IMO, You're auditor way over interpreted the standard. What you where doing was fine. Standardized work documents can include posted rules regarding PPE etc. If there are specific safety things related to a particular job you can/should include on the work instructions. Nobody who is sane is going to duplicate their PPE/safety requirements on their work instructions -- imagine if they changed. Thus, as I indicated above the blanket statement to comply with all safety requirements.
IATF 16949:2016 8.5.1.2 - Operator Safety
- Thread starter randomusername
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Mikey324
Quite Involved in Discussions
The standard doesn't state that rules for operator safety shall be noted on the route card. Unless you have it stated somewhere in you system that they have to be on route cards, there is no requirement. I'm not sure how that isn't in accordance with the clause. The clause only says work documents. There is no definition as to what is, or isn't, a work document.
I'm sorry, but health and safety related stuff is by nature work related. One other question, was this the only "finding" from the audit? I would personally take this farther up the chain.
Hi randomusername,
got it.
However, Rout cards could be considered as work instruction. You can mention them in your operative procedures to create a link to show conformity. It could be an OFI, given that the auditor checked that personnel was aware during on the shop interviews , as you reported. This is my thought. Waiting for other expert Covers' comment to suggest .
The requirement is for “standardized work documents“ to include operator safety. That is way more broad than a work instruction and could include many types of documents. Most facilities will have a list of PPE and safety rules — which is a standardized work document. We run thousands of different parts. It’s crazy to think we would need to include those rules on every work order. Any change would require updating thousands of documents.
Mikey324
Quite Involved in Discussions
That would be a document control finding for future audits
Rich Shippy
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Did the registrar auditor cite this at the original certification, or make mention of it? and what are your internal audits indicating about this requirement? Your answer may lie there.
randomusername
Registered
Hi all, apologies for the following lengthy post but I will try and answer everyone.
After reading all the posts and the potential to tie myself in knots when it comes to updating any documents in the future, I think I will go with Golfman25's suggestion and place a simple statement on the route cards referencing the health & safety requirements displayed in your work area are to be followed at all times.
Mikey324 - We received 3 minor n.c's in total. The other two were;
1) Internal auditor competency (7.2.3) - We are a small business and one of our internal auditors with core tools training left, leaving us with just the one fully trained auditor. This auditor is internally training another individual (as per our internal procedure) who will be attending a core tools course at the beginning of the year. As the trainee auditor will be auditing the areas that the trained auditor is responsible for, the n.c. is for auditor impartiality. My interpretation is that this n.c. effectively says that we cannot internally train any auditors regardless of the qualification the person doing the training has, because impartiality could always be claimed and it is difficult to defend.
2) Continual improvement (10.3.1) - RPN is used as the deciding factor for PFMEA improvements which the auditor stated as being contrary to AIAG recommendations. I understand the reasons for not relying on RPN as a deciding factor but argued that the FMEA manual does not state that it cannot be, it only states it is not recommended. I think in reality the n.c. was because we hadn't justified why we hadn't done anything to reduce the RPN, because he attempted to align the fact that we had 3 internal rejects for a specific issue over the year, but the PFMEA had not been reviewed in that time period.
He did try to hit us with a fourth n.c. for our audit timetable as all audits are currently carried out over a 3 year cycle. This is based on the IATF requirement as well as historic internal findings etc. He tried to claim that the standard implied that the 3 year cycle was referencing the certification cycle, but I successfully argued that it doesn't state that in the standard, it simply states a 3 year cycle. He put this to his technical team for guidance who came back and agreed with us. He then moved on to auditor competency and gave the first n.c. above.
Rich Shippy - The n.c. for operator safety has never been picked up in the 7 years I have been with the organisation and we have had 3 different external auditors in that time period. In addition, internal auditor training by another internal auditor that is fully trained (externally) has also always been acceptable to previous auditors and using RPN has never been an issue before. I am not saying that any of the findings aren't justified or in-line with IATF etc., but I would of expected them to have been highlighted over previous audits.
After reading all the posts and the potential to tie myself in knots when it comes to updating any documents in the future, I think I will go with Golfman25's suggestion and place a simple statement on the route cards referencing the health & safety requirements displayed in your work area are to be followed at all times.
Mikey324 - We received 3 minor n.c's in total. The other two were;
1) Internal auditor competency (7.2.3) - We are a small business and one of our internal auditors with core tools training left, leaving us with just the one fully trained auditor. This auditor is internally training another individual (as per our internal procedure) who will be attending a core tools course at the beginning of the year. As the trainee auditor will be auditing the areas that the trained auditor is responsible for, the n.c. is for auditor impartiality. My interpretation is that this n.c. effectively says that we cannot internally train any auditors regardless of the qualification the person doing the training has, because impartiality could always be claimed and it is difficult to defend.
2) Continual improvement (10.3.1) - RPN is used as the deciding factor for PFMEA improvements which the auditor stated as being contrary to AIAG recommendations. I understand the reasons for not relying on RPN as a deciding factor but argued that the FMEA manual does not state that it cannot be, it only states it is not recommended. I think in reality the n.c. was because we hadn't justified why we hadn't done anything to reduce the RPN, because he attempted to align the fact that we had 3 internal rejects for a specific issue over the year, but the PFMEA had not been reviewed in that time period.
He did try to hit us with a fourth n.c. for our audit timetable as all audits are currently carried out over a 3 year cycle. This is based on the IATF requirement as well as historic internal findings etc. He tried to claim that the standard implied that the 3 year cycle was referencing the certification cycle, but I successfully argued that it doesn't state that in the standard, it simply states a 3 year cycle. He put this to his technical team for guidance who came back and agreed with us. He then moved on to auditor competency and gave the first n.c. above.
Rich Shippy - The n.c. for operator safety has never been picked up in the 7 years I have been with the organisation and we have had 3 different external auditors in that time period. In addition, internal auditor training by another internal auditor that is fully trained (externally) has also always been acceptable to previous auditors and using RPN has never been an issue before. I am not saying that any of the findings aren't justified or in-line with IATF etc., but I would of expected them to have been highlighted over previous audits.
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