Consultant as Management Representative - and the 40 Day Wonder Implementation!

[Marc]

I was reading in a news group - misc.industry.quality - and found the following message dated 6 January 2000:

- --> Subject: Free ISO 9000 Gap Analysis Audits for Florida
--> businesses:...
--> We are offering free one or two-day ISO 9000 Gap Analysis audits for
--> Florida businesses interested in pursuing ISO 9000 registration.
--> There are no strings attached, no hidden charges and no contracts
--> required. Full audit report is sent free as well. Not all industries
--> and locations are eligible. References from other free audit
--> recipients available for your review!
--> for more details, and to see our travel limits.

I went to the web site and found this on their Rapid ISO 9000 Implementation page:

--> OQR's "Rapid ISO 9000 Implementation Program"
-->
--> And, for your company's first registration audit --- always the most
--> difficult! --- OQR will represent the Quality System to the
--> registrar of your choice, acting as temporary "Management Rep" for
--> the audit.

My comment was I have not run into a registrar which would let me serve as Management Rep during the audit. However, back when I started doing this in 1993 that was not allowed and I have not since even considered trying to use what I consider a questionable approach. Has anyone else seen this approach used?

I must admit I also find their "40 day" implementation claim as quite optimistic for 99% of the companies out there. I would think this not possible on the basis of the requirement for some historical evidence of systems performance (including a round of internal audits) unless the company was essentially compliant to begin with (in which case a month and a week. From their web site:

--> If your company is on the "fast track" to ISO 9000, check to see if
--> you may be a candidate for OQR's proprietary --- and proven! ---
--> "Rapid Implementation Program," which may be able to get your system
--> ready for registration in as little as 40 days.

OK folks, what say you?

[This message has been edited by Marc Smith (edited 07 January 2000).]

[barb butrym]

If the consultant has a contract, and that contract has him employed as perhaps...say...the quality manager, even though a contract employee...that consultant may indeed act as the management rep. Not just for the audit.....but for the implementation period.....plus a bit...or even indefinitely...

been there...done that.....from both sides... registrars don't seem bothered as long as there is a contract clearly giving the contract MR the responsibility and authority that goes with the job

[This message has been edited by barb butrym (edited 07 January 2000).]

Although I know consultants who are management reps., I'm glad I don't have to audit them cause I think I'd have an issue with it. I think (I don't have my ISO book in front of me) somewhere in ISO 4.1.2.3 it says something about the management rep being appointed by the supplier's management and be a member of the supplier's own management.

Of course I think there are exceptions (2 person company, clearly defined contract, etc..), but for the majority of companies I would have to say there was an issue.

[Laura M]

I would have a bigger issue with the stated approach that they will handle the MR job "temporarily"...for the initial assessment. I just envision a group of consultants being the only folks the registrar talks too....the info quoted from the website doesn't give me the "warm-fuzzy" that the company will be left with the ability to sustain their status. Maybe there is a registrar out there that has audited one of their companies that can respond?

On the consultant/contract management rep...I think that's exactly how smaller companies need to handle things. Many don't have the need for a full time quality person.

I know this approach keeps me busy.

[Marc]

From: misc.industry.quality

The key here is that this is intensive, on-site, full-time consulting up to and including the registration audit. Note that this approach is harder to pull off for consultants who only show up a day a week, or less, or who simply give the occasional seminar to management. Nothing in the ISO standard nor RAB requirements prohibits a company from utilizing a temporary employee as a member of its management (or in any other capacity) so long as the employee is authorized [4.1]my company acts as a temporary Management Rep for its clients (if need be--- this is more common for small companies.) This approach has been accepted by a number of major registrars, including SGS, NSF, and U/L, and used since 1988. Registrars DO however like to see that a permanent member of the staff is "in training" for future surveillance audits, but again one could challenge them on it. This we document at the opening meeting attendance sheet, where the future "permanent" ISO rep signs in as such.

