1.0 Purpose: 2.

0 Scope:

The purpose of this Procedure is to establish a documented process to implement and perform Layered Process Audit at ArvinMeritor LVS Plants. 1. Responsibility: The Site Manager is responsible for the implementation of this procedure at the plant. The Operations Production Manager is responsible for the e!ecution of this procedure. The "uality Manager is responsible for the support in the e!ecution of this procedure. 2. Definitions: Layered Process Audits: #t is a "uality #mprovement system involving multiple layers of management$ chec%ing the high&ris% items in the process. #t is an ongoing system of process chec%s that verifies if proper methods$ settings$ tools$ gages$ operator craftsmanship$ error proofing devices and other important inputs are in place and being follo'ed in order to assure product (uality. LPA Auditor: )mployee trained in the LPA concepts and in the application of the *hec% List. #n this 'ay everyone is an auditor for Layered Process Audits and do not need "uality Management System auditor training$ since they are not "uality Management System auditors. 3. Scope: The scope of a Layered Audit Process is limited to the identified processes and process steps re(uiring special attention due to their criticality to customer satisfaction$ rather than being a broad chec% of process compliance. +ot %eeping LPA,s to their original intent by$ for e!ample$ broadening them to include all processes or not updating their (uestion sets$ 'ould li%ely reduce the benefits of the Audits and discourage their use.

3.0 Instruction: LPA must be implemented 'here they 'ill be more effective and can be developed to be operation specific$ process specific$ department specific$ product line specific$ etc. )ach plant must define for 'hich processes and product line they 'ill implement the LPA$ based on critical items$ customer issues$ internal metrics$ system process audit results and customer re(uirements. #n order to be implemented 'ith focus and be successful$ it should be firstly implemented at a pilot area process - higher ris% or ne' line 'ith critical process - to create the culture at leadership level and evaluate the procedure chec% sheet and ma%e any correction before implementing at other areas or processes. Audit Items: A cross&functional team - minimum 'ith "uality$ Manufacturing )ngineering and Production & must be formed 'ithin the plant to develop the list of items for the Layered Process audit. The Audits must include 'hatever the plant believes is critical to product (uality and are typically those that are high ris% to customer satisfaction. Processes$ procedures and other aspects of the operation that are critical to ensure product (uality are items that should be considered and also the team must consider the status and importance of the related process - Safety or *ritical. To be most effective$ LPA,s must be relative short in duration$ typically bet'een 1. to /0 minutes depending upon line si1e comple!ity and therefore should include items that can be verified (uic%ly. All (uestions in the *hec%list must re(uire only a yes or no as an ans'er$ in order to avoid confusions and ma%e it simple and faster. The Layered Process Audit *hec% Sheet should contain specific items as listed belo' to be audited as minimum2 )rror proofing or error detection e(uipment Process machine parameters Set up result records - 3irst piece Product identification & *ontrol of non conforming parts 4ages and measuring e(uipment calibration Safety Procedures 5ocumentation related to high&ris% items - 6or%ing instructions$ *ontrol plan$ records$ etc. *orrective actions from past (uality issues 7if applicable8 9e'or% procedure 7if applicable8 "ualification of #nspectors and 6elders 7if applicable8 Tor(ue monitoring 7if applicable8 Other items that could be included on the Layered Process Audit *hec% Sheet are2 Visual Aids Stac%ing pac%ing re(uirements Preventive maintenance :ouse%eeping Part feature inspection Traceability )nvironmental re(uirements Metrics update Tooling control See attachment 1 for an e!ample of a LPA *hec% List.

Audit Layers and re!uency: LPA gets its name from the re(uirement that multiple layers of the organi1ation conduct the same audit. LPA places these people ;'here the 'or% is being done< to verify critical items. This facilitates communication bet'een management and 'or%ing level team members and also demonstrates to all team members that these critical items are very important$ because all levels in the plant are verifying that they are being done properly. The follo'ing levels and fre(uency are re(uired in order to ma%e LPA,s effective2 Le"el 12 The Line or *ell Team Leader 'ill perform an audit every shift to assure that the high&ris% items are in conformance 'ith the specifications or documented process. Le"el 22 The Area Supervisor 'ill perform an audit on a daily basis to assure the high&ris% items are under control and being verified every shift$ completing also the items assigned to his level. Le"el 32 The Area Manager 'ill perform an audit on a 'ee%ly basis to assure the high&ris% items are under control$ being verified by the previous levels and complete the items assigned to his level. Le"el #2 The Site Manager 'ill perform an audit on a monthly basis to assure all items are being verified by the previous levels and complete all items in the *hec%list. $%ecuti"e Le"el2 The Operations and "uality 5irector - or other business e!ecutives & responsible for the plant$ 'ill perform a revie' during plant visits to verify compliance to LPA re(uirements. See section =. #n case of smaller plants 'here the Operations structure is not as defined above$ other available technical personnel - "uality #nspector and "uality Manufacturing )ngineers & may be used to substitute the Team Leader or Area Supervisor. The number of levels may be reduced to / only in case the plant 'or%s in only one shift or does not have the complete structure and technical personnel as defined above. A schedule for levels >$ / and ? must be prepared and communicated by the "uality area in order to define 'hich cell line 'ill be audited by each auditor. The responsibility for e!ecuting the LPA cannot be delegated by the auditor@ therefore any conflict in the schedule must be agreed 'ith the "uality area at the beginning of the month. See attachment > for an e!ample of a LPA Schedule sho'ing Audit Areas$ Audit Layers and Audit 3re(uency.

