Section 5 of the EELQMS requires companies intending to market, develop or manufacture engine lubricants for which compliance with ACEA Oil Sequences will be claimed, to keep records that enable independent assessment of their relevant processes by internal and/or external auditors. The auditors should report their findings to the relevant company management.
Record keeping
Sufficient records should be kept to enable proper monitoring, measurement, analysis and evaluation of practices and procedures including, but not limited to:
- Lubricant marketers: details of final performance data sets that demonstrate that the relevant requirements of the claimed ACEA Sequences have been met in full.
- Lubricant developers: full details of development programmes including all programme extensions to obtain the final formulation
- Lubricant manufacturers: full details of manufactured batches including formulation composition, components batches and control analysis results that demonstrate that the manufactured lubricant formulation matches that finalised by the lubricant developer.
These records should be complete enough to demonstrate that all development work was done in compliance with the requirements of the EELQMS. They should also conform to any of the detailed auditing requirements of relevant Codes of Practice referenced within the EELQMS including:
- ATIEL Code of Practice (Section 10)
- ATC Code of Practice (Section C)
- ACC Code of Practice (Appendix J)
Auditing
Compliance with EELQMS requires that records be made available for periodic internal/external audit.
Internal audits should be independent of the entity being audited and should be thorough, including, for example, a complete “vertical” audit through a lubricant development project from design to final performance data set, or a complete “horizontal” audit, through development, marketing claims, and manufacturing procedures.
In addition to internal audit, management may commission an external audit by an independent company or entity with sufficient expertise in either the lubricants industry or in quality assurance systems.
Management review
Management should review the results of all internal and external audits and, where non-conformity is identified, determine the corrective action required.
Continual improvement
The EELQMS, and any procedures from entities participating in the system, may be updated when required in order to continue to meet the requirements of the ACEA Sequences in the most effective manner. Lubricant companies should ensure they are always following the latest version of the EELQMS guidelines which will always be available on the EELQMS website.