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AC7126 REV.

C
Issued 2010-03
AUDIT CRITERIA
Revised 06-Feb-2017
161Thorn Hill Road
Warrendale, PA 15086-7527 Superseding AC7126 Rev. B

TO BE USED ON AUDITS STARTING ON OR AFTER 21-MAY-2017

Nadcap
AUDIT CRITERIA FOR
CONVENTIONAL MACHINING AS A SPECIAL PROCESS
(HOLEMAKING, BROACHING, TURNING, MILLING, GRINDING, EDGE TREATMENT)

1. SCOPE

These Audit Criteria are intended for use to survey a facility seeking
accreditation by Nadcap for Conventional Machining as a Special
Process (CMSP) processes. These criteria are supplemented by
process Audit Criteria for specific machining processes to be
accredited.

The purpose of these Audit Criteria is to provide a means to verify and


document that systems are in place to control processes, and that the
process procedures are being followed.

Note: the questions in this checklist contain no Export Control (EC)


content.

2. GENERAL INSTRUCTIONS

2.1 Instructions for the Auditors

PRI operating procedures provide that "This report is published by PRI to advance the state of technical, engineering, and quality
sciences. The use of this report is entirely voluntary, and its applicability and suitability for any particular use, including any patent
infringement arising there from, is the sole responsibility of the user."

PRI values your input. To provide feedback on this document, please contact the appropriate commodity staff engineer.
(Contact information is located at http://www.eauditnet.com under “Contact Us”.)
Copyright 2016 Performance Review Institute. All rights reserved.
t-frm-15 04-Jan-2016
PRI AC7126 Revision C -2-

In completing this assessment, auditors are instructed to respond with a


“YES” or “NO” to address compliance with each statement of
requirement. For any negative responses, the auditor must clearly
indicate if the “NO” reflects noncompliance with respect to existence,
adequacy, and/or compliance. Existence relates to evidence of a
procedure or policy, adequacy relates to the completeness of the
procedure or policy and compliance relates to evidence of effective
implementation.

All negative responses require a Nonconformance Report (NCR) or


explanation.

All “Not Applicable” (NA) responses must be explained.

The audit results should not include any Customer proprietary or


International Traffic in Arms Regulations/Export Administration
Regulations (ITAR/EAR) information, as it may be viewed by any
Nadcap subscriber.

Definitions as well as Customer specific references are located in the


CMSP Audit Handbook and Audit Handbook Appendix A – Subscriber
References. These guidance documents are located in eAuditNet
Public Documents.

2.2 Instructions for the Supplier

2.2.1 Prior to the Audit

The Supplier shall complete a self-audit to AC7126 and applicable


process checklists in preparation for this audit. All internally identified
nonconformances should be corrected prior to the actual audit. All not
applicable (“NA”) answers must be explained.

The Supplier shall forward the following to the assigned auditor at least
30 days prior to the scheduled audit (in English, unless otherwise
agreed between auditor and Supplier)

The submitted information should not include any Customer proprietary


or International Traffic in Arms Regulations/Export Administration
Regulations (ITAR/EAR) information.

List of current quality systems approval (Registrars, Customers,


expirations, etc.)

Completed copy of the self-audit checklists (including job audits and


explanations for questions marked NA, noting the procedure number
and clause where applicable).

A drawing or detailed list defining the equipment used for processing


those parts for which Nadcap accreditation is sought.
PRI AC7126 Revision C -3-

2.2.1.1 Did the Auditee make a copy of their completed self-audit available to YES NO
the auditor at least 30 days prior to the audit date - utilizing the version
of the checklist(s) applicable to this audit?
Compliance Assessment Guidance (CAG): Nadcap recommends the
following:
Self-audit to be performed 90- 120 days prior to the scheduled audit. In
the event of a checklist(s) revision, a 90-day notification is required to
allow sufficient time for compliance. An audit against the changes is
acceptable if it supplements the existing self-audit -therefore together
meeting the expectation to utilize the version of the checklist applicable
to the scheduled audit

2.2.1.2 For each question in the checklist, has the Supplier identified where the YES NO
means of compliance or evidence* of compliance may be found.
(* procedure, checklist, physical location of evidence, etc.)

2.2.1.3 Does the self-audit include job audits as required by the Task Group? YES NO
CAG: The CMSP Task Group requires that one job audit per relevant
Subscriber per checklist shall be completed.

