Dangerous Act - Auditor says major nonconformance for safety (risk) issue

G

Graruss

#1
While undergoing a stage 1 audit, the Auditor stated before entering the workshop that if he spotted any operator using an angle grinder without a side handle it would be an immediate Major Non Conformance. Our risk assessments state two handed operation but do not specify handle to be fitted. Would I would be interested in the opinion of the forum members if they have experienced this or a similar situation.
 
Elsmar Forum Sponsor
E

engr.post

#2
Re: Dangerous act

An internal auditor or a first or third party auditor? Consider that could have a bearing on how you respond.

You could look/ask why grinding w/out handle? I my opinion it could be e.g. for easier access to component, for finer hand control of grinding operation, for comfort. Hands grinders already have wheel guards, people use safety specs and shields etc.

Next, these could be very experienced and skilled wo/men. Rather than people that are not used to handling tools.

If this is a systematic assessment issue something like a risk assessment can be used to consider what is and isn't 'dangerous' - itself a subjective term (in this case). Carefully identify the hazards, and subjectively rate their probabilities.

Another point, ask auditor to define scope of this audit, and terms such as minor and major nonconformance. But try to work with each other to resolve this. There is no need to accept this nc but you have to reason why for the auditor.

best
 
Last edited by a moderator:

Randy

Super Moderator
#3
Stage 1 he really isn't supposed to be doing much more than document review. It also looks like he is being less than objective and impartial having already made decisons for acts he has not seen.

Additionally he had better be able to back himself up with something other than "I am an auditor". Below is what is supposed to happen during a Stage 1 direct from ISO 17021:2006.

9.2.3.1 Stage 1 audit

9.2.3.1.1 The stage 1 audit shall be performed

a) to audit the client's management system documentation;

b) to evaluate the client's location and site-specific conditions and to undertake discussions with the client's personnel to determine the preparedness for the stage 2 audit;

c) to review the client's status and understanding regarding requirements of the standard, in particular with respect to the identification of key performance or significant aspects, processes, objectives and operation of the management system;

d) to collect necessary information regarding the scope of the management system, processes and location(s) of the client, and related statutory and regulatory aspects and compliance (e.g. quality, environmental, legal aspects of the client's operation, associated risks, etc.);

e) to review the allocation of resources for stage 2 audit and agree with the client on the details of the stage 2 audit;

f) to provide a focus for planning the stage 2 audit by gaining a sufficient understanding of the client's management system and site operations in the context of possible significant aspects;

g) to evaluate if the internal audits and management review are being planned and performed, and that the level of implementation of the management system substantiates that the client is ready for the stage 2 audit.

For most management systems, it is recommended that at least part of the stage 1 audit be carried out at the client's premises in order to achieve the objectives stated above.
 

Ron Rompen

Trusted Information Resource
#4
I agree completely with Randy; a finding of the nature you describe would be (IMHO) definitely outside the scope of a Stage 1 audit.

I would also question (politely of course) the rationale behind designating this finding as a major n/c at ANY time; the wording of the standard (ISO) is:

6.4 Work environment
The organization shall determine and manage the work environment needed to achieve conformity to
product requirements.
NOTE The term “work environment” relates to those conditions under which work is performed including physical,
environmental and other factors (such as noise, temperature, humidity, lighting or weather).

This is expanded on in the TS 16949 standard:
6.4.1 Personnel safety to achieve conformity to product requirements
Product safety and means to minimize potential risks to employees shall be addressed by the organization,
especially in the design and development process and in manufacturing process activities.
6.4.2 Cleanliness of premises
The organization shall maintain its premises in a state of order, cleanliness and repair consistent with the
product and manufacturing process needs.

Although operator safety is a prime concern for all of us, I would not (as an auditor) write up a single incident (or set of incidents, if all operators consistently use the grinder without the handle attachment) as a major nonconformance.

Neither the ISO or the TS standard prescribe WHAT is considered the correct measures for 'personal safety', this is documented in other legislation, and if it is not specifically noted in that document, (or within your own company procedures) then it cannot found to be a nonconformance, no matter what personal feelings the auditor may have.

Remember that auditors come at all levels of experience and with all kinds of backgrounds, knowledge and pre-conceived notions. Not all of them are correct.
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#5
Neither the ISO or the TS standard prescribe
I have a feeling that the stage 1 audit in question was not done against a QMS standard such as ISO 9001 or ISO/TS 16949. Even though the OP did not disclose which standard is at play, this thread is under Occupational Health & Safety Management Standards.
 
D

David Hartman

#6
Are there specific OSHA (or other local) standards/regulations in your area that would require a side handle on a grinder?
 

Jim Wynne

Staff member
Admin
#7
While undergoing a stage 1 audit, the Auditor stated before entering the workshop that if he spotted any operator using an angle grinder without a side handle it would be an immediate Major Non Conformance. Our risk assessments state two handed operation but do not specify handle to be fitted. Would I would be interested in the opinion of the forum members if they have experienced this or a similar situation.
Was this auditor missing any fingers, by any chance? :tg:
 
P

PGTIPS8

#8
Clearly agree scope before the visit. But if this is a safety audit or safety bias then he is within his scope to flag dangerous occurances. Remember PUWER requirements associated with equipment handling and modification. If the grinder has a handle port then the handle should be fitted. If the operation requires a grinder of a different nature in order to access the work area. Then you should not remove a handle from the grinder to gain access, you need to risk assess the work and factor in correct safe access and egress. Be very careful regarding R.A. and mitigation. We recently had to stop all angle grinder work accross ouir site, of 10.000 people, due to poor operations and risk assessments using angle grinders. HSE ETC!!!!!!!!
 

Randy

Super Moderator
#10
He ain't supposed to be looking at that stuff during Stage 1 on an OHS certification and he most probably is outside of the Scope of the audit and absolutely is past being objective (I've done at least 2 of these in my career:lol:)

Here's the deal though, if perchance you guys are doing a tour and he observes something then he is absolutley correct to question it and ask you about the associated risk of the activity, your controls and any regulatory requirment associated with grinder use. He is not correct though in making such a brash statement as you quoted.

I will say that I am ashamed of my ignorance in UK OHS regulations especially since I kinda, sorta work for a UK based organization...Kinda, sorta;)
 
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