While auditing top managment, I asked how he ensured effective communication throughout the company. He responded with there is a chain of command that is implemented and communication is filtered up and filtered down as necessary. He also stated that there is an Open Door Policy that are employees use when necessary. I asked him if I could see a copy of the open door policy and he said I could review in the handbook. I looked in the handbook, and guess what, no open door policy?

As a company, we do have an open door policy, but the only person who has a copy of it is me, the Quality Manager. Our consultant wrote about 12 policies for our company when we began the process of getting ISO certified, however, none of these policies have ever been distributed throughout the organization. Is this a nonconformity??

Any suggestions or feedback would be appreciated!!!

There is no requirement for the organization to document the "open door" policy. The real question in my mind is (since you've determined it's a part of your system) whether its communication has been effective throughout the organization. Are employees aware of the policy? Do they have questions about it that aren't being answered because they don't have access to the document? Does lack of access to the document affect their ability to achieve their process results?

That was what I was trying to get at during the audit, that communication may not be as effective as originally thought. How do I approach this during our meeting to discuss the audit results?

Did your audit determine that it wasn't effectively communicated? Is it having a negative impact?

Did your audit determine that it wasn't effectively communicated? Is it having a negative impact?

that is my question...do you have people who don't know they can talk to the boss? Why have (or how have) you determined that this is a problem? Does this affect your quality management system in some way?

there is certainly no requirement in ISO to have a documented open door policy. Do you say in your quality manual that you will have a written policy explaining an open door policy?

As per How to audit top management processes (http://isotc.iso.org/livelink/livelink/3553985/APG-AuditTopManagement.doc?func=doc.Fetch&nodeid=3553985) from the IAF, it states -

The auditor/audit team should be constantly looking for opportunities to corroborate the answers received from top management when interviewed.

This includes

a) the availability and relevance of policies and objectives

b) the establishment of linkage between the policies and objectives

c) obtaining the evidence that these policies and objectives are effective and understood throughout the organization

d) determining if the policies and objectives are appropriate for continual improvement of the quality management system and for the achievement of customer satisfaction.

e) determining if top management are involved in management reviews.

Thus if any of the (a) - (e) not in place would be a non conformity.

Well, I think the audit determined that there is not effective communication when it comes to our policies and procedures in general, this one specifically. However, I'm not sure of how much of a negative impact it is though.

Well, I think the audit determined that there is not effective communication when it comes to our policies and procedures in general, this one specifically. However, I'm not sure of how much of a negative impact it is though.

As an Internal Auditor, it is your responsibility to identify issues that may have been uncovered during the Audit. I would document this as either a Minor NC or OFI. This may lead to an NC by the Registrar later under effective communication. Just my opinion.

That was what I was trying to get at during the audit, that communication may not be as effective as originally thought. How do I approach this during our meeting to discuss the audit results?

You could refer the link that I have in my previous post -it says it all :)

As an Internal Auditor, it is your responsibility to identify issues that may have been uncovered during the Audit. I would document this as either a Minor NC or OFI. This may lead to an NC by the Registrar later under effective communication. Just my opinion.

Based on what I've read so far, I'd say an OFI at most. Are you talking about ISO 9001 clause 5.5.3? It requires "appropriate" communication processes and communication regarding the effectiveness of the QMS. I don't see a basis for a nonconformity there unless it's been determined that it's detrimental to the system.

As per How to audit top management processes (http://isotc.iso.org/livelink/livelink/3553985/APG-AuditTopManagement.doc?func=doc.Fetch&nodeid=3553985) from the IAF, it states -

The auditor/audit team should be constantly looking for opportunities to corroborate the answers received from top management when interviewed.

This includes

a) the availability and relevance of policies and objectives

b) the establishment of linkage between the policies and objectives

c) obtaining the evidence that these policies and objectives are effective and understood throughout the organization

d) determining if the policies and objectives are appropriate for continual improvement of the quality management system and for the achievement of customer satisfaction.

e) determining if top management are involved in management reviews.

Thus if any of the (a) - (e) not in place would be a non conformity.

Although there's a lot of good guidance information in the document you referenced, a guidance document (not endorsed by ISO or IAF) published by a working group is never the basis for a nonconformity.

