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

J

Jason PCSwitches

At some point we've got to be real....and objective.

Is the system functioning within the intent of the standard?

If so, additional paperwork is of no value to the organization or the CB.

I would think that a notation of the active internal CA's would be sufficient to allow follow-up during the next audit. They can be reviewed and analyzed for effectiveness at that time.

Let's not get into the mentality of "beating-up" those who are putting forth an honest effort.

Auditing shouldn't be about "jamming people up", it should be about "objective" evaluation.
 

Sidney Vianna

Post Responsibly
Leader
Admin
Is the system functioning within the intent of the standard?
And how can you tell? It takes time for any auditor to know if the organization has a robust, reliable, trustworthy corrective action process. There is no one size fits all answer. If this is a stage 2, certification audit, there is very little history between the CB and the registrant. If this is a surveillance audit and the registrant has been certified for several years, then the scenario is different. Auditors have to use judgement and discretion. If the system was so effective as some try to imply, the NC's should have been uncovered way before the external auditor showed up and resolved.
 

rickpaul01

Involved in HankyPanky
Several of you, both for and against, have brought up excellent points. Some of them…

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.

If the system was so effective as some try to imply, the NC's should have been uncovered way before the external auditor showed up and resolved.


Now, do we remember what the original NC was? nonconformances found related to not having addressed changes to REV C

So, if I was hired to audit you to Rev C, and I show up, and you haven’t implemented Rev C yet, I am going to think exactly what Jason posted.
 
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J

Jason PCSwitches

Auditors have to use judgement and discretion. If the system was so effective as some try to imply, the NC's should have been uncovered way before the external auditor showed up and resolved.[/QUOTE]


Judgement & discretion are a major part of the audit process. You will have to admit that as I know your experience in the field has shown you such.

No system is perfect. If so, then there would be no need for oversight (or internal audits) except for CONFORMANCE; which is what we are looking for.

CONFORMANCE = not my view, your view, how this guy did it, how that guy did it; just CONFORMANCE to the integrity of the requirements of a standard as related to an organization.

We can go back and forth on this ad infinitum, but come on; you must know that there are situations (judgement & discretion) where NC's don't need to be issued just because....

If the system has effectively identified it's flaw's, then it is in essence operating effectively in-respect to continual improvement and basic standard requirements. An auditor must then use judgement regarding when analyzing the evidence of such.

If the system demonstrates that it is, essentially, self-aware, why bother. Use Discretion and note the current activity and follow-up on it later. There are exceptions but again, judgement & discretion must be used when conducting an objective evaluation of not only a QMS system, but for anything.
 

Sidney Vianna

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Leader
Admin
Now, do we remember what the original NC was? nonconformances found related to not having addressed changes to REV C
Thanks for the reminder. It just adds even more weight for the CB auditor NC's to stick, simply because AS9101D has new nonconformity management requirements, in terms of timeliness for correction, containment, corrective action, etc. Would the internal corrective action process have the same requirements as the AS9101D standard? I doubt it.

I find very difficult to accept that people would have such a difficult time cutting and pasting text from their NC forms to the CB NC forms. If that is so difficult, as I said, just void your internally triggered NC's and focus only on the CB's.
 
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Jen Kirley

Quality and Auditing Expert
Leader
Admin
Auditors have to use judgement and discretion. If the system was so effective as some try to imply, the NC's should have been uncovered way before the external auditor showed up and resolved.

Judgement & discretion are a major part of the audit process. You will have to admit that as I know your experience in the field has shown you such.

No system is perfect. If so, then there would be no need for oversight (or internal audits) except for CONFORMANCE; which is what we are looking for.

CONFORMANCE = not my view, your view, how this guy did it, how that guy did it; just CONFORMANCE to the integrity of the requirements of a standard as related to an organization.

We can go back and forth on this ad infinitum, but come on; you must know that there are situations (judgement & discretion) where NC's don't need to be issued just because....

If the system has effectively identified it's flaw's, then it is in essence operating effectively in-respect to continual improvement and basic standard requirements. An auditor must then use judgement regarding when analyzing the evidence of such.

If the system demonstrates that it is, essentially, self-aware, why bother. Use Discretion and note the current activity and follow-up on it later. There are exceptions but again, judgement & discretion must be used when conducting an objective evaluation of not only a QMS system, but for anything.
I believe you have just described why there is variation among how auditors perform, even within the same CB.
 

amadisonr

Inactive Registered Visitor
During our recent certification to AS9100C we had NC's that were identified by our internal audit team. As a matter of fact, some of those items were written up and some were not.

I also have attended additional training on AS9101; this is specific to the CB point of view and I say that the answer is yes. If the condition of the non conformance has not been corrected then the NC still exisits. If the NC is in process of CA(corrective action) then in some cases they may review the corrective action and see if it is reasonable. It depends on the auditor. But in my opinion, I agree with Rickpaul01 that it doesn't really matter because you are already processing the CA.

Good luck
 
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