2.2.2 During the Audit

The Supplier shall provide for an in-briefing with the auditor. Key
members of the applicant’s staff should attend the in-briefing so the
audit purpose, methods, and assessment processes can be discussed.

Working space for the auditor with desks or tables, chairs, telephone,
etc. shall be made available. Clerical, typing and reproduction services
are to be provided, as required. This is not a full time assignment.

Auditor shall verify the scope of accreditation and modify it in eAuditNet


as required in agreement with the Supplier.

Job audits should be selected based on rotation of Subscribers, part


number and other criteria such as equipment and operators. The job
tracker shall be used to help select job audits.

A final out-briefing shall be conducted at the completion of the audit.


Each nonconformance and observation will be reviewed and the
Supplier will be given the opportunity to discuss proposed corrective
action or to provide any additional information.

2.2.3 Following the Audit


PRI AC7126 Revision C -4-

In accordance with Nadcap procedures, the Supplier has 21 calendar


days from the close of the audit to submit a corrective action plan and
identify effective dates for each NCR. The response must address the
immediate action taken to resolve the discrepancy, the root cause of
the nonconformance from a systems management approach, and the
actions taken or to be taken to preclude reoccurrence. When objective
evidence is required, it shall be submitted within 21 calendar days from
the close of the audit.

PRI Staff or the Task Group may, after review of the audit report,
require additional information or may find cause to issue additional
findings.

The CMSP Task Group may, upon review, change the auditors’
determination of a finding or observation.

Nonconformances identified as part of the Nadcap audit with potential


product impact may, at the CMSP Task Group’s discretion, require a
VCA (verification of corrective action) follow-up audit at the Supplier’s
expense.
NOTE: Final authority over the audit report, acceptability of corrective
actions and accreditation recommendation rests with the Task Group.

2.3 Job Audits

A minimum of two job audits are normally required for each checklist. If
there are multiple methods checked for a given checklist, then at least
one job audit is performed per method. If there is a satellite audit, then
two job audits per checklist are performed at the satellite location
unless otherwise arranged with the staff engineer.

It is preferred that live audits are performed. When no hardware is


currently in production, a scrap part or non-production material may be
utilized.

When any of the above are not available, a completed production job
may be audited; the expectation is that it is of a recent production job.
The auditor will still audit the set-up, tools, fixtures, parameters,
operators, etc. by simulating the job without any material at the
machine.

3. SUPPLIER INFORMATION
NOTE: *Only information not contained in eAuditNet shall be recorded.

3.1 General Information


PRI AC7126 Revision C -5-

Nature of Business: ______________________________________________________


In-House Products Only (Captive):______ Accepts Outside Work: _____________
Total Employees: ________________ Number#ofQAPersonnel:
________________
Number# of CMSP Personnel : __________________________________________
Facility Size (Square Footage): ________ Number of Operating Shifts: _________
Company*: _______________________ Audit Date(s)*:____________________
Division*: ________________________ Phone*: _________________________
Address*: ________________________ Facility*: _________________________
City/State/Zip*: __________________________________________________________
Comments: ____________________________________________________________

3.1.1 Audit Contacts

Identify the primary contact for the audit.

Name Title/Position Contact number*

3.1.2 CMSP Equipment

Attach the drawing or detailed list defining the equipment used for
processing those parts for which Nadcap accreditation is sought

3.1.3 DELEGATED AUTHORITY

Identify any individuals holding delegated authority for CMSP


processes e.g. Honeywell SCA

Name Title/Position/Delegation held Contact number*

3.2 Quality System Approvals

Identify any current approvals related to quality system compliance in


accordance with Nadcap OP 1114.
PRI AC7126 Revision C -6-

Auditing/Certifying Agency Audit Criteria Certificate Issue Date Certificate Expiration Date

The Nadcap CMSP Task Group recognizes PRI AC7004 and/or a


Nadcap approved quality system in accordance with Nadcap OP
1114. If the Supplier has been audited and has an approved quality
system in accordance with the requirements of Nadcap OP 1114,
then no further assessment for quality systems existence will be
required. Although specific audit criteria for evaluation of the general
quality system is not included within the text of this checklist, the
requirements of the Supplier’s approved quality system do form a part
of the standard used in the Nadcap CMSP Accreditation program. As
such, auditors may identify and record nonconformances related to
the quality system. These nonconformances must be addressed by
the Supplier in order to obtain Nadcap accreditation.

