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Thanks for your feedback; It's not just talking about audits; at the management review top management actually discuss the plan, review training needs, assign resources, etc.
We are giving internal audit more visibility through the Management Review.
We are giving internal audit more visibility through the Management Review.
You're missing the part in 8.2.2 that says you need to audit your quality system. It doesn't say, "audit only those parts that are not discussed in management review".
An audit is quite different than monitoring activities.
Now... if you include the internal audit program on your schedule, then have management audit it together during management review, you'd have a much stronger case to argue. But, then you're still going to need to generate an audit report, still document your nonconformities, and still take corrective action regardless of who you want to call the "auditor".
I think what you're doing could be a very good solution to the tight budget / tight resources issue. When management refuses to budge and won't offer funding for audit staff, make them conduct the audit!
Don't forget to train them as auditors - so you've got your competency issue taken care of...
I'm with Andy on this one though... as it stands, based on what you're saying, you're monitoring the audit program in management review, which is a good thing since it's required under 5.6.2, but you're not auditing your audit program. That would be a NC against 8.2.2 which requires that:
"The organization shall conduct internal audits at planned intervals to determine whether the quality management system
a) conforms to the planned arrangements (see 7.1), to the requirements of this International Standard and to the quality management system requirements established by the organization, and
b) is effectively implemented and maintained."
So, 8.2.2 requires that you audit the entire quality system and 5.6.2 requires that you talk about those audits during management review meetings. Unless you can show that an audit was conducted during the management review meeting, and back that up with an audit report, you haven't met the requirements of 8.2.2. And, if your registrar hasn't seen it yet, my guess is you're probably going to see a NC in the future.
Tie it to the paycheck and people line up. 