Are Registrars Suppliers?

[Marc]

From: ISO Standards Discussion
Date: Wed, 31 May 2000 11:39:43 -0500
Subject: Re: Is a Registrar to be Treated as a Supplier /Naish/Humphries

From: "Edwin Humphries"

Phyllis,

> In a recent audit discussion with an auditor, the question of the registrar
> as a supplier came up. It is my belief the registrar is just another
> service provider like any you might have such as a calibration supplier or
> carrier service.
>
> By that I mean you should do the same type of qualification as you might
> with a service provider. Meaning what ever you might do for a service
> provider. One auditor felt that because they were approved by the
> registration board you did not need to do anything and the other felt you
> should qualify them as well. Any thoughts on this?

I have for a long time promoted this course to my clients: the only problem is that against any reasonable set of "subcontract requirements" (i.e., customer and market requirements), most certifiers/registrars would fail. It also begs the question of what type of control the client can exercise over the certifier/registrar: incoming inspection? SQA? On site inspection?

> In the same discussion, we discussed the timing of the audits. By this I
> mean what time during the day the audit should begin. My client has most of
> their day shift employees starting at between 5 and 6 in the morning so
> they leave between 2:30 and 4:00 in the afternoon. When we requested an
> earlier start time, one of the auditors indicated he doesn't start before 9
> in the morning. So we had to have people stay late making for long days for
> the staff. They did not object but I did.
>
> If the registrar is a supplier doesn't that mean they should be meeting
> your criteria? I have seen this with a couple of other registrars as well.
> And have even seen them show up late at that. Am I the only one who thinks
> the auditors should be available at the time the company staff is there
> normally?

Absolutely not: I have seen auditors abuse their power in all sorts of ways, and this is a common one. Where companies ask their consultants to assist them during the audit period (an increasingly common, though somewhat problematic course), this means the company has to pay the consultant to cool their heels while the auditors wend their way to the audit.

I am now encouraging my clients to write a contract with their certifier, and to determine the clauses of the contract themselves - or to modify the contract proposed by the certifier. I believe that such a contract would include the manner in which audits are conducted, communication paths between certifier and client, the manner of reporting, to method of establishment of audit dates, the right to refuse auditor selection, time and duration of audits, etc. The contract should have teeth: financial penalties in the event of breach of contract, and the right for the client to refuse to pay for incompetent audits or for some of the common cost- adding audit practices: auditing areas not covered by the defined scope of the certification, audits focusing on issues not addressed by ISO9000, time spent on auditing to an interpretation of the Standard rather than its intent, etc.

Certifiers need to remember who is the customer, and to meet their stated needs and expectations; but then, that would be expecting them to practice what they preach.

> The client did have 2 other shifts but the people who did things like
> calibration and safety training, and key functions worked the day shift.
> They did audit some of the second shift production staff in this audit so
> at least they hit more than one shift.

It would, in fact, be reasonable to expect a responsible auditor to ENSURE they audit other shifts than the day shift; but maybe I'm being unreasonable! ;-o

Best Regards
Edwin Humphries

[Marc]

From: ISO Standards Discussion
Date: Wed, 31 May 2000 11:43:02 -0500
Subject: Re: Is a Registrar to be Treated as a Supplier /Naish/Kozenko

From: Write9000

> First -
> In a recent audit discussion with an auditor, the question of the registrar
> as a supplier came up. It is my belief the registrar is just another service
> provider like any you might have such as a calibration supplier or carrier
> service.

I'm with you 100% on this one; any firm you pay money to for a service is a "supplier."

> Second -
> In the same discussion, we discussed the timing of the audits. By this I mean
> what time during the day the audit should begin. My client has most of their
> day shift employees starting at between 5 and 6 in the morning so they leave
> between 2:30 and 4:00 in the afternoon. When we requested an earlier start
> time, one of the auditors indicated he doesn't start before 9 in the morning.

Ordinarily I'd agree with you here, too, but the reality is: Registrar auditors are a rare breed of "suitcase enabled" traveling salesmen/women types. In my brief sojourn down this quality path I've made many a good friend who is such, and the travel schedule simply makes them a little nuts. (When they're "on the road... ;o) "

If you shop around, there are Registrars who could easily accommodate your reasonable request to start at 6 a.m. (and in fact, many would prefer to, because of the "good timing" aspects of honoring your request); but...

If auditors were baseball players, then in spite of how good they played ball, some of them would also scratch, or spit in the dirt. Or, both. The key would be to watch really closely to see if you could tell why they were in the Major League (that is, Professionals).