This checklist includes process-focused criteria that test the quality


system for compliance relative to conventional machining as a special
process.

If there is no evidence of an AS/EN/JISQ9100 or an AC7004, then an


AC7004 audit will be included in conjunction with this audit.

4. GENERAL QUALITY SYSTEM REQUIREMENTS

4.1 During the course of the audit, was compliance with the existing YES NO
quality system demonstrated?

4.2 For re-accreditation audits, are corrective actions from previous audit YES NO NA
findings implemented?
CAG: NA only applies if there have been no Nadcap audit findings in
the previous CMSP audit or if this is an initial audit.

5. GENERAL SYSTEM REQUIREMENTS

5.1 General Conventional Machining as a Special Process

5.1.1 Does the Supplier have a procedure detailing how to assure YES NO
Customer requirements for controlled machining operations are met?
CAG: All Suppliers shall determine during contract review if the
machining needs to be controlled and if it needs to be qualified. If the
given Customers have requirements on how to qualify their parts, the
procedure shall meet those requirements.

5.1.2 To perform each conventional machining process for which YES NO


authorization is required, does the Supplier have documented
approval that complies with Customer requirements or is there
evidence of internal approval if no Customer authorization is required?
PRI AC7126 Revision C -7-

CAG: Even if no Customer authorization is required, the Supplier must


define their system for internal approval for it to be considered CMSP
level machining.

5.1.3 Does the Supplier have the required revision(s) of the Customer YES NO
specifications?

5.2 Frozen Processes

5.2.1 Does the Supplier have a procedure to assure that prior to YES NO
implementing any changes to process parameters or Customer
approved documents, that the changes are 1) internally reviewed to
determine if a new substantiation is required, 2) maintained as
records even if only administrative, 3) submitted to the Customer if
needed, 4) approved by the Customer if needed?
CAG: The Supplier must define their system. In addition, if there are
any Customer requirements they must also be incorporated into the
procedure. Also, the auditor is to verify the system by investigating a
process that was changed or if no changes have been made verify
that personnel are aware of the procedure.

6. CONTROL OF SUB-CONTRACTORS

6.1 Does the Supplier have a procedure detailing the process to sub- YES NO
contract machining which ensures any sub-contracted CMSP
processes still meet the Customer requirements?
CAG: Even if no machining is sub-contracted, this shall be
documented.

6.2 Sub-contracted Processes SECTION NA

Section NA applies to section if there are no sub-contracted Nadcap


CMSP processes.

6.2.1 Are facilities used for sub-contracted machining processes approved YES NO
per Customer requirements, by either the Customer or by the Supplier
if the Customer has delegated that authority?
CAG: The Supplier must have objective evidence that they have been
delegated the authority to approve subcontractors for machining if the
subcontractor does not have direct Customer approval.

6.2.2 Has the Supplier documented flow down of Customer requirements YES NO
including if applicable the latest copy of Customer specifications to
any sub tier Suppliers?

6.2.3 When sub-Suppliers are used for any portion of a process is the YES NO
process data reviewed and approved?
CAG: The data shall be reviewed by authorized individuals as defined
by the Supplier or if applicable the Customer.
PRI AC7126 Revision C -8-

7. CUTTING TOOL AND ABRASIVE CONTROL


NOTE: This section applies to custom and catalog tools.

7.1 Procurement Procedure


NOTE: Section 7.1 questions apply to systems for the management of
incoming tools whether they are purchased, supplied by the
Subscriber or a Customer, or manufactured in house.

7.1.1 Is there a cutting tool and abrasive procurement procedure? YES NO


CAG: The requirements of AS9100/AC7004 shall be applied to cutting
tools and abrasives. The Supplier shall assure that only tools that
match the approval document and any additional Customer
requirements are purchased, that they are verified upon receipt, who
is responsible for the process, etc.

7.1.2 Are tool and abrasive suppliers/manufacturers approved per the YES NO
Supplier’s procedure and any additional Customer requirements?

7.1.3 Is there a procedure to ensure that non-standard tools, if used, are YES NO NA
procured to the correct revision of the drawings?
CAG: NA is applicable if no non-standard tools are used.