Thanks for everyone's responses! They were all a lot of help!

I have to ask the question, what are you trying to achieve by raising this as an N/C? Is it because you think you can or because you think that in doing so will result in a corrective action which will cause improvement.

I must say that I find it quite tedious when auditors want to flex their muscles and raise N/C's against section 5 of ISO 9001 because they think it is a clever thing to do.

In my opinion, clause 5.5.3 is far too 'open ended' and gets used as the home for all lost N/C's - i.e. where auditors are too lazy to find the real reason for a problem and instead they opt for the easy option.

Normally it is easy to verify whether communications has been effective. You can randomly ask a number of people and ask whether they know the quality policy, relevant procedures and quality targets.

If not, your could raise a NC based on either 5.3d or 5.1a.

I would do this if there is objective evidence that the quality system is not effective due to the fact that is has not been communicated.

While auditing top managment, I asked how he ensured effective communication throughout the company. He responded with there is a chain of command that is implemented and communication is filtered up and filtered down as necessary. He also stated that there is an Open Door Policy that are employees use when necessary. I asked him if I could see a copy of the open door policy and he said I could review in the handbook. I looked in the handbook, and guess what, no open door policy?

As a company, we do have an open door policy, but the only person who has a copy of it is me, the Quality Manager. Our consultant wrote about 12 policies for our company when we began the process of getting ISO certified, however, none of these policies have ever been distributed throughout the organization. Is this a nonconformity??

Any suggestions or feedback would be appreciated!!!

May I ask what 'other' policies your consultant wrote? 12? This might be the root of the problem. Someone else wrote them and missed the point!

Having an 'open door' policy has nothing to do, IMHO, with effective communication regarding the quality system. Often, businesses use a balanced score card or similar methods posted around the building about how the processes are performing. An open door policy is, to me, a 'feely, touchy' deal and can't replace the use of data, trends, customer feedback and other information compared to objectives, about how the business is doing.

Yes. It violates Cl 5.5.3 Internal Communication.
Raffy:cool:

It would be nice to see evidence of what the "communication process" is - inputs, outputs, etc. Then, follow a few examples of the process from beginning to end. Audit the intended audience to see if the communication was effective. :cool:

Open door policy is not communication. It is ventilation.:rolleyes: Just venting....is all it is.

I think the 'evidence' that communication isn't effective is very thin, to say the least. I'd be less than impressed by an auditor who jumped to that conclusion on such a slender basis.

I've rarely if ever seen an 'open door' policy written down - and would question the need to do so. More importantly, is there any real evidence that such a 'policy' (more like culture/habit I think) is widely known? Or any real evidence that what the manager says isn't so? I'd tread very carefully and seriously want good grounds before drawing such a conclusion.
But just asking a single manager, then going & looking for a written policy, not finding it and proposing to raise a NC on that? Nope. Very superficial auditing and likely to backfire.

I have to ask the question, what are you trying to achieve by raising this as an N/C? Is it because you think you can or because you think that in doing so will result in a corrective action which will cause improvement.

Mine is here: I guess, this is one good example of “statement of fact” scenario, where accordingly, you can use your top management declaration about the open policy that was not effectively implemented….

…from my pov, you can raise an NCR for this… it is not a specific ISO requirements but the mere fact that it was declared by your top management as one of your strategy for effective communication (that is apparently to comply with ISO 9001 clause 5.5.3 requirement) which is not effectively being implemented…

I think the 'evidence' that communication isn't effective is very thin, to say the least. I'd be less than impressed by an auditor who jumped to that conclusion on such a slender basis.


I agree. I would expect to see objective evidence that the "process" they claimed was ineffective - such as responses by the shop floor personnel that they really have no idea what is going on with the direction of the company. If the claimed "process" is ineffective (and it sounds like it would be, but show me the facts that prove it), then use that as audit nonconformity objective evidence.

Had the management said they really did not have a system, then you could drop an NC without further evidence. But, they really did not say that. They said they had a system. You might ponder if anything that illustrated their process was identified in the quality manual, and see if that matches their response.

It is not up to the auditor to show opinion of ineffectiveness, it is up to the auditor to show objective evidence of ineffectiveness.