Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interest)?

Can a consultant hired to implement a QMS also perform 1st. Part audits to the same?

  • Yes

    Votes: 20 74.1%
  • Yes, if the company does not have a suitable Internal Auditor

    Votes: 4 14.8%
  • Better not

    Votes: 2 7.4%
  • No

    Votes: 1 3.7%

  • Total voters
    27
  • Poll closed .
U

Umang Vidyarthi

#11
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

IMO there is nothing wrong, in view of the fact that the cosultant only provide the guidence and guidelines to the quality dept. He also audits from time to time whether the implementation is in tune with the ISO or not. He remains 'aloof' from implementation on ground zero. In other words, he is not involved in day to day activity of the quality deptt. and hence he is fully qualified to perform the internal audit.
 
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Coury Ferguson

Moderator here to help
Staff member
Super Moderator
#12
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

I took out the bit about the consultant as I don't feel it is relevant. :)
That is relevant. By definition, they (the consultant) developed, designed and wrote the QMS, therefore it is their work.

In this particular scenario, the new person did not develop, design or write the QMS, but is responsible for the system with the authority to change the system.

So, does this fall under the requirement that the auditor not audit their own work (in this scenario)?
 
Last edited:

Paul Simpson

Trusted Information Resource
#13
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

That is relevant. By definition, they (the consultant) developed, designed and wrote the QMS, therefore it is their work.
I didn't explain myself well! :eek: The use of a consultant is irrelevant to the question of auditor independence.

If the new hire is in place they are the only one we could potentially question the independence of.
 
#14
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

To my way of thinking, the architect of the system has little to nothing to do with being responsible for the implementation. Indeed, the 'work' isn't done by the people who wrote the stuff, it's who performs it that counts! Otherwise we'd not be any further ahead for smaller companies where the people who do the work often wrote their own documents!!

No, it has nothing to do with the consultant being the architect, it's all about the implementation of what's written..........
 

Coury Ferguson

Moderator here to help
Staff member
Super Moderator
#15
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

To my way of thinking, the architect of the system has little to nothing to do with being responsible for the implementation. Indeed, the 'work' isn't done by the people who wrote the stuff, it's who performs it that counts! Otherwise we'd not be any further ahead for smaller companies where the people who do the work often wrote their own documents!!

No, it has nothing to do with the consultant being the architect, it's all about the implementation of what's written..........
In this scenario we are talking about the new hire performing the Internal Audits. Yes, in this scenario, the Consultant performed a round of internal audits.

I ask this again: Is this scenario, is the new hire auditing their own work?
 

Paul Simpson

Trusted Information Resource
#16
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

I ask this again: Is this scenario, is the new hire auditing their own work?
Coury, you have my answer, no - with the caveat that if they are involved in doing something that one of the procedures calls up - say approving procedures for issue - then they cannot audit any work that they have done.

If they have just arrived they can audit document approval they haven't been involved in! :)
 
J

joshua_sx1

#17
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

…if you are relating to a person who developed the QMS with another different person who will perform the audit, it is OK :yes: … but! they shouldn't belong to the same consultant (organization) who developed your QMS… :nope:
 

harry

Super Moderator
#18
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

From Big Jim's post in the other thread: 1st, 2nd and 3rd Party Audits - Definition

ISO 19011 definitions?

3.1
audit
NOTE Internal audits, sometimes called first party audits, are conducted by, or on behalf of, the organization itself for management review and other internal purposes and can form the basis for an organization's self-declaration of conformity. In many cases, particularly in smaller organizations, independence can be demonstrated by the freedom from responsibility for the activity being audited.
It provides even more room for argument - especially for the external party who may be the original QMS consultant.
 

Randy

Super Moderator
#19
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

I think it's a crock of warmed over horse bagels.:horse:
 

Paul Simpson

Trusted Information Resource
#20
Re: Can our QMS Consultant Perform Internal Audits on our behalf (Conflict of Interes

From Big Jim's post in the other thread: 1st, 2nd and 3rd Party Audits - Definition

ISO 19011 definitions?

3.1
audit
NOTE Internal audits, sometimes called first party audits, are conducted by, or on behalf of, the organization itself for management review and other internal purposes and can form the basis for an organization's self-declaration of conformity. In many cases, particularly in smaller organizations, independence can be demonstrated by the freedom from responsibility for the activity being audited.
It provides even more room for argument - especially for the external party who may be the original QMS consultant.
I take the point about use of 19011. Please bear in mind the note is explanatory of the word independent and is trying to explain that (particularly in smaller organizations) it is often very difficult to get total independence.

I also like the wording in 19011 later:
ISO 19011.2002 said:
6.2.4 - Selecting the audit team

e) the need to ensure the independence of the audit team from the activities to be audited and to avoid conflict of interest;
That is the overall aim.

…if you are relating to a person who developed the QMS with another different person who will perform the audit, it is OK :yes: … but! they shouldn't belong to the same consultant (organization) who developed your QMS… :nope:
Why?

Let's get back to the principle, here.

  • If you are not completely independent you may have a conflict of interest.
  • Internally it is almost impossible to have complete independence from any of the processes within the organization
  • The internal audit is there to demonstrate the organization's systems work
  • In the example we are discussing the new hire is probably independent (as far as s / he can be)
  • A consultant from the firm who helped develop the QMS (with the organization)
  • What consultant has anything to gain from carrying out an internal audit and saying no problems found when in fact they exist - only to risk a third party saying the system is inadequate

Let's bear in mind there is no such thing as complete independence, taking 3rd party (independent) certification or accreditation as an example:
  • If I am a certification body / registrar / accreditation body I am paid by my client for the assessments I provide
  • If I am a government body I am subject to internal and external political pressures (either to increase or restrict access to an area of activity)
  • If (just picking a random example :notme:) I am an accreditation body with a mission to "clean up" accredited certification and one of the ways of doing that is to get rid of rogue certification bodies I have lost any independence and no longer have a remit to carry out audits of CBs.
 
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