7.1.4 Do tool drawings flow down all Customer requirements? YES NO NA


CAG: Even if only standard tools are used, there shall be a system in
place to identify Customer requirements and to address tool drawings.

NA applies where there are no tool drawings.

7.1.5 Does the tool and abrasive procurement procedure ensure that new YES NO
and re-ground tools are in Compliance to the purchase order and/or
Customer requirements?
CAG: Certificate of Compliance (CoC) is one method but not the only
method. However, verifying the CoC may be required by some
Customers.

7.1.6 Is there a procedure assuring that any foreseen changes to Customer YES NO NA
approved cutting tools are communicated in advance to their effective
date to the Supplier by their tool vendors, when required by the
Customer?
CAG: NA applies if there are no Customer requirements.

7.2 Tool Control Procedure


PRI AC7126 Revision C -9-

7.2.1 Is there a cutting tool control procedure that assures only the correct YES NO
cutting tools and abrasives are issued to the workstation?
CAG: For indexable inserts the Task Group expectation is that there is
documentation for the operator to define their use. One insert edge is
considered equal to one cutting tool and does not need to be tracked
unless it is used for more than one part.

7.2.2 If particular cutting tools / abrasives (tool types, tool materials, YES NO NA
coating, etc.) are prohibited by the Customer, is this documented and
followed?
CAG: NA applies only if none of the Customer have prohibited specific
tools.

7.2.3 Is there a change management control procedure for cutting tool YES NO NA
drawings?
CAG: NA, if only standard catalogue tools are used

7.2.4 Is there a person or function responsible for cutting tool and abrasive YES NO
compliance to Customer requirements?
CAG: This shall be explicitly documented such as in a procedure or
job description.

7.2.5 Do tool drawings identify all critical characteristics, including cutting YES NO NA
tool material and regrind limits (where applicable)?
CAG: NA is permitted if no tool drawings are used.

7.3 Worn Cutting Tools and Abrasives

7.3.1 Is there a procedure to assure that worn cutting tools and abrasives YES NO
are dispositioned (either disposed of or reconditioned) and not
inadvertently re-used?
CAG: If the wear is not easily visible on a used insert cutting edge, it
is necessary to have a method to prevent improper reuse of a given
edge.

7.4 Reconditioning In House

7.4.1 Is there a procedure to assure tool reconditioning requirements are YES NO NA


identified and flowed down internally including critical requirements
and, where applicable, Customer critical requirements?
CAG: NA applies if reconditioned tools for the processes being
audited are not reconditioned in house.

7.5 Reconditioning Outsourced SECTION NA

Section NA applies if reconditioned tools for the processes being


audited are not outsourced for reconditioning.
PRI AC7126 Revision C - 10 -

7.5.1 Is there a procedure to assure tools are reconditioned to the YES NO


Supplier’s, and if applicable to the Customer’s, critical requirements?

7.5.2 Are the reconditioning criteria and requirements incorporated into the YES NO
purchase requirements/drawings and verified?
CAG: The Supplier shall flow down the requirements and verify tools
are reground to the original geometry and/or the specific requirements
from the Subscriber, e.g. max number of times or length.

7.5.3 Does the Supplier have a procedure for approving sources for cutting YES NO
tool reconditioning?

7.5.4 Are cutting tool reconditioning sources approved per the Supplier's YES NO
procedure?

8. CUTTING FLUID CONTROL SECTION NA

Section NA applies if cutting fluid is not required for the processes


audited.

8.1 Procurement Procedure

8.1.1 Is there a procedure to approve the cutting fluid manufacturer/supplier YES NO


when required by the Customer?
CAG: The requirements of AS9100/AC7004 section 7.4 shall be
applied to cutting fluids if the Customer has requirements on the
cutting fluid. If there are no specific cutting fluid requirements, there
shall be a system to identify this during contract review.

8.1.2 If required by the Customer, is there a procedure to notify the YES NO


Customer of the cutting fluid for process approval?
CAG: Even if there are no Customer requirements, there shall be a
system to verify and flow down this requirement if applicable.

8.1.3 Do the cutting fluids purchased meet the requirements? YES NO


CAG: The requirements may be either those of the Customer or the
Supplier. Examples include being on QPL, chemical content of fluids,
etc.