The language of the standard is indeed specific about a "member of the supplier's management" acting as rep, but it does not say anything about the hourly requirements or employee status of ANY individual within an organization. For example, if a supplier's Quality Manual references a "QA Manager," in no way does ISO care if that QA Manager works 40 hours a week or merely 12, so long as the person is empowered by top executive management, that the empowerment is documented, and that the person is trained. The ISO standard neither intrudes on the client-consultant relationship, and speaks plenty on "subcontractors." OQR --- in effect a subcontracted, temporary Manager --- therefore requires in its contracts that the OQR agent be empowered as either ISO 9000 Administrator or Co-Administrator (if another employee is available to fill the role already). The contract may then be provided to a registrar if required (although none of the aforementioned --> registrars have ever asked to see one.) OQR also requires it be included on the client's Approved Vendor List (or equivalent.)

By the way, in one particularly difficult situation we had to deal with, the QA Manager (and ISO Rep) quit two days before the registration audit. We had no time to reschedule, and had to take our lumps. However, the registrar (International Management Systems) was flexible with us on this obviously troublesome arrangement, and allowed us to sign in an ISO-knowledgeable Engineering Manager as "Acting ISO 9000 Administrator." Of course, at the six-month surveillance audit he expected to see a permanent staff member fill the role (and he did.)

Likewise, I have spoken to a new registrar and discovered that they in fact hired a consultant to help setup the registration company to meet all the RAB requirements, and the RAB had no problem with it, and accredited the registrar. I suspect if ISO had a problem with this arrangement, it would have showed up at that level!

> By the way, I would hope that a company's 'first registration audit' is
> their LAST registration audit.

Not completely true. Most registrars operate with one of two contracts: an open contract with an initial registration audit followed by ongoing bi-annual surveillance audits, in perpetuity; or a closed-end contract (usually three to five years) where following the initial registration audit there are annual surveillance audits until the contract ends. At that point, their ISO certification ends as well, unless a new contract is signed, and the client must undergo a full "initial registration audit" once again. In both cases, a client may (of course) at any time cancel or expire a contract and sign a new one with a different registrar. Clients weigh the pros and cons of both methods, although I prefer the former one as the costs for the client are generally lower.

[barb butrym]

Originally posted by Christian Lupo:
Although I know consultants who are management reps., I'm glad I don't have to audit them cause I think I'd have an issue with it.

It goes with out saying, some consultants can be idiots...and should not attempt this. It takes one who can be humble.....and professional. I have had the compliment paid at a closing meeting, that the auditor, at first was uneasy with the arrangement, and was reluctant, however once we started he saw a side of consultants that was rare...and he went on to say he found the audit a pleasant experience.....hmmm muct have been my charm...LOL

---Edited to correct html.



[This message has been edited by Marc Smith (edited 28 August 2000).]

I guess that what makes this job so interesting, ya have to take each companies situation on an individual basis.

[Marc]

From: Jim Stewart
Organization: Northern Illinois University
Newsgroups: misc.industry.quality
Date: Wednesday, January 12, 2000 3:20 PM
Subject: Re: Free ISO 9000 Gap Analysis Audits for Florida businesses

In following this thread--which I was not going to respond to because my answer will sound like a "me too" - I can verify that a small company can start from scratch in a relatively (surprising) short time. In 1994, I authored with Peter Mauch and Frank Straka "The 90 day ISO mauual" St Lucie Press ISBN 1-884015-11-5. It includes a short manual and the a proceedire/forms system of compliance. Since each of my coathors has long experience on TAG176, we have never had a major problem with the system meeting compliance. We picked 90 because nobody would believe forty then. A lot of the successful case studies came through Peter's dealings with TMI here in Illinois.

The major difficulty in documentation is that we START with having the documented management quality meetings from the first gap analysis and begin the documented internal audit process before trying to get any procedures. I also think that we expect the company to assume more responsibility than you do, Mr Paris. As to your claim of 40 days, I have absolutely no doubt that it can be met.

Jim Stewart, PhD
Northern Illinois University

[This message has been edited by Marc Smith (edited 12 January 2000).]