Audit &on'conformance Reaction Plan: The area leader supervisor is responsible to solve any non&conformance detected during the LPA. +on&conformances detected during audits must be fi!ed immediately$ or an action plan must be developed 'ith responsible and timing clearly defined in order to be verified by the area manager at least once per 'ee%. 3or each item in the *hec%list it is necessary to have a documented reaction plan in case the item is not in conformance. All non&conformances must be addressed using the appropriate defined reaction plan and documented by the auditor in an attachment of LPA *hec%list. #t must be clearly stated in the reaction plan 'hen the non&conformance detected re(uires stopping the line cell in order to solve it before resuming production. The reaction plan may include a validated method for 100A containment of the identified non&conformance on parts already produced$ in order to avoid any suspect part going into ne!t steps of process or to the customer. Audit ()ners*ip: Operations Manager of the areas 'here the audits are conducted must o'n LPA. The "uality area and other functions must participate and support the Layered Process Audits System to be effective. Operations manager must ensure the follo'ing2 Layered Process Audits are conducted on time and according schedule@ Layered Process Audits are conducted by the designated team members@ The results are recorded and revie'ed regularly@ 9esources are available and focused on corrective actions for the non& conformances identified. +onductin, Layered Process Audits: Once the *hec%list 'ith the audit items$ non&conforming reaction plans$ audit layers and fre(uency has been determined$ the trained auditors can begin conducting the LPA,s. The most significant part of the audit process is ensuring that the audits are performed to schedule and that the results of the audits are recorded. #t is imperative that site management instills discipline early in the process to complete the audits according to schedule$ sho'ing commitment to the LPA process. The results of all LPA,s must be 'ell recorded and maintained. The non&conformances detected must be vie'ed as an opportunity for improvement and the auditor must follo' the documented reaction plan to assure that containment 'as implemented if necessary and record the actions on the *hec%list attachment. The auditor must advise the area supervisor before starting the audit and e!plain all non& conformances detected$ specially the ones that cannot be fi!ed immediately$ re(uiring an action that 'ill be follo'ed up by the leader. The plant should use the established corrective action procedure to resolve$ document and report to management any systemic non&conformances detected during the LPA,s.

Re"ie)in, LPA Results: A designated person in Operations should be responsible for summari1ing 'ee%ly the LPA results and report them to Operations Management and to "uality area$ 'ho 'ill be responsible for revie'ing the non&conformances in such a 'ay that systemic issues reoccurrences and trends &'ithin the areas can be identified and corrected across the entire plant and at other facilities. Operations Manager and Site Manager should conduct scheduled revie's of LPA results in order to sho' management commitment to the audits and to have an opportunity to monitor the impact of the Audits on the plant,s metrics. These revie's should be performed during the monthly PO9 & Plant Operations 9evie'. The area must have a chart to summari1e the Planned vs. Actual LPA,s performed during the month and to summari1e the Percent of Audited #tems in *ompliance. This chart must be displayed on the area metrics information board to be used on the team meetings and the consolidated information must be displayed on the plant 'ide metrics information board -aintainin, Layered Process Audits: The items in the LPA *hec%list must be revie'ed regularly by the plant area teams$ to ensure that it continues to include those items that are critical to (uality. #tems can be added to or changed in a LPA in situations such as the follo'ing2 +e' customer re(uirements@ +e' or modified procedures in the plant that are critical to product (uality@ *orrective actions to address e!perienced (uality issues@ *ritical to (uality items that must be communicated to all sta%eholders@ +e' process setup re(uirements@ Verification of corrective actions ta%en in response to previous LPA findings. #tems can be deleted from a LPA in situations such as the follo'ing2 Automated e(uipment replaces a previously manual&dependent operation@ )rror Proofing is added to an operation. *areful analysis must be made before an item is deleted from a LPA$ because even if automated e(uipment replaces a manual operation$ it may be necessary to add items related to the ne' e(uipment in the *hec%list. *ustomer specific re(uirements should be referenced and the customer contacted before deleting any item from the *hec%list. Any change on the LPA *hec%list must have the approval of "uality and Operations areas. Auditin, +ompliance to Layered Process Audit Re!uirements: The Operations 5irector or the "uality 5irector responsible for the plant 'ill perform a revie' during plant visits to assure that the LPA System implemented in the plant meets all the re(uirements from this procedure and customer re(uirements. This verification is not focused on the *hec%list items that an audit is to verify$ but to verify that the plant,s Layered Audit System 'as effectively implemented and is used to drive (uality improvement overall. See attachment / for an e!ample of Auditing *ompliance to LPA 9e(uirements. Reference: LPA Process 75*B8 "SC 9e(uirements 74M8 *"#&D Layered Process Audits 4uideline 7A#A48 See flo'chart

#.0 Procedure .istory: Re" Le"el Prepared Cy2 Approval2

Date

Re"ision +*an,e 10&0D&0= 5ate 10&0D&0= 5ate

Edson Yamashita Director, Quality, Latin America Stefan Land Vice President, Quality, LVS