8.1.4 When required by the Customer, does the Supplier assure changes in YES NO NA
the composition of Customer approved cutting fluid are communicated
to them by their cutting fluid vendors/manufacturers?
CAG: NA is applicable if there is no Customer requirement

8.1.5 Does the Supplier verify the requirements, including all Customer YES NO
requirements, for cutting fluids have been met prior to their release for
production use?
PRI AC7126 Revision C - 11 -

8.2 Cutting Fluid Control Procedure

8.2.1 Is there a procedure for cutting fluid maintenance that covers the YES NO
necessary elements for the cutting fluid(s) in use, including frequency
of testing and storage?

 Assigned responsibility for control

 Concentration or chemistry check/maintenance (water-based


fluids)

 Viscosity and particle concentration (cutting oils)

 Tramp oil control (maximum allowed concentration)

 Cleaning requirements prior to re-charge

 Filtration

 Systems or procedures to prevent fluid contamination


CAG: Specific tests and frequencies will vary depending on the fluid in
use. For this question, the exact tests and frequencies are up to the
discretion of the Supplier so long as the listed points are considered,
documented and followed.

8.2.2 Does the procedure for cutting fluid maintenance meet manufacturer’s YES NO
recommendations and if applicable any Customer requirements?

9. EQUIPMENT

9.1 Equipment Qualification

9.1.1 Does the Supplier have a procedure for equipment qualification, YES NO
including re-qualification intervals, and does it meet Customer
requirements where applicable?

9.1.2 Are there procedures in place to assure equipment is re-qualified after YES NO
maintenance to any spindle, axis drive, or monitoring systems before
the equipment is returned to production?

9.1.3 Are instruments/gages used to qualify equipment part of the YES NO


Supplier’s approved calibration system?

9.1.4 Are there procedures or templates detailing how to test the YES NO NA
functionality of each monitor/alarm system function?
CAG: This may apply to alarms on cutting fluid, spindle speed, etc. in
addition to process monitoring system alarms. Refer to CMSP
Handbook Appendix A.

NA applies if the equipment used has no alarms.


PRI AC7126 Revision C - 12 -

9.1.5 Does the procedure identify which gages do not require calibration, YES NO
i.e. reference-only gages, and how they are to be identified?
CAG: Gages/readouts that are used by the operator to set process
parameters or to set alarm limits must be calibrated. Gages/readouts
associated with machine function (e.g. lubrication levels) need not be
calibrated. Gages either shall be marked or proceduralized as to
being reference only.

9.1.6 Are tool wear measurement devices included as part of the Supplier’s YES NO NA
approved calibration system?
CAG: NA applies if tool wear measurements are not required.

9.2 Equipment Maintenance

9.2.1 Is there a documented maintenance plan which clearly communicates YES NO


all actions required to keep the equipment in good working condition
including the following points:

 Lubrication procedure

 Cleanliness procedure

 Moving parts degradation inspection

 Responsibility and frequency

 Cutting Tool holder inspections

 Part holding fixtures and cutting fluid nozzles?

9.2.2 Where unique Supplier or Customer requirements exist, does the YES NO NA
maintenance training program include the specifics for CMSP
machine maintenance?
CAG. NA applies where unique Supplier or Customer requirements do
not exist.

9.2.3 Are records maintained for all maintenance actions, preventive and YES NO
otherwise, for each machine and cutting fluid system?

9.2.4 Are cutting fluid Pressure or Flow levels evaluated as part of YES NO
preventive maintenance (P/M) or equipment calibration?
CAG: If there is a required cutting fluid pressure or flow this must be
validated at least annually. If flood is permitted, then a visual
inspection during P/M is sufficient.

10. WORKSTATION AUDITS

10.1 Does evidence exist to show workstation audits for CMSP have been YES NO
performed in accordance with the Supplier's procedures and any
Customer requirements?
PRI AC7126 Revision C - 13 -

11. PROCESS DEVIATIONS

11.1 Does a procedure exist for notifying the Customer of deviations to YES NO
Customer requirements?

11.2 If there is a failure to comply with a Customer required validated YES NO


condition, is this identified, comprehensively documented and
reported to the Customer for analysis as per the procedure?
CAG: A failure to comply with a validated condition includes approved
process parameters, consumables, etc. Check that the
nonconforming product procedure was followed for machining
examples. If there are no examples, check for awareness.

