Now I am confused. What do you mean by stage 1 audits that you perform? Are you an auditor? You had said before
As for the stage1/stage 2 bundled activities, in my mind, it clearly goes against the intent of 17021. There is an obvious reason for the standard to state that the certification audit MUST/SHALL be split into Stage 1 and Stage 2. If you bundle the 2 stages together, you are clearly violating both the text and the intent of 17021. And, exactly because of people becoming too creative, ANAB had to clarify the issue with the Heads Up document.
Until people understand that CB's are should be in the confidence building business and not in the lobby wall adorning business, we wont have done a good job of educating our interested parties.
Below are the two items Sidney cited earlier from 17021 and from an ANAB Heads Up. The shall contained therein are in red print for emphasis:
The stage 1 audit
shall be performed to
a) audit the client's management system documentation;
b) 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) 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) 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) review the allocation of resources for stage 2 audit and agree with the client on the details of the stage 2 audit;
f) 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) 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.
9.2.3.1.2 identification of any areas of concern that could be classified as nonconformity during the stage 2 audit.
9.2.3.1.3 In determining the interval between stage 1 and stage 2 audits, consideration
shall be given to the needs of the client to resolve areas of concern identified during the stage 1 audit. The certification body may also need to revise its arrangements for stage 2.
Time Interval Between Stage 1 and Stage 2 Audits
What is the expected time period between the stages (stage 1 and stage 2) initial audits? Can these be done back to back?
The expectation and intent is that there be a time period between the stage 1 and stage 2 audits, as specified in ISO/IEC 17021:2006, 9.2.3.1.3, which states: “In determining the interval between stage 1 and stage 2 audits, consideration
shall be given to the needs of the client to resolve areas of concern identified during the stage 1 audit. The certification body may also need to revise its arrangements for stage 2.”
The reason the time period is not specified is because it depends on the results of the stage 1 audit, and the capability of the client and the resources it has available to resolve any areas of concern.
Even though the intent is that there be some period of time between the stage 1 and stage 2 audits, a CB and its client may agree conduct these audits back to back.
ANAB expects a CB to fulfill the intent of the standard and have a process that normally provides for some period of time between the stage 1 and stage 2 audits, and to have reasonable justification for this period of time based on the results of the stage 1 audit. It is ANAB’s expectation, consistent with the intent of the standard, that back-to-back audits be the exception, not the rule. ANAB also expects a CB conducting stage 1 and stage 2 audits back to back to be able to demonstrate that it clearly communicated to the client the increased risk that the initial audit would not be successful because the audits were conducted back to back, and that the client accepted the risk.
Some CBs have informed ANAB that they must do back-to-back audits in some geographic regions to be competitive. This is not considered acceptable justification. (ANAB has heard the same statements about audit duration). ANAB will expect to see technical justification and evidence of agreement by a client for back-to-back audits.
I don't see how any of the three places "shall" as used can clearly be applied in the manner Sidney has stated.
Sidney also said:
"As for the stage 1/stage 2 bundled activities (Sidney's terminology), in my mind (clearly a statement of opinion), it clearly goes against the intent of 17021."
Sidney goes on to state that this is the reason that ANAB issued a Heads Up on the topic, and posted that document.
In fact, the Heads Up does permit them to be (in Sidney's terms) "bundled".
