Auditing 6.4 Work Environment



Re: What does the standard say?

db said:

Unless the auditor can show where my work environment has resulted in my inability to achieve conformity to product requirements, there can be NO nonconformance cited.

Let's assume you are correct and the auditor won't pin you down that you haven't "determined" or demonstrated "management" of the work environment, and will only have cause to cite you if you produce nonconforming product.......

Do you really have zero nonconforming product?:eek: Are you saying that you can produce 100% good product? If not, how will you demonstrate that it isn't the fault of the work environment?

Seriously, what is so difficult about meeting the requirements of this clause? Look around and you will see the components of it all around you. This isn't something that should be difficult.

However, if I was an auditor and found seamstresses working on delicate fabric or doing intricate beadwork in a hot warehouse without AC and no potty breaks allowed except for lunchtime and lunchtime was limited to 15 minutes, I would cite a nonconformance to this clause no matter how many good items they produced. Because a worker is not working to best ability under these circumstances and fabric will be ruined and wasted and employees will be sick and absent resulting in less production. The business suffers when employees suffer and that is the point.

M Greenaway


How could you say the workers were not working to their best ability under such circumstances ? I think in order to raise an NC you would have to be able to prove that to be the case, not just speculate (probably quite rightly) that the product will be affected. I would see the poor working conditions as a probable cause of problems, but would dig deeper to find hard evidence.

Just my preferred approach as it leads to far less contention in closing meetings or with the audit report if opinion is kept out, and only hard facts reported.

Chris May

My take would be that you could demonstrate that the working environment does have an impact upon the business, by measuring the productivity levels.

An "environmentally" friendly workplace would have an effect upon the operators and happy bunnies would be more productive.

As pointed out, it would not be auditable to 9K2K buy could be cited as an opportunity for improvement (observation).

No way should you get a NC for this.



M Greenaway


Like you say the NC could be cited if you could demonstrate that their was an actual problem, such as productivity because low productivity would doubtless lead to complaints of late delivery.

Root cause investigation might determine the work environment was to blame, but I would think that being able to identify that the work environment is detremental to quality just by its 'appearance' and our own perception of whats 'good' is perhaps skating on thin ice. Unless of course the environment was clearly detrmental, like making ice cubes in a furnace !

I am kind of thinking in terms of some of the manufacturing facilities in places like India, where to a westerner the conditions might appear to be not conducive to producing a quality product. But in fact in the context of the location, culture, etc might to the guys working there pose no problems what so ever.

Maybe - just thinking aloud.


6.4, or social engineering?

Oh where do I begin?

Lucinda, in your scenario involving the seamstress, at what point would you not issue a nonconformance? When the AC was installed, when the potty breaks got to 25 min? Whose definition of a suitable work environment would we use? If I live in an area of the world that sees a lot of 100 degrees plus days, and the temp is 105, the auditor might feel like dieing, but the seamstress might be commenting that the temp is “mild”. Who is to judge, and what is the standard? I have relatives that did not get indoor toilets until the 80’s. We can’t force our ‘comfort level’ on other organizations. That is why the "needed to achieve conformity to product requirements." is in there.

Are you saying that you can produce 100% good product? If not, how will you demonstrate that it isn't the fault of the work environment?
This is the problem area for the auditor. It is incumbent on the auditor to show evidence that nonconforming product was created as result of the environment, not the auditee. The presence of nonconforming product does not, by its self, mean there was a failure in 6.4.

Martin said:

Like you say the NC could be cited if you could demonstrate that their was an actual problem, such as productivity because low productivity would doubtless lead to complaints of late delivery.
I don’t think we can categorically make this statement. I know lots of low productivity shops that make 100% on-time deliveries. They just take their lack of productivity in account when quoting lead times. Low productivity is a red flag and a threat, but auditors can do little until it does create a problem.

Chris said:
An "environmentally" friendly workplace would have an effect upon the operators and happy bunnies would be more productive.
The US has some of the most environmentally friendly shops in the world, yet we also have the most disgruntled workforce. Why? Perhaps if we ‘spoil’ our workforce, they will find other things to complain about, or will just want more. Which leads back to my response to Lucinda’s post.

Ken K

One quick can an auditor give a nonconformance for environment? How can they possibly prove the environmental conditions warrent one? Is it an assumption on their part?

This seems like a really grey area to me. If I look at Lucinda's example of the seamstresses, how many things would one need to change before improvement is seen? Would improvement be seen? Would it make a difference? What if it didn't?

I once had the opportunity to view the casting operations at the Kohler Company not far from here. They make mostly bathroom fixtures (tubs, sinks, toidies). The environmental conditions would seem brutal to an auditor, but comfy to the workers. Where would you draw the line?

Okay, maybe quite a few questions...but still a grey area IMO.

Interesting discussion.

M Greenaway


Yes I think we (me, you and db) are in agreement here. It is unlikely in an audit that you will be able to determine a root cause. That should really be left to the corrective action process. The audit should highlight firm evidence of specific non-compliance. I agree it would be nigh on impossible to cite a non-compliance against the 'environmental conditions' unless in extreme conditions, such as I (exaggeratingly) quoted.

That is what I think the intent of the standard is - specific environmental conditions for specific products/processes.

Randy Stewart

Here comes a Monkey wrench!

I have to agree with all of you. We had a situation where during our kirksite reclaimation process the guys were getting bad headaches. We have been doing this for years, and it was known that you get headaches during this. Its due to the lubes, bondo, etc. used in soft tool die operations. It is not a life threatening situation nor was it an OSHA violation. I sited this under an internal audit finding and it kicked off a study into the problem. We now have a new make-up air system (was found the shop was at a negative pressure) which allows the ventilation system to work. In other words, I do believe we have a responsibility to respond to these situations. But at the same time we must be reasonable. I don't know if I would have written up an NC if it had been an external audit, to be honest I think I would have left it as an observation to see what could be done. I feel you would have a difficult time in getting an NC to fly on this issue, if the enviroment isn't controlled I bet I could find other areas showing a lack of management involvment. It would lead me to really look at management, they must not be too concerned about there employees.


So you think it will be difficult to write a NC? and that is your stumbling point? Responsibility is not on auditor to prove the company doesn't do something, it is on the company to prove it does! Without objective evidence that something is being done, it is not being done. Sounds like an easy NC to me.....

The question should really be "at what point is an auditor happy that "determination" and "management" of work environment has taken place.

Would you would say that a company is determining and managing their work environment if they haven't documented that they are aware of the above points (temp, etc.) and they don't feel that it affects the ability to conform to product requirements?

Would you still say that the company is managing that 100 degree sweat shop appropriately if the seamstresses are sweating all over the fabric? Or if the machine is jamming because of the humidity? Or they have to rebead 10percent of their dresses because the ladies are faint with dehydration due to not drinking because they won't get to potty?

I'm told that this was ISO's idea of introducing social and safety issues into business practice and it was European contingent's idea. US was not happy with it and neither was the rest of the world. (this is just second-hand gossip so don't shoot me. I'm just repeating what I was told)

At any rate, whether or not you think that a NC could ever be raised against it, that is no reason to ignore the clause.
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