Auditing 6.4 Work Environment



The problem Lucinda is that the organization HAS objective evidence of compliance to 6.4 PROVIDED they can show that environmental conditions have not caused nonconforming product. Let's look at your example. First, you added additional information that was not in your earlier post, but that is okay.

Would you still say that the company is managing that 100 degree sweat shop appropriately if the seamstresses are sweating all over the fabric?
Does having sweat on the fabric result in nonconforming product? If so, you can cite against 6.4. I have worked in Reynosa, Mexico building houses. It was 105 degrees and, being a northern boy, it nearly killed me. The locals thought it was funny! One even wore a jacket the next day because he was "chilly" at 97. Is 100 degree too hot? By whose standard. Likewise, I prefer the office temp to be about 60 year round. If I set the thermostat there, others would be saying it was too cold to work. Set it at 80 and I complain. At 70 no one is happy. Does this mean we can't meet 6.4? As far as appropriately managing, who is to say they aren’t? Can we write a noncompliance if the employees don’t make $65 per hour, US? What if the temperature was only 98 degrees? What is the ISO 9001:2000 mandated temperature?

Or they have to rebead 10percent of their dresses because the ladies are faint with dehydration
Now, we have nonconforming product (I think). It makes no difference if the rebeading is from work environment, or laziness, or defective beads, there is nonconforming product. But, if the work environment results in the nonconforming product, then you could cite 6.4. Are we to be doctors and able to determine why the ladies are faint? (Actually it makes no difference why they are faint. If their medical condition results in nonconforming product, you could still cite 6.4)

Responsibility is not on auditor to prove the company doesn't do something, it is on the company to prove it does!
Yes, this is true. However, if I do a root cause analysis and state that the rebeading was due to the beads were packaged by the vendor wrong (even if this isn't true), what right does anyone else have to say: "No it was because of the work environment!" If I say I have no problems with product due to the work environment. How can an auditor tell me otherwise?

In your examples, the auditor could see (one of the methods of obtaining objective evidence - observation) that the work environment has in deed created nonconforming product. In this case, a nonconformance could be written against 6.4. However, this leads me back to my original statement (although I could have stated it better). The auditor must be able to “prove” the nonconformance. This is done by showing what the standard says and what the objective evidence is that shows the “shall” was not met. In the case of 6.4 the burden of proof is the AUDITOR must what objective evidence proves the “shall” was unfulfilled. If the standard requires a procedure and the auditee cannot produce one, the objective evidence is the auditee could not produce the required procedure. If the requirement is that the work environment shall not result in nonconforming product, the objective evidence would be nonconforming product that was caused by the work environment. The proof is still on the auditor.

M Greenaway

db - you said it all, perfectly.

NC's should always state (in my opinion) specific instances of objective evidence that demonstrate a part of the system doesnt work. Which part should be left to being determined in the root cause investigation that is undertaken by the corrective action process.

I personally think the clause in question is specifically targetted in ISO9001 towards processes that require special environmental conditions, such as 'clean room' environments for the production of micro chips for example. ISO9004 perhaps takes it beyond this narrow (but crucial) focus to wider issues of ergonomics and employee comfort, but I would personally steer well clear of these issues unless they were very clearly a problem.

i.e. I would not raise an NC because someones VDU screen is not at the correct level as given in that obscure European Directive that gets bandied about at your induction day !


Quite Involved in Discussions
Lucinda, you are correct originally work environment was to include safety and labor type regulations but was shot down by several Far East countries.


From the viewpoint of conformance with ISO 9001:2000 6.4, I agree with db - auditors should only cite a NC to 6.4 if there is proof that the work environment affects "conformity to product requirements".

It seems a little cold (I'm not talking 60 F here db :p ) if you don't consider the welfare of employees, but one may argue the standard isn't about that (except where it results in NC product).


1. To follow db's line of reasoning "Are we to be doctors and able to determine why the ladies are faint?", I return to my earlier question - what competencies are auditors expected to have when auditing 6.4?

2. Following closely on (1), can we stretch 7.2.1 (c) to say that auditors should be aware of laws relating to working conditions as they affect product realisation? (Yes, ISO 9001 auditors & internal auditors are not government/regulatory inspectors, but how much should auditors know?)

3. To come back to my earlier lighting issue - the organisation has not determined (objectively) what "adequate lighting" for inspection is, so our auditors have cited a NC based on the inspectors statement that lighting is inadequate. If the auditors were to have carried light meters & found illumination to be 4 lumens (I pulled that number out of a hat) could they cite a NC if there are no organisation-determined requirements?

Quality Improvement:

Lucinda, I think you may be interested in the call from consumers for development of standards for Corporate social responsibility (CSR) by ISO. The press release is Ref.: 826, 19 June 2002, the url:
- Link Was: /iso/en/commcentre/pressreleases/2002/Ref826.html
There's also the "Investors in People Standard" (I think I saw it on a thread in the Cove): - Link was: /thestandard/

If I'm becoming too long-winded, let me know :)

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Sweatshops and safety regs

First of all, I'm not sure anyone running a sweatshop would be interested in ISO registration. Their idea is to turn a fast buck and the cost of ISO would work against that. However...

This is not a new discussion. The old 4.9 c) stated we had to conform to standards and codes. The same argument was raised there. Supposing you, as an auditor, found a fire door block by equipment. Could you write to 4.9 c)? I would ask you specifically what code I was in violation of? Can you cite the actual fire code that was violated?

It seems a little cold
Cold, no..heartless absolutely. But ISO is not about compassion and feeling. It is about logic and meeting the "shalls".

Mike S.

Happy to be Alive
Trusted Information Resource
Re: Sweatshops and safety regs

db said:

This is not a new discussion. The old 4.9 c) stated we had to conform to standards and codes. The same argument was raised there. Supposing you, as an auditor, found a fire door block by equipment. Could you write to 4.9 c)? I would ask you specifically what code I was in violation of? Can you cite the actual fire code that was violated?

In the case of a blocked fire door, if I were auditing I’d write it up as a NC as it is very common knowledge in industry that this is a safety violation. If pressed to specify what exact fire code was being violated by someone in the company, I’d say “hold on while I call the local fire company (or OSHA) and I’ll get you your answer”. That should quiet them down a bit.

Other issues like lighting, room temperature, etc. are more subjective for sure. JMO.

M Greenaway

Good point Mike.

Blocking of fire doors is breaching regulatory requirements (although it has nothing to do strictly with product quality). If the auditee asked me which regulation was in breach I would serve up another NC citing the fact that they were not aware of regulatory requirements - but this is beyong an ISO9001 audit in my opinion, this is more an OHSAS audit.

The original discussion was on environmental conditions, which I think would be a seperate kettle of fish to OHSAS issues. Keep it clean and stay focussed on the issues is my advice.


Leading to the next question

I know this is off subject, but. Lucinda's scenario and my question about the blocked fire doors leads me to a question. What is the auditor’s obligation when they see something that they know is unlawful? Are they obligated to report it to the appropriate authorities, or are they prohibited from doing so?

M Greenaway


The law of the land must always overide any so-called 'confidentiality' that the auditor must maintain.
Now, there's a good question.

Someone within the company is responsible, but may not be aware of what's happening. Wouldn't the very first thing to do be to get the attention of that person?

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