QCA Frequently Asked Questions

Best practices are, by their nature, voluntary. When an industry best practice gains momentum, frequently the government or the market will adopt those best practices as standards. Examples of industry-based standards that have gained acceptance in law and the market include:

• ASTM F-963 Originally defined by the Toy Industry of America, this standard is now embodied in U.S. law as a component of the Consumer Product Safety Improvement Act of 2008.
• FLA Labor Standards An outgrowth from a White House-sponsored initiative, the Apparel Industry Partnership (AIP) is a roundtable comprised of a handful of large apparel labels, non-governmental organizations and college students addressing concerns for labor rights in a manufacturing setting. QCA benchmarked its social accountability standards and audit processes with FLA in 2015.

An example of a similar board structure would be PhRMA. The PhRMA Code pertains to the design, development and introduction of new drugs to the marketplace and the obligation to educate stakeholders on the role new medicines play in patient care. Consistent with this, a Code revision in 2008 limited promotional items to only those with educational value. QCA’s board, like PhRMA’s, represents the industry’s leading companies which are devoted to advancing the industry and protecting end-users of products.

• The Self-Assessment is a gap analysis of an Applicant Supplier’s manufacturing compliance programs plus an additional module on regulatory compliance specific to their product categories.

• Applicants successfully completing the self-assessment are authorized to schedule validation audits with one of QCA’s two authorized third-party audit providers.
  • Audit Scope
    • All Applicants are required to demonstrate strength in all five areas of compliance – Product Safety, Quality, Social Accountability, Supply Chain Security and Environmental Stewardship.
  • Audit Location(s)
    • Applicant’s North American headquarters
    • Applicant’s supply base
      • Internal supply chain
      • External third party manufacturers
    • Minimum scores
      • A minimum score of 91 in all areas of compliance is required for headquarters.
      • A minimum score of 81 is required in the supply base.

International Standards Organization (ISO)

• Maintains working committees focused on a broad range of standards (i.e. quality management systems, environmental management systems, competencies for labs and auditors, standards for security seals, etc.)
• Consensus standards regularly updated.
• Certification requires renewal by an ISO-authorized organization
• QCA accepts validated current certification for ISO-9001:2015 in lieu of audit for the product safety and quality components of the QCA Compliance Accreditation Program.

World Responsible Apparel Production (WRAP)

• Factory-level certification focused exclusively on social responsibility.
• International Labor Organization-based model for assessing ethical manufacturing practices.
• Alternative WRAP schemes include an annual certification, a bi-annual certification (Gold) and a tri-annual certification (Platinum). Gold and Platinum certifications incorporate self-assessment.
• QCA accepts current validated WRAP Gold certifications in lieu of the social accountability component of the QCA Compliance Accreditation Program.

Fair Labor Association (FLA)

• The FLA is a membership organization with a social accountability compliance assessment program.
• Membership requirements vary:
  • Participating Companies have established compliance programs that adhere to FLA principles and publish audits performed under the auspices of FLA.
  • Participating Suppliers have established compliance programs that adhere to FLA principles and publish audits performed under the auspices of FLA.
  • Collegiate Licensees
    • Category B members have established compliance programs and commit to audit their supply base.
    • Category C members have self-certified established compliance programs adhering to FLA principles
    • Category D members sign the FLA Code of Conduct
  • FLA employs audit assessment tools reflecting the International Labor Organization’s standards for ethical manufacturing practices.
  • QCA does NOT accept FLA accreditation at this time.

Quality Certification Alliance (QCA)

• The Quality Certification Alliance (QCA) is a participation organization based on demonstrated compliance with QCA Pillars of Compliance.
• The QCA Compliance Accreditation Program is a comprehensive program, which covers:
  • product safety
  • product quality
  • supply chain security
  • social accountability and
  • environmental stewardship
• QCA employs a continuous model of gap analysis review, validation and ongoing random monitoring for participant accreditation.
• QCA employs an annual review of the program supplemented by benchmarking with other established programs known for their rigor.
• Bi-annual renewal is required.

