Internal Audit Corrective Actions - Can a CB write an NC on an in-process CA?

Jen Kirley

Quality and Auditing Expert
Leader
Admin
I am not concerned about grades or scores.
What I am concerned with is completing internal audits as required by the standard and identifying non-conformances which lead to improvements, then just to have them written up again by the CB. I can understand the CB auditor noting the issue but not repeating something that is already address. FOR WHAT WOULD BE THE POINT OF DOING AN INTERNAL AUDIT. Goes to not making quality products, why should I care to identify issues why not wait for the customer find the problem. Goes against the entire purpose of Section 8 of the standard.
I don’t see the value of writing a non-conformance (NCR) on a issue that is already addressed by the organizations internal audit process, back to the double jeopardy issues.
I was originally under the impression that the internal NCs were to be open at time of registration audit, which is fine but it's possible the CB auditor would still raise a nonconformance. But this part reads as though the internal NC is closed. Do I misunderstand you?

If the internal NC is still open, I am not sure why the organization would feel bothered by it. In both cases a plan of action would need to be made, carried out and reassessed for effectiveness. The difference is that you'd be reporting to the CB auditor about what you'd already be doing to resolve the problem. What about this happening in a third party audit makes the internal NC activity an exersize in futility? You are already doing it. So just do it.

There is no rule that a CB would, or is even allowed to decide not to write an NC on a clear issue because the client company had an open internal NC on the same issue. The registrar is charged with verifying compliance and is getting paid good money to do so. They would be remiss if they did not take this opportunity to see through an issue to closure.
 

paultyler

Involved In Discussions
You didn't understand. The NC is still and open issue. However, if the CB auditor can view this as black and white and write an NCR on the same issue I have already identified. Then I am doing the same thing twice on the same issue. My own root cause, corrective action, verification process (documentation included). Then I am repeating the process again to answer another NCR (filling out the CBs forms, etc). This is doing the same thing twice, not value added.
 

Sidney Vianna

Post Responsibly
Leader
Admin
You didn't understand. The NC is still and open issue. However, if the CB auditor can view this as black and white and write an NCR on the same issue I have already identified. Then I am doing the same thing twice on the same issue. My own root cause, corrective action, verification process (documentation included). Then I am repeating the process again to answer another NCR (filling out the CBs forms, etc). This is doing the same thing twice, not value added.
Then DROP/VOID your internal NC and process only the CB CAR form. At the end of the day, you will accomplish the same result, isn't it?

What you don't understand (apparently) is the fact that the CB NC will be followed up and they will ensure that the issue has been resolved. With your internal CAR process, there could be delays, games, lack of verification of implementation and effectiveness, etc...

If you read my arguments in the thread I hyperlinked you would have seen sound argumentation for why CB auditors could decide to keep their NC's despite the fact you might have already identified the issue at hand.
 

paultyler

Involved In Discussions
WOW, really. I fully understand the process. To suggest that an organizations internal process might have "delays, games, lack of verification of implementation and effectiveness" is a question of integrity.

I am sorry but I take that as a personal attack on my integrity.

I still stand that having a NCR written up by a CB auditor that has already been idenfied by the internal audit process is WASTE OF MY TIME.
 

Sidney Vianna

Post Responsibly
Leader
Admin
To suggest that an organizations internal process might have "delays, games, lack of verification of implementation and effectiveness" is a question of integrity.
Not really. It is the reality for many organizations who have less than robust corrective action processes. Delinquent corrective action requests abound in the corporate world. If that is not your experience, good for you. But it is FOR MANY organizations.
I am sorry but I take that as a personal attack on my integrity.
Obviously my post was never intended as such. But, if you feel that any post (including mine) crossed the line you can always use the report button
Internal Audit Corrective Actions - Can a CB write an NC on an in-process CA?
to bring that to the attention of the Forum moderators.
 
J

Jason PCSwitches

Let's take a step back and look at this for a second.

One of the very 1st things audited by a certification body is generally the internal audit process.

If during the course of the audit routine an N/C is noted, & that N/C is parallel with a CURRENT/OPEN CA that the internal audit process detected, then it should not be an issue. Here's why.

You've already determined the IA process to be effective, to some degree. The NC has been noted, recorded, addressed, & is currently ensuring action is taken to correct/prevent recurrence of the NC.

Issuing an additional NC is absolutely a waste of time unless the CB auditor finds that the noted NC has not been addressed in a reasonable amount of time or it is just "wallpaper" to try and cover issues that the organization hasn't addressed properly. There are obviously more justifications but I digress....

Either way it is the responsibility of the organization to demonstrate it's case, as it is the CB auditor to justify the need for an added CA.

What happened to confidence and Balls!! No disrespect intended :)
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
You didn't understand. The NC is still and open issue. However, if the CB auditor can view this as black and white and write an NCR on the same issue I have already identified. Then I am doing the same thing twice on the same issue. My own root cause, corrective action, verification process (documentation included). Then I am repeating the process again to answer another NCR (filling out the CBs forms, etc). This is doing the same thing twice, not value added.
If it was my NC I would update my logs to say "See XYZ from registration audit #123." No extra work is done, just as no judgment of character is being rendered.
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
If during the course of the audit routine an N/C is noted, & that N/C is parallel with a CURRENT/OPEN CA that the internal audit process detected, then it should not be an issue. Here's why.

You've already determined the IA process to be effective, to some degree. The NC has been noted, recorded, addressed, & is currently ensuring action is taken to correct/prevent recurrence of the NC.

Issuing an additional NC is absolutely a waste of time unless the CB auditor finds that the noted NC has not been addressed in a reasonable amount of time or it is just "wallpaper" to try and cover issues that the organization hasn't addressed properly. There are obviously more justifications but I digress....

Either way it is the responsibility of the organization to demonstrate it's case, as it is the CB auditor to justify the need for an added CA.

What happened to confidence and Balls!! No disrespect intended :)
I used to think that way, and changed my mind. Or rather, my mind was changed for me by way of Lead Auditor training. See my input to the thread Sidney linked.

Like the automotive group, the aerospace group gets to define its expectations of auditors based on client expectations of the system.

Your finding the issue internally is noteworthy, a very good thing. But the auditor is merely recording a nonconformance to the standard, which doesn't include a clause about the auditee's sense of fair play.

If you want to pursue the issue and get a complete explanation from the source that really matters (the CB) you could ask for arbitration of the NC.
 

Randy

Super Moderator
If I were to assess and internal audit process and a corrective audit process and find both to be working as planned/required (verified effective) it would also be a waste of MY TIME as well, to issue a NC against one already being managed by the previously verified effective CA process, unless of course there is a pre-existing reason or requirement that mandates I do so.

To just automatically issue NC's against NC's that have previously been identifed and are being addressed, to me is weak and strikes me as p*ss poor.

Anyway that's my:2cents:
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
If I were to assess and internal audit process and a corrective audit process and find both to be working as planned/required (verified effective) it would also be a waste of MY TIME as well, to issue a NC against one already being managed by the previously verified effective CA process, unless of course there is a pre-existing reason or requirement that mandates I do so.

To just automatically issue NC's against NC's that have previously been identifed and are being addressed, to me is weak and strikes me as p*ss poor.

Anyway that's my:2cents:
I can appreciate that. I suppose though, that in a case like this is isn't supposed to be about what we think, but what the CB has decided and based on what internal directive, or hopefully something passed down by the standard's governing group, in this case the AS group.

I do remember asking a past CB auditor for the directive he was basing his "line in the sand" on, and he declined (or was not allowed?) to show us.
 
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