If you really thought that "not starting before 9 a.m." was similar to a ball player's anti-social itching, then after that auditor failed to meet you half-way, did s/he make up for it with work product? Or foul out?

David M. Kozenko

[Marc]

From: ISO Standards Discussion
Date: Wed, 31 May 2000 11:47:59 -0500
Subject: Re: Is a Registrar to be Treated as a Supplier /Naish/Scalies

From: "Charley Scalies"

> One auditor felt that because they were approved by the registration board
> you did not need to do anything and the other felt you should qualify them as
> well. Any thoughts on this?

A registrar is a supplier, just like every other. The decision of what constitutes criteria of acceptability is yours alone. If you decide to use their accreditation alone, fine. If you want more...that's fine too. (I suggest you at least speak with one or two of their other clients before making a decision.)

> Second -
> In the same discussion, we discussed the timing of the audits. By this I mean
> what time during the day the audit should begin. My client has most of their
> day shift employees starting at between 5 and 6 in the morning so they leave
> between 2:30 and 4:00 in the afternoon. When we requested an earlier start
> time, one of the auditors indicated he doesn't start before 9 in the morning.

You are the customer! Act like it.

Charley Scalies

[Marc]

From: ISO Standards Discussion
Date: Thu, 1 Jun 2000 11:37:17 -0500
Subject: Re: Is A Registrar ... A Supplier/../Ganor/Arbuckle

From: Don Arbuckle

I have to disagree with you here. They are in fact a supplier (of assessment and registration services) and many that I have interfaced with, expect that relationship. Some, in fact, expect to see their name on the AVL (if that is the process in place at the site) and expect to have gone through the evaluation process. This is one of the frequent checks to see that "service" providers are evaluated as are the material providers.

Not withstanding that concept, I agree with the others who have indicated that the registrar is a service provider and therefore should be treated as a supplier. I have yet to find a registrar who does not audit on the various shifts to ensure that the system is effectively implemented throughout the organization, at all levels. I don't know how a registrar can ensure this if they only audit between the hours of 9:00am and 5:00pm. Any one who has worked in a shop that has different shifts knows that there is a possibility of each shift being run differently (and occasionally **VERY** differently!) I am intrigued by the prospect of auditing only one shift and having confidence that all other shift operate properly...

BTW - as far as the registrar auditing the way we [client] audit... I don't think a reputable registrar would audit the way the client audits, unless the client is auditing according to the same requirements as the registrar. In other words, registrars have a set of requirements that govern their audit process [ISO10011 series et.al.]. That better be the way they audit! When you contract with them to provide their service, you should be specifying the type, precise identification, applicable issues of.... process requirements, the title, number and issue of the quality system standard to be applied. All of that is part of the ISO requirements you are asking them to verify (4.6.3) If you have not specified to that extent, are you really compliant with that element of the standard?

Don Arbuckle

> From: "Ganor, Eitan"

> <snip> NO,
> If a registrar is treated as a supplier, we will have a catch:
>We will audit the way he audits us,
>He will audit the way we audit him.

>As to the second question, a registrar works on standard business hours.
>He can not be flexible to irregular hours.

[Marc]

From: ISO Standards Discussion
Date: Thu, 1 Jun 2000 11:45:11 -0500
Subject: Re: Irregular Hours/../Van Putten

From: Dirk Van Putten

I thought there was a new requirement for registrars to audit on the all shifts where an activity takes place? How can an auditor accurately evaluate an activity if the registrar only audits the activity during "regular" hours? To cascade this, can an activity be audited at one site and then assume the same activity takes place at another site?

We require our third party registrars to audit the "irregular" shifts. If the shifts that work the irregular hours prepare for an audit/implement a quality system, but they never are audited, their feeling of being included is lost.

If our registrar told us that he/she would not audit during irregular hours, we would treat the auditor just like a supplier that could not supply a product when we wanted it. We would terminate the contract and get a new supplier. We cover this agreement during the contract review. It is up to the auditor and their employer (the registrar) to determine how they are going to organize their activities around our needs. If the registrar schedules an auditor to audit every day and they cannot meet our needs of auditing during irregular hours, then we will find a registrar that is willing to supply us with what we require.

I never realized that the world of registrars was so regular and non-flexible.

Dirk van Putten

Of course registrars are supliers! Is it value added to add them to your supplier list? NO. Will you ever get a finding that they are not so listed? NO!

Stick to stuff that improves service to your customers. Building files on your auditors does not!

Dave

[Marc]

I was 'passing through and came across this 'early' discussion. Thought I'd bubble it up for any contemporary comment. A lot of good thoughts here!

Also see this thread: Are Registrars Suppliers