For details on the QCA Compliance Accreditation Program auditing standards, click here.

In lieu of audit to a specific QCA Pillar, QCA accept validated current certifications from Suppliers for individual facilities that reflect the same rigorous process we require Applicants to complete. Examples of this include: ISO9001:2008 (3-year certificate), WRAP GOLD (bi-annual certificate), and ICTI CARE (annual certificate).

Suppliers who are certified by US Customs at C-TPAT Tier I, or higher, are eligible to waive the requirements of Supply Chain Security for their entire supply chain.

The QCA Compliance Accreditation Program evaluates a company’s policies, procedures and protocols for their effectiveness in detecting and deterring non-compliance throughout the manufacturing process.

While factories are not accredited or certified under this program, they are audited as an indicator of the effectiveness of the Applicant / Accredited Company’s Compliance Program.

• Applicant / Accredited Supplier’s North American headquarters
• Applicant / Accredited Supplier’s wholly-owned buying offices and auxiliary warehouses.
• Supplier self-selects factories for audit from their current supply base.

• Accredited Supplier submits a current list of supply base factories by product category and volume.
• Factories for audit randomly selected by QCA.
• Factories selected for audit in Year 1 are ineligible.

Individual products are not certified under this program, although the policies, procedures and protocols for assuring continued conformity are evaluated over the course of the self-assessment and third party-audit.

Specifications serve a number of purposes in manufacturing. For the purposes of compliance, specifications:

• Allow a manufacturer or importer to determine whether the product complies with the regulatory standards that may apply to the product in the markets where the item is intended to be distributed.
• Allow a manufacturer or importer to evaluate, given the intended function and other performance requirements, whether there are foreseeable implications for either product safety or quality.

Risk assessments are fundamental to determining whether or not a product meets an Accredited Supplier’s requirements which range from meeting the requirements for the market in which those products are to be distributed to the expectations of their customer to their own internal standards.

All QCA Accredited Suppliers are required to have a testing program. QCA does not dictate a standard set of testing requirements. the company has determined are important to addressing their unique product and needs. Suitability of the adopted testing program to the Accredited Supplier is validated in third-party audits and through random selection of products for mock recall.

QCA Accredited Suppliers maintain testing plans driven by product type, intended market, individual customer’s requirements and any other needs that may arise from “manufacturing change,” a term defined as a change in manufacturer, manufacturing process, design or raw materials.

Per standards published by the CPSC:

“Periodic testing applies to continuing production of a children’s product. If a children’s product initially is certified, and then additional production continues, effective February 8, 2013, periodic testing is required for all the applicable children’s product safety rules, even if there are no material changes. Periodic testing is in addition to material change testing. Periodic testing must be conducted often enough to assure ongoing compliance with the applicable safety rules and no less than 1-, 2-, or 3-year intervals, depending on whether the manufacturer has a periodic testing plan, a production testing plan, or conducts continued testing using an accredited ISO/IEC 17025:2005 laboratory…”

For additional details, click here.

Mock recalls comprehensively test a QCA Accredited Supplier’s compliance processes and are a required element of all accreditations and re-accreditations.

QCA Accredited Suppliers are presented with products randomly selected from their online catalogs and provided with a scenario under which the item is claimed to have failed.

The QCA Accredited Supplier provides documentation regarding the design and development of the product, as well as the risk assessment used in the approval of the product. Any applicable testing and inspection records are also submitted for evaluation. Purchase orders for the placement of the product and sales to customers are also reviewed to determine the potential scope of a recall. Lastly, a corrective action plan may be drafted if shortcomings are identified in the exercise.

The mock recall exercise thoroughly tests an Accredited Supplier’s compliance processes and prepares them for the third-party audits that follow the completion of the exercise.