11.3 Does the Supplier have a procedure requiring that operators are to YES NO
notify the authorized personnel and cease machining if any unusual
appearance of part, tool, or chip occurs?
CAG: The procedure defines how the operator is to report unusual
process conditions and who has responsibility to disposition it. This
procedure must encompass all process deviations defined by
Customers’ requirements. “Authorized personnel” is as defined by the
Customer or if there is no Customer definition a person with the
correct training as defined by the Supplier.

11.4 Is there a procedure describing how Special Cause Events are to be YES NO
handled, and is it consistent with any Customer requirements?

11.5 Are Special Cause Events managed per internal procedures and YES NO
specific Customer requirements, including evaluation/disposition of
the hardware? Verify consistency with Customer requirements.

11.6 Does the Supplier have a procedure that assures the functionality of YES NO
the machine is thoroughly checked and, if necessary, restored after a
Special Cause Event and prior to the restart of production?

12. TRAINING AND EVALUATION OF PERSONNEL

12.1 Are there training procedures that assure personnel performing YES NO
Conventional Machining as a Special Process and associated quality
and test functions are qualified to perform assigned tasks and is this
per Customer requirements for any specific processes which are in
the scope of accreditation?
CAG: There may be two types of training, operator qualification
training and additional Customer specified content.

12.2 Is there a determination of the effectiveness of training CMSP YES NO


personnel, including understanding of the Customers controlled
process procedures and requirements?
CAG: Examples might include specific practical testing, awareness
testing or written tests.
PRI AC7126 Revision C - 14 -

12.3 Does the Supplier have a procedure defining the circumstance for the YES NO
loss of operator qualification?
CAG: This applies to general operator qualification as well as any
Customer specific requirements.

12.4 Do records indicate that operators qualified to perform Conventional YES NO


Machining as a Special Process and other personnel as required by
the Customer have met all training and qualification requirements?
CAG: Check record keeping system for training and qualification for
operators, engineers, inspection personnel, etc. who are audited.

12.5 Does the Supplier have a system to assure periodic training and YES NO
qualification (where required) are performed at the required intervals?
CAG: There shall be a system to initiate the training. Relying on
memory is not adequate. Examples of systems include gage recall
systems, calendar reminders, etc.

12.6 Does training include all personnel referenced per the Customer YES NO
requirements?
CAG: Some Customer training requirements apply to personnel other
than operators, e.g. process engineers, inspectors and quality
engineers.

13. NC OR CNC PROGRAMQUALITY ASSURANCE SECTION NA

Section NA applies if the Supplier does not use equipment such as


NC or CNC’s which have part specific programs.
NOTE: This section applies to Suppliers and processes where the
approved process controls are based, at least partially, on a stored
and retrieved program or program listing. Typically, these programs
are loaded and executed on the machine.

13.1 Is there a procedure for the control of CNC programs? YES NO

13.2 Is each program uniquely identified? YES NO

13.3 Is there a revision history maintained of changes to a program? YES NO

13.4 Is there an approval process for new and modified programs? YES NO

13.5 Is new or changed program validation (1st piece) approved by Quality YES NO
and maintained for record purposes?

13.6 Is a backup of all programs done on a timely basis (at least once per YES NO
month or other interval if approved by the Customer) and are back-
ups in a secure location?

13.7 Is there a process in place to protect against unauthorized changes to YES NO


a program after first piece inspection has been completed and
approved?
PRI AC7126 Revision C - 15 -

13.8 Is there a process in place to prevent processing of parts using YES NO


obsolete programs?

14. REWORK

14.1 Is there a procedure for performing rework and is it consistent with YES NO
Customer requirements?
CAG: Rework either shall be done per the original approved process,
an optional approved rework process, or approved on a case by case
basis by the Customer.

14.2 Is there objective evidence of following the rework procedure or if no YES NO


rework has been done are operators aware of it?

15. OTHER REQUIREMENTS

15.1 If testing (e.g. metallography, fluid chemistry, etc.) is required by the YES NO NA
Customer, is it performed by a Customer approved source?
CAG: The scope of this testing also includes nondestructive testing
including, but not limited to nital etch, temper etch, penetrant testing,
magnetic particle inspection, eddy current testing, and Barkhausen
Noise effect inspection.

NA applies where testing is not performed or qualified sources are not


required.