Purely hypothetical question, completely unrelated to any recent audit activity and based on the premise that a good offense is the best defense, proactively speaking.
In Reply to Parent Post by ISO/TS 16949:2002 Section 6.4.1 Personnel safety to achieve product quality
Product safety and means to minimize potential risks to employees shall be addressed by the organization, especially in the design and development process and in manufacturing process activities
Our products convert DC power to AC power, primarily 120 Volt AC 60Hz outputs. Wherever possible, these products are UL listed. For example, we have a primary product that is UL listed but our TS customer requires a length of DC input cable that precludes a UL listing. On the personnel side, our associates are required to wear safety glasses, we are continuously upgrading equipment and designs to avoid repetitive stress injuries, we have a contract with a firm that provides auditing and training against OSHA regulations and guarantees our compliance, and we have all of the required records for OSHA. I would say that all of the preceding items add up to addressing
In Reply to Parent Post by IATF Guidance to ISO/TS 16949:2002 Section 6.4.1
Implementation examples may include:
defined responsibilities for safety
error proofing as a preventive activity in design and process control
knowledge and application of regulations
learning from internal/external audits and corrective actions
records of accidents
risk analysis such as FMEA
use of protective equipment
While our record is not perfect, we do not have a pervasive or costly injury record.
So, if an ISO registrar's auditor, who just happened to have an extensive training background in OSHA safety, was to point out that we do not have specific records for (hypothetical example) training on the proper usage of sharp and pointy objects, as required by Federal Regulations:
1) Does this rise to the level of quality system finding?
2) What if we have specifically asked our compliance firm about sharp and pointy object training and they believe that we are covered?
3) What if we have records of required OSHA training that do not specifically list sharp and pointy object training?
Or, is this what you can expect when your system is darn near perfect and, in spite of Deming's warnings about management by numbers, auditors start to get fidgety when they cannot write a certain number of findings per audit-hour?