. Preventive actions are appropriate to the effects of the potential problems, and these actions are described in the procedure PRO.SGQ.016 - Preventive Action.

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Section 8: enviroment


Columbia Tecnologia em Petr贸leo e Servi莽os Ltda cares about the environment. For that, classified all generate residues, and give them the correct disposal destination as required by public agencies or even customers. Residues such as paper, plastic and wood are destined for municipal collection. Oils and their derivatives are stored to be donated to a gas station. Scrap metals can be returned to customers or sold. Follow the frame with the residues, collect and destination:

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RESIDUES

COLLECT

DESTINATION

Paper and plastic

Bins

Municipal collection

Metallic

Area of scrap metal

Sale third party, and / or returned to customer

Wood

Dumpster

Collection by specialized company

Oils and derivatives

Barrels plastic

Collection by specialized company

Contaminated

Casks and buckets

Collection by specialized company

Columbia Tecnologia em Petr贸leo e Servi莽os Ltda


Section 10: Safety at work


Columbia Tecnology knows the legal and normative requirements related to safety at work and follow these requirements. Provides individual and collective protective equipment to their employees, making the necessary guidance for use and verifying their effective use in daily activities, and do weekly meetings “Safety Minute” for a deeper orientation. The safety at work is part of the employee training program, and when necessary made Internal Commission for Accidents Prevention-CIPA, PPRA and PCMSO.

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Columbia Tecnologia em Petr贸leo e Servi莽os Ltda

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